Updated: Sep 2
Take your brand to market with legalisation in your mind.
Packaging needs to be at the forefront of all Hemp & Cannabis businesses in South Africa. You can sell CBD legally, but THC is still illegal, the approaches of good practice on labelling products can be difficult because, at the moment, there is no legislation on labelling for the South African Cannabis sector.
The Hemp & Cannabis packaging industry is one of the fastest and innovative growing retail sectors in the world. According to Zion Marketing Research, the Global cannabis packaging industry is expecting to reach US$ 20.41 billion by 2025, which is an estimated growth of 7.1% between 2019 and 2025. Internationally, packaging in this sector is a very tedious process, as regulations keep changing and governments of different countries impose different legislation. A recent law is on child-resistant packaging that came in to effect on 1 January 2020 in the US and Canada and then rolled out to other legal countries in Europe. With these ever-changing challenges, the Cannabis packaging sector can be a leader in innovative packaging design.
The Hemp & Cannabis industry still needs to educate consumers on products in the health and medicinal sectors. It is here where listing ingredients on Hemp and Cannabis packaging will help build brand loyalty. Researching local and international packaging guidelines, I’ve tried to find standard approaches to take into consideration.
These guidelines can add value and instil consumer trust in your brand. Why I researched the international standards is because, in South Africa, some products containing THC and CBD have no or very little ingredient information. Coming from a packaging background, this raises concerns for consumers as well as the Hemp & Cannabis industry. Incorrect labelling may cause an adverse reaction for a user, and this can damage your brand that you are trying to build, and may lead to lawsuits.
This packaging recommendation can work for both CBD as well as THC labelling. Before I proceed, my disclaimer. These are suggestions and not South African regulations. Note, the sale of products containing THC is illegal in South Africa.
So what if… cannabis legalisation happened tomorrow?
It is always advisable that you test your product in an ISO accredited testing facilities, it will add credibility in your brand. Whether it’s a Hemp or Cannabis manufactured products, test your product and establish the right ingredients list, know what the levels of THC and CBD are. If you are looking to expand into an international market, you will need these tests, or your product will have to be tested overseas.
If you are planning to test your flower, oils and medicinal cannabis products or even beauty products, use a lab with ISO/ICE 17025 and ISO/ICE 17025 and SR 2407certification, which is an international standard for testing.
Manufacturing of large scale edibles and beverages especially for export, needs to be done in a facility that is ISO 22000 certified, or if you have a facility, you may want to look into this certification?
Supplying an accurate ingredient list on your packaging is a selling point. It will help you educate your customer, especially first time users. The bummer is if you are planning to ship internationally, then you may need to adjust your label to meet the requirements of that country.
Popular packaging materials are glass, plastics, cardboard and blister, reputable brand agencies and printers can guide you on the best finishes. Over the last couple of years, there has been a strong movement to environmentally friendly and bio-degradable packaging. Some of the international concepts are attractive glass packaging that can be refilled when you go back to your dispensary or social club. Another trend is organic packaging made out of Hemp or Bamboo.
There are general labelling requirements for Hemp & Cannabis industry that are standard in most countries. Accurate testing and content labelling for these countries is legally required.* Below are some suggested and lose rules to apply to cannabis-based products. FDA Cannabis packaging regulations.
- Your label should be easy to read.
- Add a common descriptive name for the product like chocolate or chewing gum.
- Manufacturers and/or Company name and contact information. (Not a good idea for now in South Africa for THC products. An alternative is email contact, or a comment section on affiliated websites.)
- Net quantity of content. Example 60 tablets with a total amount of CBD/THC.
- The US requires product packaging to have a license code. More common requirements, in Europe, are a batch code which helps with product tracking.**
- Ingredients list. People want to know what they put into their body. List all the ingredients that are in the product in measuring units.
- Nutritional facts.
- What is your final product made of excluding THC or CBD? There are 6-major nutrients which are Carbohydrates (CHO), Lipids (fats), Proteins, Vitamins, Minerals, Water.
- THC Potency. THC is a psychoactive component. Research shows that consumers want to know the potency of the product they consume. A lot of consumers are not looking for the ultimate high and take Cannabis to assist with medical conditions.
- If you have more Cannabinoid measurements for your product, you could display this as well. Research shows it is not a rule but could add value to your brand.
- Allergen warning. International food and beverage packaging laws state that you must have allergen warning notifications. A Warning example, “Made on equipment that also processes milk.”
- Potency Per Manufacturer-Specified Unit. If you are producing, let’s say jelly beans, then you would need to stipulate the THC/CBD of each single jelly bean. Every country has its maximum allowance. Please note in South Africa, it’still illegal to sell products with THC.
- Potency Per Container or By Weight/Volume. It means that if you have 60 tablets in a container, give the total value of xx mg of THC/CBD as a total in a pack.
- Acceptable Variance. We all know that there may always be a slight variation in manufacturing, Afterall we are only human. So it would be advisable that you add this as a disclaimer to your copy. An acceptable international percentage is +/-10%.
- Adding a contaminant testing statement on your packaging is part of good practice. Only add this on your packaging if you have tested the product and have the certification. This information would read, “This product is free of pesticides, mould and other harmful products.”
- In the US and Canada, the government state that the label should state where Cannabis is grown and manufactured. They have developed an icon “universal warning sign”. The icon in the US may consists of the state letters, where Canada has a single icon showing that the content contains “THC”.
- Add Warning statements to your packaging; this is part of good practice, an example “KEEP OUT OF REACH OF CHILDREN AND PETS.”
- Stay clear of misleading statements. Folks I know, Cannabis helps with a lot of conditions, the operative word is “help”. You can not make statements that the content of this product is a cure for cancer. You can, however, say that “it may assist with…”. Definitive statements may damage your brand and lead to lawsuits or government can ask you to withdraw the product.
Both the US and Cannada and later Europe stipulated that Cannabis edible products can not look like sweets that will attract children. In October 2019, the Canadian government amended its legislation on edibles to include packaging. As of 1 January 2020, the US government enforces child-resistant (C-R Regulations) packaging in all Cannabis legalised states. Stay clear of edibles that have a human, animal or superhero shape. The most famous example is the THC gummy bears. In the US and Canada, they say that these sweets would entice the child consumer market. Design packaging for an adult market.
I have included a mockup sample of how packaging could look going forward. If you need any assistance or advice on your packaging needs, send us a mail, and we will gladly assist you in your next packaging project.
We always appreciate your feedback angela@thc-a.co.za. Please note that laws and regulations of country may have been adjusted during the publication.
Research papers reviewed for this article
https://publications.europa.eu/resource/cellar/c0703c01-0d38-11e7-8a35-01aa75ed71a1.0001.03/DOC_1
https://www.zionmarketresearch.com/report/cannabis-packaging-market
https://www.iso.org/news/ref2250.html
https://anab.ansi.org/lab-related-accreditation/cannabis-testing
https://www.iso.org/standard/65464.html
https://www.healtheuropa.eu/blockchain-for-cannabis/94203/
https://www.livescience.com/58173-edible-marijuana-product-labels-are-misleading.html
https://www.cannabisbusinesstimes.com/article/5-cannabis-packaging-problems-how-to-solve-them/
https://www.healtheuropa.eu/europe-setting-standards-for-cannabis-products/94612/
https://www.healtheuropa.eu/europe-setting-standards-for-cannabis-products/94612/
https://www.medicpro.london/2020/02/13/cbd-fsa-novel-food-status/
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2015.4141
http://www.efsa.europa.eu/en/efsajournal/pub/4141
https://www.medicpro.london/cbd-lab-testing-uk/
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