Oregon’s Marijuana Labeling Rules
Whether you are involved in the medical or recreational side of the Oregon cannabis industry, you will likely be required to comply with new labeling regulations on and after October 1, 2016. These regulations, contained in Oregon Administrative Rule 333-007-0010 to 333-007-0100, apply to all recreational licensees at all times during licensure, and most medical registrants. These labeling requirements do not apply to you if you are:
- A grower providing usable marijuana or an immature plant to a patient who designated you as their grower or to the caregiver of a patient who designated you as their grower; or
- A designated caregiver who is transferring a marijuana item to the patient who designated you as their caregiver
Generic Labels
A label that provides only the necessary information required by the rules, and no graphics, photographs, or logos, is considered a “generic” label and requires no pre-approval. You are not required to provide notice to OLCC that you will be using a generic label.
Pre-Approved Labels
All other labels require pre-approval from OLCC before they may be placed on a marijuana item. OLCC licensees and OHA registrants may submit labels for pre-approval through the OLCC’s licensing portal. Although not ideal, if you are unable to obtain pre-approval prior to October 1, 2016, you may use a generic label until you are pre-approved. Going forward, certain label information may be changed without the need for a new pre-approval. The OLCC has been working on detailing what label information this applies to (e.g. strain, net weight, test results, etc.). We will update you as we learn more.
General Requirements for Labels
A container holding a marijuana item must have a principal display panel (PDP) that provides:
- The product’s identity;
- The universal marijuana symbol at a minimum size of .48” x .35 inches;
- If applicable, the medical grade symbol at a minimum diameter of .35 inches; and
- Net weight in US Customary and metric units.
Labels must:
- Be in English, minimum 8-point font, Times New Roman, Helvetica, or Arial;
- Be unobstructed and conspicuous;
- Comply with National Institute for Standards and Technology (NIST) Handbook 130 (2016), Uniform Packaging and Labeling Regulation; and
- Include all laboratories, batch testing numbers, and dates tested.
Pictograms may be used in place of written label information where appropriate, such as for activation time. 
Specific Labeling Requirements by Product Type
Follow the links below to find administrative rules containing lists of labeling requirements for each different product type.
- Immature Plants – OAR 333-007-0030
- Seeds – OAR 333-007-0040
- Usable Marijuana – OAR 333-007-0050
- Topicals – OAR 333-007-0060
- Edibles – OAR 333-007-0070
- Concentrates and Extracts – OAR 333-007-0080
- Tinctures – OAR 333-007-0083
- Cannabinoid Products other than Edibles, Topicals, or Tinctures (includes capsules, suppositories, and transdermal patches) – OAR 333-007-0085
Prohibitions
A label may not contain any untruthful or misleading statements. These include:
- Use of the term “organic” unless the product has been certified;
- Claiming that the product is gluten-free, unless labeling follows FDA labeling requirements for gluten-free products; and
- Health claims that have not been substantiated by the totality of publicly available scientific evidence, for which there is scientific agreement among experts.
A label must not be attractive to minors. This includes:
- Brands or designs that resemble a product marketed to children;
- Brands or designs typically marketed to children;
- Cartoons; and
- Images of minors.
For more information, please visit the OLCC’s page for packaging and labeling pre-approval. There you will find links to guides, workshop presentations, and frequently asked questions. If you have further questions, please contact one of our compliance attorneys and we will be happy to assist you with your labeling or other needs.
Tune in tomorrow for information on packaging requirements under the new rules.