Michigan’s Cannabis Regulatory Agency (CRA) Announces New Rules for Package Tagging and Product Combining

Michigan’s Cannabis Regulatory Agency (CRA) has introduced new guidelines allowing cannabis operators to package and sell multiple varieties of infused edibles and vape cartridges under a single Metrc package tag. This change comes in response to requests from licensees who wanted the ability to combine different product flavors, colors, and strains into a single package.

What is a Multi-Pack? New CRA Definition Explained

A multi-pack, according to the CRA, is defined as a package containing two or more varieties of the same item—either infused edibles or vape cartridges—grouped together and sold as one unit under a single Metrc package tag. This new rule will streamline packaging and labeling, enabling operators to sell a variety of products without the need to attach or scan multiple labels for each individual item.

However, the CRA has outlined several important considerations for licensees before creating multi-packs. While this move simplifies the packaging process, it also co-mingles separate SKUs (Stock Keeping Units) and product testing results under one package tag. This means that if any issue arises with one of the products in the multi-pack, such as a safety concern, administrative holds or product recalls could be applied to the entire multi-pack, impacting all products within it.

Potential Risks and Warnings for Cannabis Operators

While the new rule offers more flexibility for product offerings, the CRA has cautioned operators to carefully weigh the potential risks. Combining different products under one package tag could complicate quality control and lead to challenges when managing product recalls or addressing consumer complaints. Licensees are advised to consider all risks before moving forward with multi-pack creation.

This guidance underlines the responsibility of cannabis operators to ensure that the products they combine meet all safety standards and comply with the state’s regulations.

Important Guidelines for Multi-Pack Creation

The CRA’s technical bulletin further emphasizes that multi-packs can only contain items within the same category. For example, a combination of an infused edible and a vape cartridge would not be allowed in a multi-pack. Additionally, when combining infused edibles, each product within the multi-pack must have the same THC concentration and quantity. Operators cannot combine products with varying THC levels, such as a 10mg red gummy and a 20mg blue gummy, into the same multi-pack.

This stipulation ensures that multi-packs remain consistent in their dosage and adhere to Michigan’s legal limits on THC per serving and per package. Each package of infused edibles, regardless of the variety, must stay within these maximum THC thresholds to ensure safety and compliance.

CRA’s Ongoing Commitment to Safe and Compliant Cannabis Practices

While the introduction of multi-packs provides new opportunities for operators to innovate and expand their product offerings, the CRA is dedicated to ensuring that consumer safety and product integrity remain a top priority. The agency continues to monitor the evolving cannabis market and adjust its regulations to meet the needs of the industry while safeguarding public health.

Operators Must Be Mindful of New Multi-Pack Regulations

With the ability to create multi-packs, cannabis licensees in Michigan now have greater flexibility in how they package and sell products, potentially leading to more attractive offerings for consumers. However, operators must proceed with caution and consider the regulatory and operational risks associated with this change. By adhering to the CRA’s guidelines, cannabis operators can ensure compliance while meeting consumer demand for diverse product options.