DCR makes additional guidance changes

On Wednesday, the Division of Cannabis Regulation (DCR) of Missouri announced updated guidance for facility licensees regarding labeling requirements.

This new directive, which becomes effective on June 3, 2024, provides clarifications and variances to previous guidance from DCR.

On March 8, 2024, the DCR granted a variance from the existing labeling requirements specified in 19 CSR 100-1.120(1)(C)2. The revisions were made under the authority of 19 CSR 100-1.020(1)(A), following the DCR’s assessment that some of the current labeling practices were redundant.

Revised Labeling Guidelines:

   

1. Barcode Display: Licensees are now permitted to display a standard barcode next to or below the statewide track and trace system tag number associated with the mandatory testing results for the final marijuana product. This standard barcode may also be placed next to or below the source package tag number if the licensee opts to include this information.
2. Cannabinoid Percentages: Licensees can list cannabinoid percentages per package values, including Total delta-9-tetrahydrocannabinol (Δ9-THC) and Total cannabidiol (CBD), on the final product label. To do so compliantly, licensees must:
   • Select “Additional – Mandatory Cannabinoid % and Totals” when creating the test sample in the statewide track and trace system, in addition to the appropriate “Mandatory” testing category.
   • Include cannabinoid percentage results on the final product label immediately following the milligrams per serving/dose (mg/serving-dose) for each required cannabinoid.
   • Report Total Δ9-THC and Total CBD in milligrams per serving/dose and percentage values directly below the required cannabinoid profile.

Importantly, licensees are not allowed to send separate samples for independent cannabinoid percentage and total calculations to be included on the final product label.

According to the letter signed by Andrea Balkenbush, “DCR has determined the good cause for granting these variances is that licensees may utilize a standard barcode to assist with proper statewide track and trace system tracking requirements of final marijuana product; and licensees may list cannabinoid percentages, including Total Δ9-THC and Total CBD, to assist patients and consumers with final marijuana product administration.”

Licensees are urged to review the associated FAQs for detailed compliance instructions, which are available here.