DCR grants variance for variety packs of edible marijuana products

DCR grants variance for variety packs of edible marijuana products

The Division of Cannabis Regulation (DCR) has issued a department-initiated variance allowing Missouri manufacturing licensees to produce certain edible marijuana-infused product variety packs with minimal variations, such as differences in flavor or color, without violating existing bulk sampling rules.

The variance, announced August 15 and outlined in the document Variety Packs Variance (08.15.25), modifies the requirements in 19 CSR 100-1.110(5)(B)4 for these products. Under the standard rule, marijuana products may be sampled in bulk only after all processing of the harvest or process lot is complete.

With the variance, manufacturing licensees can combine process lots before mandatory testing when creating variety packs that meet the following conditions:

  • Products must be of the same type, with each individual item having the same volume and surface area.

  • Variations must be limited to flavorings or dyes that affect color.

  • All products in the variety pack must be made using the same ingredients (other than flavorings or colors), standard operating procedures, and harvest lots.

        

For example, a multiflavored gummy variety pack with blue, red, and yellow gummies would need to be produced under the same procedures, using the same base ingredients, and from the same harvest lots. The three flavor batches would then be combined before being sampled for mandatory testing by a licensed testing facility.

The variance applies only to edible marijuana-infused products and does not extend to inhalable marijuana products such as vaporizer cartridges or products intended for smoking.

According to DCR, variety packs covered by the variance must still comply with all process lot requirements and will undergo the standard item approval process. If a product is not eligible for the variance, it will be denied during review.

In the notice, DCR Deputy Director Erica Ziegler stated that the variance was issued to provide manufacturers “the same ability to produce a variety pack with minimal variation no matter the timing the different flavors and/or colors of candies are introduced prior to sampling for mandatory testing.”

The full variance letter and guidelines are available on the Facility Communication and Guidance page on the DCR website.