DCR releases new guidance and form for final item approval submissions
On Monday, Missouri’s Division of Cannabis Regulation (DCR) released new guidance for its item approval process.
Yesterday, DCR also uploaded the new Item Approval Application form, which can be found here.
In this article, Greenway breaks down the key steps and information regarding the submission of final marijuana products for approval.
1. Selecting the Correct Item Category
One of the crucial steps in submitting a marijuana product for approval is selecting the appropriate item category. When entering an item for approval, licensees must ensure they choose a “(Final Packaging)” item category from the Category drop-down menu. Failure to do so will result in the item not entering the review queue for the Item Approval process.
2. Completing Required Fields
After selecting the correct item category, licensees should fill out all the required fields in the submission form. Once all the necessary information has been provided, click the “create items” button at the bottom of the item window. This action initiates the Item Approval process, and the item will enter the queue for review.
3. Additional Documentation Requests
During the review process, DCR may request additional documentation via email. Licensees have seven (7) calendar days to provide the requested documentation. Failure to do so may result in the denial of the approval request.
4. Uploading Final Packaging Photos
In some cases, licensees may not have physical packaging available for a packaging photo at the time of submission. In such instances, licensees must attest on the Item Approval Application that they will upload a photo of the final packaging after receiving it but before distribution. Additionally, licensees must request DCR’s assistance to unlock the items for the photo upload, including providing the item approval number generated by Metrc.
5. Handling Ingredient Lists
Licensees are required to fill out 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, licensees should continue the list, ingredient by ingredient, in descending order, within the “Item Ingredients” field(s) after exhausting the “Public Ingredients” field. To add “Item Ingredients,” use the “+” button in the item creation window.
6. CBD Content Fields
Licensees are no longer required to enter zero (0) in the CBD content fields when creating an item. DCR has removed this requirement. Instead, licensees should identify additional cannabinoids ingredients used within the item name, possibly in a ratio format for clarity.
7. Approval Number and Categories
All item categories will receive an approval number with the implementation of the Item Approval process. Items created in item categories without “Final Packaging” will automatically receive an approval number but will not be considered approved for use. Approval for marijuana product, packaging, and label designs is mandatory before distribution.
8. Notifications and Status Updates
Licensees will receive notifications about the status of items submitted for approval. There are five possible statuses: “Ready,” “Under Review,” “Rejected,” “Approved,” and “Denied.” The “Approval” column on the items screen should be referred to for the approval status of “Final Packaging” items.
9. What to Do If an Item Is Denied
If an item is denied approval, DCR will provide reasons within the item notes. Licensees must delete the item in Metrc and generate a new item with the necessary changes before resubmitting.
10. Packaging Design Compliance
Both 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. Licensees are encouraged to review the Packaging, Labeling, and Product Design Guide for detailed information.
In case of questions or feedback related to packaging, labeling, product design, compliance, or the Item Approval process, licensees can contact the Product Compliance Team via email at CannabisProductCompliance@health.mo.gov. Additional information can also be found on the DCR website at https://health.mo.gov/safety/cannabis/facility-comms-guidance.php.
The Item Approval process is a critical step in ensuring that marijuana products in Missouri meet regulatory standards and contribute to a safe and compliant cannabis industry. Licensees are urged by DCR to follow these guidelines diligently in order to streamline the approval process and avoid any compliance issues.
