When selecting a company to provide edibles for your patients, there are many factors that come into play: efficacy, taste, packaging, and compliance with state law. In Colorado, a Manufacturer of Infused Products (MIP) must abide by certain guidelines laid forth by the Department of Revenue (DOR). While a MIP must complete an application and pass a health inspection, it is incumbent on Medical Marijuana Centers (MMC’s) to determine their labeling is up to code. Here’s what to look for, using Denver MIP Sweet Grass Kitchen as our study, per HB1284 and the DOR:
Does the edible contain:
a. an identity statement;
b. a net weight statement;
c. a list of ingredients;
d. a recommended use by or expiration date;
e. batch tracking information;
f. basic medical and/or legal warning information; and
g. statement of the company name and State Licensing Authority
license number, together with the company’s telephone number
or mailing address or website information;
From the example here, you can see clearly where Sweet Grass Kitchen has made the required disclaimers and provided product information. One issue that we found was an altering of the language that the DOR provides, specifically:
“This product is infused with medical marijuana and was produced without regulatory oversight for health, safety or efficacy and there may be health risks associated with the consumption of the product.”
While this information is paraphrased on the product, it is not identical to the preferred language and should be updated to reflect that exact phrasing. Additionally, MIP’s that include statements regarding the efficacy or milligram amounts in the product are encouraged to include the following statements:
- “The appropriate dose of medical marijuana may be different for each patient and medical condition. Please consult your physician or medical marijuana center.”
- “Levels of active components of medical marijuana reported on product labels are not subject to independent verification and may differ from actual levels.”
We would encourage all MIP’s to include this language, as it prevents any ambiguity over the intent of their product. A warning for children, while not mentioned in the rules specifically, is another element we think responsible MIP’s should move toward.
Overall, Sweet Grass Kitchen is one of the most complete labels we’ve seen for compliance and would recommend only minor changes.
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