August 31, 2023 A Hot Market: Arizona’s Packaging Regulations
In November of 2020, 60 percent of voters in Arizona approved the legalization of cannabis for people 21 and older–only ten years after medical marijuana barely squeaked by on the ballot at 50.1 percent. As the 13th state in line to pass legislation permitting cannabis use three years ago, Arizona wasted no time getting recreational retail of cannabis to market. State-licensed dispensaries and producers were able to begin official operations as early as January 2021–earning Arizona the bragging rights of being the fastest state in U.S. history to begin legal sales after a voter referendum!
Cannabis is big business in the Grand Canyon State, too. In 2022–only Arizona’s second year of recreational sales–the state’s cannabis sales exceeded $1 billion in revenue. And taxation on the plant is filling up the state’s pockets, with 2022 totalling over $270 million in taxes collected. The success of this burgeoning market comes with its own unique set of standards, as in other states, for the possession, cultivation, taxation, and sale of cannabis. Today, we’re taking a closer look at Arizona’s laws around packing and labeling requirements–crucial understanding to anyone trying to make their way in the cannabis boom in the southwest.
Firstly, state law dictates that all cannabis leaves dispensary doors in an opaque, child/tamper-resistant exit package. In reference to labeling and design, the state has more specific regulations.
All recreational cannabis in Arizona must contain the following information on packaging labels:
The marijuana establishment license number.
Any cultivator information, as applicable.
The batch number for the product.
Strain type.
Weight and amount, as applicable.
What “form” the cannabis product is (flower, concentrate, etc.)
Lab-tested information about the potency of the cannabis, including milligrams of THC or CBD contained therein.
Ingredients (for non-flower products), listed in order of abundance.
The date of harvest, manufacture, or sale.
Along with the above details, the label must contain the following warning:
"ARIZONA DEPARTMENT OF HEALTH SERVICES' WARNING: Marijuana use can be addictive and can impair an individual's ability to drive a motor vehicle or operate heavy machinery. Marijuana smoke contains carcinogens and can lead to an increased risk for cancer, tachycardia, hypertension, heart attack, and lung infection. KEEP OUT OF REACH OF CHILDREN"
Finally, Arizona also prescribes some design-related regulations to the packaging of cannabis in the state. Compliant packaging and labeling cannot
be false or misleading.
be manufactured or sold in the form that resembles a human, animal, insect, fruit, cartoon or toy.
be advertised to children in any way–including use of any resemblance to food or beverage brands that are marketed to kids.
In summary, Arizona has a comparable framework for packaging of cannabis as in other legalized states: license information, product details, and packaging and labeling that warns consumers and avoids consumption by children/minors.
As the southwestern state’s cannabis market is still relatively new, it is likely that these statutes will be amended or reformed in the coming years, making it important for purveyors to stay up to date with ongoing legislative changes. For now, you can read the direct language from the Arizona Administrative Code and stay tuned to our blog for other breakdowns on all things packaging in U.S. cannabis.
*This blog is not intended to be prescriptive legal advice for what you should or should not include on your packaging. Like many things in our industry, packaging requirements change frequently. Please contact your legal team to confirm your packaging label requirements.