The Missouri Division of Cannabis Regulation (DCR) released new guidance on Monday, aimed at streamlining the item approval process for marijuana product designs, packaging, and labeling. The guidance, effective immediately, introduces efficiencies for submitting template-based items, allowing licensees to expedite approvals for products differing only in flavor or strain.

The Item Approval process, initially implemented on September 1, 2023, under 19 CSR 100-1.120(2), requires compliance review of all marijuana product designs prior to use. This step ensures products and packaging are designed to protect public health.

Under the new guidance, once a licensee receives Department approval for a template item through the statewide track and trace system (Metrc), they can submit variations based on that approved template. The new items may only differ in flavor or strain, with placeholders used to indicate these differences. For example, a gummy product would list “natural [flavor (e.g. lime)] flavoring” to denote the variable ingredient.

Licensees can submit all template-based items at once, potentially reducing review time. The approved items will receive an approval number, found at the beginning of the item name.

Data for approved template-based items must be submitted in a CSV file format to CannabisProductCompliance@health.mo.gov, accompanied by a completed Item Approval Application. The email subject line should follow the format: Licensee # – Approved Template Number Item Name.

Licensees are not required to submit unique labels for each template-based item. They may use the same label file as the original approved template and attest that the items match the approved template.

Sections 4-6 of the Item Approval application, which identify logos, symbols, side or behavioral effects, and a QR code, are not required for template-based items, as these elements must remain consistent with the approved template.

The new guidance document can be accessed here.

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