Cannabis “Party Packs”

The LCB has continued to receive concerns from industry members related to cannabis “party packs” or “mixed packs” that violate product labeling and/or traceability requirements. The cannabis mixed packs in question contain unique, individual items without individual traceability numbers that correspond to each unique item. Some of these mixed packs also lack individual quality control (QC) testing information. The issues with non-compliant party packs are often twofold:

1. Individual and unique items have been amalgamated under a single traceability number that is not representative of all of the unique items in the pack.

2. Individual and unique items have QC labeling, including potency, that is not representative of all of the unique items in the pack. Sometimes the potency information is averaged for the individual, unique items.

It is our desire to increase labeling and traceability compliance through quality education and continued communication with the industry in which the following information on mixed pack requirements is offered:

First of all, it is important to make a distinction between the definition of “cannabis mix” and the colloquial or industry term “cannabis mixed packs.” Cannabis mix is created from taking unique items and homogenizing them into one new item. Conversely, cannabis mixed packs are heterogeneous, consisting of items that remain distinct and separate. WAC 314–55–010 defines the three types of cannabis mix as:

• “Cannabis mix” means an intermediate lot that contains multiple strains of useable cannabis and is chopped or ground so no particles are greater than 3 mm.
• “Cannabis mix infused” or “mix infused” means an end product that contains cannabis mix and may contain other intermediate products or useable cannabis.
• “Cannabis mix packaged” or “mix packaged” means an end product containing only cannabis mix and no other product types.

Cannabis mixed packs or party packs do not meet these definitions of cannabis mix as they contain unique, individual items.

Party packs are allowed, however, the labeling must provide the detail related to the individual items. This means that each individual and unique item must have an individual traceability number. For example, if a mixed pack contains four individual and unique items, the packaging must have four individual traceability UPC labels — one for each unique item. The product must also be labeled with individual QC testing information, including potency. Aggregate or average test result label information is not compliant.

Examples of non-compliant mixed/party packs:

Example #1

• Good example of the individual detail needed to represent the four unique items in the pack (i.e., QC results and item description).
• However, all four unique items are listed under a single traceability number that is not representative of all of the items.
• The packaging should have four traceability UPC labels.

Example #2

• Package has five unique items in the package, but does not provide the individual detail required for each of the five items (i.e., individual QC results and individual traceability UPC codes).
• The QR codes on the packaging are not functional.

We thank you for your cooperation and compliance with cannabis mixed/party packs. If you have any questions or concerns regarding mixed/party packs, please contact your compliance consultant.