Missouri’s Division of Cannabis Regulation (DCR) has recently rolled out new guidelines for approving cannabis products, and we’re here to break it down for you. Whether you’re an established player in the industry or a newcomer, understanding these steps is crucial.
1. Choosing the Right Category
The first step is choosing the correct item category. When submitting a cannabis product for approval, select “(Final Packaging)” from the Category drop-down menu. This step is critical, determining whether your product enters the approval process queue.
2. Completing Mandatory Fields
Once you’ve chosen the right category, fill out all the mandatory fields in the submission form. This information is vital for the approval process. After providing all necessary details, click the “create items” button to initiate approval.
3. Be Prepared for Additional Documentation
During the review process, the DCR may request further documentation via email. It’s crucial to respond promptly. You have seven calendar days to provide the requested documents; failure to do so may result in the denial of your approval request.
4. Uploading Packaging Photos
Sometimes, you may need to get the physical packaging ready when submitting your product. In such cases, you must declare your intent to upload a photo of the final packaging after receiving it but before distribution. To do this, request DCR’s assistance to unlock the items for photo upload. You’ll need to provide the item approval number generated by Metrc.
5. Ingredient Lists
You must complete the public ingredients field for every submitted item, including solvents used in the extraction process. If the list of product ingredients exceeds the 1,000-character limit, continue in descending order within the “Item Ingredients” field(s) after exhausting the “Public Ingredients” field. Use the “+” button in the item creation window to add “Item Ingredients.”
6. CBD Content Fields
Good news: you no longer need to enter zero (0) in the CBD content fields when creating an item. Instead, identify additional cannabinoid ingredients within the item name, possibly in a ratio format, for clarity.
7. Approval Number and Categories
After implementing the Item Approval process, every item category will receive an approval number. Items created in categories without “Final Packaging” will automatically receive an approval number but won’t be considered approved for use. Approval for product, packaging, and label designs is mandatory before distribution.
8. Keep an Eye on Notifications
You’ll receive notifications about the status of items submitted for approval. There are five possible statuses: “Ready,” “Under Review,” “Rejected,” “Approved,” and “Denied.” For “Final Packaging” items, refer to the “Approval” column on the things screen for the approval status.
9. Handling Denied Items
DCR will provide reasons in the item notes if an item is denied approval. The next step is to delete the item in Metrc and generate a new one with the necessary changes before resubmitting.
10. Packaging Design Compliance
The interior and exterior of packaging designs must meet specific requirements outlined in 19 CSR 100-1.120(1)(B). This includes limitations on colors, logos, and symbols used. Review the Packaging, Labeling, and Product Design Guide for detailed information.
For any questions or feedback regarding packaging, labeling, product design, compliance, or the Item Approval process, don’t hesitate to contact the Product Compliance Team via email at CannabisProductCompliance@health.mo.gov. Additional information is also available on the DCR website.
The Item Approval process is pivotal in ensuring that cannabis products meet regulatory standards and contribute to a safe and compliant industry in Missouri. Following these guidelines will streamline the approval process and help you avoid compliance issues.
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