The Missouri Division of Cannabis Regulation (DCR) has issued new communications regarding a variance for marijuana product labeling requirements, aiming to streamline the process and enhance the information available to consumers and patients. The announcement, made by Jennifer Zamkus, Director of the Section for Compliance & Enforcement at the DCR, outlines specific changes permitted under the variance from standard labeling requirements as outlined in 19 CSR 100-1.120(1)(C)2.

Under the new variance, cannabis product labels can now include a standard barcode linked to the package tag number, facilitating easier tracking and verification in line with the state’s mandatory tracking system. This barcode must be placed directly next to or under the statewide track and trace system tag number associated with the mandatory testing results for the final marijuana product, or next to the source package tag number as allowed by a previous variance dated August 18, 2023.

The variance also allows licensees to list the percentage of cannabinoids per gram (%/g) on the final product labels, including totals for delta-9-tetrahydrocannabinol (Δ9-THC) and cannabidiol (CBD). This information must be based on calculations made for the representative sample collected by the testing licensee during mandatory testing.

To include these percentages, licensees must select “Additional – Mandatory Cannabinoid % and Totals” when the test sample is created in the statewide track and trace system, in addition to the product’s designated “Mandatory” testing category. The cannabinoid %/g results must be listed on the label immediately after the milligrams per serving/dose for each required cannabinoid.

The variance will take effect following implementation changes in Metrc, the statewide track and trace system. The DCR will notify licensees when these updates have been completed and the new labeling practices can begin.

The newly issued FAQs provide further clarity on reporting requirements, stating that licensees must report the exact milligrams per serving/dose (mg/serving-dose) of eight specific cannabinoids, including Δ9-THC, CBD, and others. This information must be presented in terms of mg/serving-dose, not milligrams per gram (mg/g), with the licensee responsible for determining the serving or dosage size.

For cannabinoid content, the variance also allows for the inclusion of percentage per gram (%/g) values on the label, following the mg/serving-dose listing for each required cannabinoid.

Licensees with previously approved products can request to add the new labeling features by contacting DCR.

The variance will take effect following implementation changes in Metrc. DCR will notify licensees when the updates have been completed and the new labeling practices can begin.

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