It is no secret that big changes are coming to cannabis on October 1st and it's enough to cause everyone concern. Here are the most important things to know for this rapidly approaching date:
1. Packaging and Labeling- Your packaging and labeling needs to be approved for your product to be on the dispensary shelf. The packaging and labeling requirements are really tricky and I recommend that you read through this guide to fully understand what is expected of you. And, if this does not make you want to poke your eyes out, you can go even deeper with this powerpoint. Applying for approval is a little confusing and we will do a separate blog on this.
2. Labs- After October 1st you may only have your product tested by an ORELAP certified lab. Supposedly you can go to this page to see the list of accredited labs. However, the only list that exists here is a long list of labs that are not accredited. Remember this is not the same thing as a lab being licensed by OLCC. There are currently no labs licensed by OLCC although seventeen labs have applied.
3. Processors- Perhaps the biggest challenge for OHA has been the processor piece. On October 1st all types of processors have to be licensed by the OHA in order to sell to dispensaries. This is, in our opinion, not going to happen. We have been told, but are pending confirmation, that the provisional license process will stay in place and the benefits will be extended to concentrate makers, edible producers and everyone else not making extracts. We are also being told that if you are an extractor on the list but have not received a license yet, you will continue to be able to extract past October 1st. Updates will follow as we receive this in writing.
4. New concentration and serving size limits- Now is the time to start reconciling this if you are a processor. While existing inventory in dispensaries may be sold off under particular labeling and packaging requirements, moving forward only products that comply with the new limits will be accepted. Here is the chart for medical limits and here is the chart for adult use.
5. ODA requirements- after October 1st dispensaries selling edibles (and edible companies) must have a food safety license from the ODA. Here is the checklist. If you have not read this and it applies to you, go read it. There is a ton of information here and you do not want to be tripped up when you are otherwise licensed and compliant.
As always, if you need help understanding and complying with these new rules give us a call. We can walk you through these changes and answer any other questions. Good luck out there!