# COMAR Title 14 — Independent Agencies

## Subtitle 17 — Maryland Cannabis Administration

### Chapter 18 — Finished Product Packaging

**Authority:** Alcoholic Beverages and Cannabis Article, §§36-202, 36-203, and 36-203.1, Annotated Code of Maryland

**Administrative History:** Effective date:

**Administrative History:** Regulations .01—.08 adopted as an emergency provision effective July 1, 2023 (50:14 Md. R. 559); emergency status expired June 30, 2024

**Administrative History:** Regulations .01—.07 adopted as an emergency provision effective June 7, 2024 (51:14 Md. R. 676)

**Administrative History:** Regulations .01—.07 adopted effective July 22, 2024 (51:14 Md. R. 678)

**Administrative History:** Regulation .03D amended effective April 14, 2025 (52:7 Md. R. 324)

#### Regulation .01 Definitions.

*COMAR 14.17.18.01*

A. In this chapter, the following terms have the meanings indicated.

B. Terms Defined.

  (1) “Cartoon” means a drawing showing the features of the subject in a simplified or exaggerated way.

  (2) “Child resistant” means with respect to packaging of cannabis or cannabis product ready for retail sale, designed or constructed to be significantly difficult for a typical child younger than 5 years old to open and not to be significantly difficult for a typical adult to open, and complies with 16 CFR §1700.15(B)(1).

  (3) “Exit packaging” means an opaque bag, pouch, or other container that cannabis, cannabis products and/or cannabis seeds and plants are placed after a retail sale and before the purchased items leave the licensed premise.

  (4) “Lot” means all of a cannabis finished product that is uniform, that is intended to meet specifications, and that is manufactured, packaged, or labeled together during a specified time period according to a single lot record.

  (5) “Marketing layer” means the outermost layer of a retail sale container, which is most predominantly apparent and visible. If the container consists of only a single layer, then the outer surface of the container is the marketing layer.

  (6) “Tamper evident” means with respect to a device or process, bearing a seal, a label or a marking that makes unauthorized access to or tampering with a package, product, or container easily detectable.

#### Regulation .02 General Packaging Requirements.

*COMAR 14.17.18.02*

A. All items shall be individually packaged by a licensed grower or processor prior to distribution to any licensed dispensary for retail sale.

B. Packaging Requirements.

  (1) All packaging of any cannabis product for retail sale shall be:

    (a) Tamper evident;

    (b) Child resistant; and

    (c) Plain and opaque.

  (2) Tamper evident packaging required under this section:

    (a) For soft sided packaging:

      (i) Shall be sealed at the opening in a way that indicates if the container has been opened or tampered with; and

      (ii) Once opened shall remain clear that the package has previously been opened; or

    (b) For a rigid container shall:

      (i) Contain a tamper evident seal; or

      (ii) Have an adhesive band or seal on the lid or enclosure that indicates the package has previously been opened.

  (3) Any soft sided package shall be 4 mil or greater in thickness.

  (4) Any package containing multiple servings shall be resealable.

#### Regulation .03 General Labeling Requirements.

*COMAR 14.17.18.03*

A. All cannabis and cannabis products for retail sale shall be properly labeled in accordance with this regulation.

B. Labels required under this regulation shall:

  (1) Except as specifically authorized, be printed directly on, or on a label or sticker affixed directly to, the marketing layer;

  (2) Use text no smaller than size 6 font or 1/12 an inch; and

  (3) Use text clearly written and printed in the English language.

C. Warning Statements.

  (1) All products sold for retail shall include all of the following warning statements in a manner that complies with §B of this regulation:

    (a) “The contents may only be lawfully consumed by a consumer 21 years old or older, or a registered medical cannabis patient.”

    (b) “Consumption of cannabis may impair your ability to drive a car or operate machinery. Please use extreme caution.”

    (c) “There may be health risks associated with cannabis use, especially if pregnant or breastfeeding.”

    (d) “This package contains cannabis. Keep out of reach of children and animals.”

