Understanding Cannabis Product Labels

Cannabis product labels contain a great deal of information, most of it required by the Cannabis Regulations. It can sometimes be confusing for consumers to understand everything that is present on a label. The Regulations prescribe what, where and how information must appear on the label of all cannabis products. In this article, we’re going to break down some of the important aspects of a cannabis product label, which will hopefully give you a better idea of all the information that is being shown to you.

The Cannabis Regulations require plain packaging and labelling for all cannabis products with restrictions on logos, colours, and branding. Furthermore, cannabis products must be labelled with the standardized cannabis symbol, the mandatory health warning message, and include specific product information (e.g., brand name of the cannabis product, class of cannabis, delta-9-tetrahydrocannabinol (THC) and cannabidiol (CBD) information, plus licence holder information).

These measures are designed to:

• Reduce the attractiveness and appeal of cannabis products (just like cigarette packaging), particularly to young persons;
• Make the standardized cannabis symbol and health warning messages more prominent and noticeable on the product label;
• Provide consumers with accurate information about the content and use of the cannabis product.

Common Elements Required for All Classes of Cannabis Products

We’ll start by covering some of the common label elements required on all classes of cannabis products (e.g. dried flower, cannabis extracts/concentrates, cannabis topicals, and edibles).

All information on a cannabis product label must be in English and French (except for International Nomenclature of Cosmetic Ingredients (INCI) names and European Union (EU) trivial names) and be clearly and prominently displayed, and legible under normal conditions of purchase and use.

Every cannabis product label must have a principal display panel (PDP) that must appear on the principal display surface of the container. This is the surface that is displayed or is visible under normal or customary conditions of purchase or use.

Here’s what must be present on the PDP:

• Standardized Cannabis Symbol – This symbol must be displayed on the PDP of the label. It is used to inform and warn consumers that the cannabis product contains THC. The standardized cannabis symbol must appear on the label of all cannabis products containing THC in a concentration greater than 10 μg/g, taking into account the potential to convert THCA into THC.

• Health Warning Message – This message must be displayed on the PDP of the label. It is comprised of a primary and secondary message in a yellow box, to inform and warn consumers of the potential health risks and effects of using cannabis. The full list of health warning messages is available on Health Canada’s website. The different health warning messages must be displayed in rotation on each type of container, and of each brand name of the cannabis product that is packaged in a year, so that each message is displayed (to the extent possible) on equal numbers of containers of that product. Because of this, you may see a different health warning message on different cannabis product labels at different times.

• THC and CBD Content – The unit of measure of THC and CBD content (represented by quantity (mg) or concentration (mg/g)) must be displayed on the PDP of every cannabis product. This information may be displayed differently depending on the class of cannabis in the immediate container, whether the cannabis product is in discrete units or not, and the intended use of the cannabis product. (See the example below of the THC/CBD listing for a cannabis topical)

• Brand Name – The brand name of the cannabis product must be displayed on the PDP of the label. However, it must not be in metallic or fluorescent colours. It can be in any type style, but the type size must be smaller than or equal to the type size used for the health warning message that appears on the label.

• Additional Brand Element – Only one other brand element (in addition to the brand name) may be displayed on the PDP of the label. This element could include, for example, a slogan or logo. It must not be in metallic or fluorescent colours. If the brand element is an image or graphic, the surface area must be smaller than or equal to the surface area of the standardized cannabis symbol that appears on the label. If the brand element is text only, the type size must be smaller than or equal to the type size used for the health warning message that appears on the label.

Required Information About the Cannabis Product

In addition to the comment elements listed above, the Regulations require all cannabis products to be labelled with specific product information. This info must be displayed on either the PDP or the area of the cannabis product label that is visible under customary conditions of purchase and use (i.e., the exterior display surface). This information must also be presented in both English and French.

Here is a list of additional information that is required to be shown on a cannabis product label:

• Contact information of the licence holder – so that the consumer is able to contact the licence holder in the event of any questions, comments or a product recall.
• Class of cannabis – so the consumer is made aware of the class of cannabis inside the packaging.
• Lot number – used to associate the product with a particular manufacturing/harvesting batch. The lot number helps trace the product back to quality control processes, and is useful in the event of a product recall or inquiry.
• Recommended storage conditions – to ensure the quality of the cannabis product is maintained.
• Packaging date – indicates when the finished product was placed and sealed in its final packaging.
• Expiry date – to communicate to the consumer the stability of the product in regard to potency. The cannabis product should be used before the expiry date.
• Net weight – indicates the total weight of cannabis in the package.
• Net volume – indicates the net volume of the edible cannabis (not in solid form), expressed in numerical values followed by millilitres (mL).
• Number of discrete units, if applicable – indicates the number of individual units (e.g. 10 capsules, 10 chocolates).
• Net weight per discrete unit, if applicable (e.g., 10 grams per capsule).
• Cannabis possession statement – the statement “Contains the equivalent of ## g of dried cannabis” where ## is the equivalent quantity of dried cannabis, in grams. This statement allows easy determination of dried cannabis equivalence, as the maximum public possession limit is up to 30 grams of dried legal cannabis at any time.
• The warning statement “KEEP OUT OF REACH OF CHILDREN / TENIR HORS DE LA PORTÉE DES ENFANTS” in upper case font – to ensure that cannabis products are kept away from youths.
• Identity by common name of product or its function – the generic name of the product may be the name of the cannabis product form (e.g., cream, drops, capsule, chocolate) for ease of understanding.
• Intended use(s) of cannabis product – (e.g., inhalation, ingestion, for use on skin, etc.)
• Durable life date – also known as a “best before” date. This is required for edible cannabis that has a durable life date of 90 days or less (e.g., Best before 19 JN 28).
• List of ingredients (and constituents) – to inform the consumer fully and accurately of all the components in the cannabis product.
• Sources of food allergen or gluten, and added sulphites – informs consumers of any potential food allergens, gluten or added sulphites. This includes any cross-contamination statements.
• Nutrition facts table – required for edible cannabis, and informs consumers of the nutritional facts regarding said product.

Other Information About the Cannabis Product

Licence holders may also provide additional product information regarding the proper use of their cannabis products. This information could include:

• Directions for use of the product
• Information about the product form or formulation
• Other warnings and precautions

We hope this article has shed some light on all the information that is present (and required) on a cannabis product label. Remember, product labels are a means of providing consumers with the information they need to make informed decisions before using cannabis. Therefore, compliant cannabis product labels are an absolutely must!

How we can help you

At Cannabis License Experts, we provide you with the guidance to plan your cannabis business, acquire funding, navigate the legal requirements, and acquire the appropriate licence for your operations. As the Canadian cannabis industry develops, more and more licensed producers will be needed to meet the demands of consumers.

Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs, Preventive Control Plans (PCP), cannabis product label reviews and more.

Our Edibles Compliance division can provide you with a solid plan for your edibles business to help get your products on store shelves.

Contact us today to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.