DCR Releases new guidance on item approval

DCR Releases new guidance on item approval

 

Late last week, the Division of Cannabis Regulation (DCR) released new guidance regarding the Item Approval process for Missouri marijuana operators.

DCR states that this process is designed to ensure transparency and consumer confidence by providing detailed product information and images to the public through the statewide track and trace system, Metrc.

To help licensees navigate this new process, the DCR has provided a comprehensive checklist that outlines the necessary documentation for a complete Item Approval submission. Licensees are encouraged to use the checklist below to ensure that all the requirements for Item Approval are met.

Upload in Metrc:

  1. ☐ Physical Product Photo (JPEG or PDF): Licensees must submit a clear photo of the entire final marijuana product intended for distribution. If a product contains multiple servings and/or doses, a photo of a single serving and/or dose should be provided.
  2. ☐ Label (PDF): A single PDF file of the label information, known colloquially as the “testing label” or “label required by rule,” must be included. The label should list all required information in the proper order.
  3. ☐ Physical Packaging Photo (JPEG or PDF): Licensees should provide a clear photo of the entire final marijuana packaging intended for distribution, including all printed content, display panels, and wrappers.

Upload in Box.com:

  1. ☐ Item Approval Application: The Item Approval Application is a critical document that licensees must submit.
  2. ☐ Mockup/Dieline of Packaging (PDF): This refers to the template that ensures the correct layout of the final physical package in a flattened form. Licensees should also submit interior packaging dielines if applicable.
  3. ☐ Logo or Symbol 1 (PDF) – if applicable: Licensees should include any logos or symbols associated with their product.
  4. ☐ Logo or Symbol 2 (PDF) – if applicable: Additional logos or symbols, if necessary.
  5. ☐ QR Code (PDF) – if applicable: If the product includes a QR code, it should be included in the submission.
  6. ☐ Child-Resistant Certification for Package (PDF or Word): Certification ensuring that the packaging is child-resistant is required.
  7. ☐ Package Specification Sheet (PDF or Word): A document detailing the specifications of the packaging should be included.
  8. ☐ Package Manufacturer’s Food Grade Statement, or Certificate of FDA Compliance (PDF or Word): This statement should be obtained from packaging vendors and/or manufacturers.

DCR instructs licensees to request child-resistant certification, package specification sheets, and food-grade statements from their packaging vendors and manufacturers.

Additionally, DCR provided specific guidance for the photos required in the Item Approval process.

Product Photo: This should be a clear image of the entire final marijuana product on a solid neutral color background. If a product contains multiple servings and/or doses of the same flavor/strain, a photo of a single serving and/or dose should be submitted.

   

Label Photo: A single PDF file of the label information, including all required information in the proper order, should be provided. Leave variable or unknown content blank.

Packaging Photo: This should be a clear image of the entire final marijuana packaging, including all printed content, display panels, and wrappers, on a solid neutral color background.

DCR states that photos should not include embedded brand or product logos and should not be styled in a way that includes raw ingredients, marijuana leaves, or additional branding imagery.

 

In addition to the checklist and photo requirements, DCR also addressed reported issues related to the implementation of Metrc, the statewide track and trace system used to upload item approvals. DCR states that problems with Metrc functionality have been resolved, and there are currently no functionality issues within the system.

Licensees encountering issues with integrated Metrc are I instructed to track their daily operations directly in the system and report system issues to CannabisDevelopment@health.mo.gov.

See the documents in full here below.