  (2) Any product intended for topical application shall include a statement identifying that the product is not intended for human consumption, ingestion, or inhalation.

  (3) Any product for retail sale shall include the Maryland Poison Center emergency telephone number.

D. Product Information.

  (1) All products sold for retail shall include the following product information in a manner that complies with §B of this regulation:

    (a) Net weight of the cannabis, or cannabis product;

    (b) Finished product lot number;

    (c) Name of the licensee that packaged the product;

    (d) Name and phone number of the licensee that manufactured the product to report an adverse event;

    (e) An itemization, including weight, of all cannabinoid and terpene ingredients specified for the product, with concentrates of any cannabinoid of less than 1 percent printed with a leading zero before the decimal point;

    (f) If applicable, a list of all major allergens contained in and used to manufacture the cannabis finished product in accordance with the Food Allergen Labeling and Consumer Protection Act of 2004, 21 U.S.C. §343 (2010), specifically milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, and soybeans;

    (g) A list of all noncannabis ingredients;

    (h) A list of any solvents used to produce the product; and

    (i) Dates corresponding to the date that:

      (i) The product was harvested, packaged, or produced; and

      (ii) The product would be considered expired by, or best used by.

  (2) The information required under §D(1)(e)—(g) of this regulation may be printed on an inner layer of a label or made available through a link or QR code.

E. A certificate of analysis completed by an independent testing laboratory in accordance with COMAR 14.17.08 and the Technical Authority shall be made available on the package through a link or QR code.

F. Universal Symbol.

  (1) Packages shall display the universal symbol:

    (a) On the front or most predominantly displayed area of the package;

    (b) In an area no smaller than ½ inch by ½ inch;

    (c) In the form provided by the Administration and may not be modified, recreated, stylized, stretched, or otherwise distorted; and

    (d) On a background where the symbol is clearly distinguishable and identifiable.

  (2) The following symbol shall be the only symbol used on packages under this regulation:

#### Regulation .04 Medical Cannabis Product Packaging and Labeling.

*COMAR 14.17.18.04*

A. Unless otherwise stated, product regulations under Regulations .02 and .03 of this chapter apply to medical cannabis products.

B. In addition to the packaging and labeling requirements under Regulations .02 and .03 of this chapter, medical cannabis products shall:

  (1) Maintain space for a licensed dispensary to attach a personalized label for the qualifying patient; and

  (2) Notwithstanding the exemption in §D(2) of this regulation, bear a clear warning that it is illegal:

    (a) For any person to possess or consume the contents of the package other than the qualifying patient; and

    (b) To transfer the package or contents to any person other than a transfer by a caregiver to a qualifying patient.

C. High potency products that are only authorized for sale to qualifying patients under COMAR 14.17.13.03A shall maintain the requirements under §B of this regulation on the product packaging from the licensed grower or processor.

D. For products that are authorized for sale to either qualifying patients or adult use consumers, the warnings required under §B(2) of this regulation:

  (1) May be applied to a sticker or label that can be attached to the product at the point of sale, such as the personalized label under §E of this regulation; and

  (2) Do not need to be included on a product sold to an adult-use consumer.

E. All products dispensed to a qualifying patient under COMAR 14.17.12.04A shall include a personalized label for the qualifying patient, which shall include:

  (1) The name of the qualifying patient;

  (2) The name of the certifying provider;

  (3) The name of the licensee where the product was dispensed;

  (4) The date that the medical cannabis was dispensed;

  (5) The name of the product;

  (6) The strength of applicable cannabinoid and terpene compounds:

    (a) Displayed in units appropriate to the dosage form; and

    (b) Concentrations of any cannabinoid of less than 1 percent shall be printed with a leading zero before the decimal point;

  (7) The quantity of medical cannabis dispensed, displayed in units appropriate to the dosage form;

  (8) Any directions for use of the product; and

  (9) The instructions for proper storage or handling of the product.

