It’s hard to believe the first few months of 2018 are already behind us. While the new 2018 rules might feel like old news, it’s easy to forget that not all new rules took effect January 1. There are some major deadlines approaching this summer that should be on your calendar. Specifically, now is the time to really dig into the new packaging and labeling rules if you haven’t already.
Preparing for new packaging and labeling rules requires a tremendous amount of effort and planning. To help guide your efforts, the MED issued Industry Bulletin 18-03. This bulletin is arguably the most lengthy and detailed bulletin the MED has ever issued, and we are grateful for this detailed guidance. Let’s talk through some of the top considerations detailed in the bulletin:
First, be sure to take note of some key deadlines. Beginning July 1, 2018, med and rec dispensaries will no longer be able to take possession of products with legacy packaging. In other words, all MIPs/OPCs must have all of their product with “old” labels out the door by June 30, 2018. Thankfully, dispensaries have until July 1, 2019 to unload any of this older product (provided it doesn’t expire prior to July 1, 2019). This is the longest packaging/labeling grace period in MED history!
Additionally, we want to call special attention to the varying requirements for products during transfer from license to license and transfer to patient/customer as well as specifications for containers versus Marketing Layers. The MED provides the following definition:
“Marketing Layer” means that packaging in addition to the Container that is the outermost layer visible to the consumer at the point of sale. The Marketing Layer is optional, but if used by a Licensee in addition to the required Container, it must be labeled according to the requirements in Rules M 1001 et. seq. or Rules M 1001-1 et. seq.
As the industry has matured, the use of Marketing Layers has become quite common, so this is going to impact many businesses across Colorado.
Clearly, these new packaging and labeling regulations are another big change for the industry. Big change isn’t new for us, but be sure to allow ample time for packaging/labeling design, ordering, and roll out. Good luck!
Yours in Compliance,