#### Regulation .05 Edible Cannabis Product Packaging.

*COMAR 14.17.18.05*

A. Unless otherwise stated, product regulations under Regulations .02—.04 of this chapter apply to edible cannabis products and tinctures.

B. All edible cannabis product packaging shall include:

  (1) Milligrams per single serving of total THC, total CBD, and any other marketed cannabinoid;

  (2) Milligrams per package of total THC, total CBD, and any other marketed cannabinoid;

  (3) The number of servings per package and, if applicable, the recommended size of a serving;

  (4) A nutritional fact panel consistent with the U.S. Food and Drug Administration Standards;

  (5) A list of all active and inactive ingredients in descending order of predominance by weight in the cannabis product; and

  (6) A warning label that states, “Effects of this product may be delayed by 4 or more hours.”

C. The nutritional fact panel required in §B(4) of this regulation may be printed on an inner layer of a label or made available on the package through a link or QR code.

D. Any edible cannabis product containing multiple servings shall:

  (1) Be resealable;

  (2) Contain no greater than 10 milligrams of THC per serving;

  (3) Contain no greater than 100 milligrams of THC per package;

  (4) Clearly indicate the size of a serving; and

  (5) Include within the package a measuring device that is appropriate for the product form, such as a dropper for liquids or a measuring spoon for powders.

E. Multiple, individually packaged single serving products may be packaged together by a licensed processor using a marketing layer if the marketing layer:

  (1) Contains the necessary labels, warnings, and standards under this chapter; and

  (2) Does not combine products the THC content of which exceeds 100 milligrams.

#### Regulation .06 Packaging and Labeling Requirements of Cannabis Seeds and Plants.

*COMAR 14.17.18.06*

A. This regulation applies only to cannabis seeds and plants for home cultivation regulated under 14.17.13.07.

B. Products sold under this regulation are exempt from Regulations .02—.05 of this chapter.

C. Cannabis Seeds. Packaging for cannabis seeds for sale to consumers shall:

  (1) Keep cannabis seeds dry;

  (2) Prevent germination of the seeds in the packaging; and

  (3) Not impart any deleterious substances into the cannabis seeds.

D. Labeling Requirements. All cannabis seeds or plants for home cultivation shall display on the marketing layer:

  (1) The name of the licensed facility where the cannabis seeds were derived or propagated;

  (2) The name of the licensed dispensary where the product is being sold to an individual for home cultivation;

  (3) The net weight of the product, or the number of individual seeds; and

  (4) A warning label that states, “For home cultivation only. Must be 21 years old or older or a registered patient for home cultivation.”

#### Regulation .07 Prohibited Packaging and Labeling.

*COMAR 14.17.18.07*

A. Cannabis products packaging and labeling may not bear any:

  (1) Image that may appeal to minors, including:

    (a) Resemblance to the trademarked, characteristic, or product-specialized packaging of any commercially available candy, snack, baked good or beverage;

    (b) Images of food, candy, baked goods, cereal, fruit, beverages, or the words “candy” or “candies”;

    (c) Images, graphics, features, or likeness to images, graphics, or features that are popularly used to advertise to children, such as cartoons, animals, neon colors, celebrities, mascots, or phrases;

  (2) Statement, artwork, or design that could reasonably mislead any person to believe that the package contains anything other than a cannabis finished product;

  (3) Seal, flag, crest, coat of arms, or other insignia that could reasonably mislead any person to believe that the product has been endorsed, manufactured, or used by any State, county or municipality or any agency thereof;

  (4) Depiction of any form of consumption of cannabis or cannabis products;

  (5) Depiction of overconsumption or intoxicating effects of cannabis or cannabis products;

  (6) Claims regarding health or physical benefits to the consumer; or

  (7) False or misleading statements;

B. Labels, marketing layers or any other aspect of the product package are prohibited from obscuring any warnings, statements, or information required under this chapter.

C. Products are prohibited from targeting or being designed to appeal to any individuals younger than 21 years old.