Washington Cannabis Labels Just Got a Bit Simpler

The Washington State Liquor & Cannabis Board (LCB) released updates to the rules governing Cannabis labeling in December. The new rules are effective January 1st, 2020.

A 2019 Washington State Cannabis Label; Several changes directed by LCB will take effect January 1, 2020.

Of note to Washington consumers are changes which include that Producers and Processors (Pro’s) may simply list Total THC and Total CBD. No longer will Pro’s be required to list all of the confusing quantities previously required, such as the individual quantities of THCA, THC, CBDA, CBD, and Total Cannabinoids. Pro’s will still have the right to list Total Cannabinoids, but it is not required.

Amended sections of the LBC’s release are shown in the appendix at the bottom of this article.
Click this link to view the new WSLCB rules WSR-20-01-72
https://lcb.wa.gov/sites/default/files/publications/rules/2019%20Proposed%20Rules/WSR_20-01-172.pdf

Consumers may note that Harvest Date is not included in the new requirements. Instead, lot numbers for tracking within the state’s traceability system must be shown. As this conceals the age of cannabis which may not be smelled before purchase, LCB may find itself examining the rules again very soon.

Until a solution in found, Seattle Bliss will at the very least provide harvest dates for every sample reviewed. It should also be noted that Producers and Processors should include Harvest Date on the label. Not including harvest date appears to be concealing information the consumer wants.

How do you feel about it? Would you prefer to know how old your cannabis is?
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Appendix of Requirements

The following section quotes only the new LCB labeling requirements. These are the things which must be included on the label. The complete release also includes language in regard to restrictions, which are outside the scope of this article.

Marijuana Concentrates

(e) Marijuana concentrate labels must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the marijuana producer and processor;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) The net weight in ounces and grams or volume as applicable;
(iv) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(v) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use;
(vi) If solvents were used to create concentrate or extract, a statement that discloses the type of extraction method, including in solvents or gases used to create the concentrate; and
(vii) A complete list of any other chemicals, compounds, additives, thickening agents, terpenes, or other substances used to produce or added to the concentrate or extract at any point during production. A copy of the complete list of chemicals, compounds, additives, thickening agents, terpenes, or other substances must be kept and maintained at the facility in which the marijuana concentrates are processed.

Edibles, Solid Form

(f) Labels for marijuana edibles in solid form must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the licensees that produced and processed the marijuana or marijuana products;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) The serving size and the number of servings contained within the unit. If more than one serving is in a package, the label must
prominently display the serving size, the number of servings in the package and the amount of product per serving;
(iv) Net weight in ounces and grams or volume as applicable;
(v) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(vi) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use;
(vii) A list of ingredients in descending order of predominance by weight or volume as applicable and a list of major food allergens as defined in the Food Allergen Labeling and Consumer Protection Act of 2004;
(viii) If solvents were used, a statement that discloses the type of extraction method, including any solvents, gases, or other chemicals or compounds used to produce or that were added to the extract.

Edibles, Liquid Form

(e) Labels for marijuana edibles in liquid form must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the licensees that produced and processed the marijuana or marijuana products;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) The serving size and the number of servings contained within the unit. If more than one serving is in a package, the label must prominently display the serving size, the number of servings in the package and the amount of product per serving;
(iv) Net weight in ounces and grams or volume as applicable;
(v) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(vi) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use;
(vii) A list of all ingredients in descending order of predominance by weight or volume as applicable and a list of major food allergens as defined in the Food Allergen Labeling and Protections Act of 2004;
(viii) If solvents were used, a statement that discloses the type of extraction method, including any solvents, gases, or other chemicals or compounds used to produce or added to the extract.

Useable Marijuana

(d) Labels for useable marijuana must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the licensees that produced and processed the marijuana or marijuana products;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) Net weight in ounces and grams or volume as applicable;
(iv) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(v) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use.

Marijuana Mix

(d) Labels for marijuana mix must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the licensees that produced and processed the marijuana or marijuana products;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) Net weight in ounces and grams or volume as applicable;
(iv) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(v) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use;
(vi) If solvents were used, a statement that discloses the type of extraction method, including any solvents, gases, or other chemicals or compounds used to produce or added to the extract;
(vii) Any other chemicals or compounds used to produce or were added to the concentrate or extract.

Topicals

(d) Labels for marijuana topicals must clearly and visibly provide all of the following information:
(i) The business or trade name and the nine digit Washington state unified business identifier (UBI) number of the licensees that produced and processed the marijuana or marijuana products;
(ii) The lot number of the product (the unique identifier number generated by the board's traceability system). This must be the same number that appears on the transport manifest;
(iii) The label must prominently display the net weight in ounces and grams or volume as applicable, and may not exceed serving and transaction limits as described in WAC 314-55-095;
(iv) Total THC (delta-9-tetrahydrocannabinol) meaning the concentration of THC and THCA, total CBD (cannabidiol) meaning the concentration of CBDA and CBD, using the formulas referenced in WAC 314-55-102;
(v) Medically and scientifically accurate and reliable information about the health and safety risks posed by marijuana use;
(vi) A list of all ingredients in descending order of predominance by weight or volume as applicable.

Additional Labeling

(8) Optional label information. Optional label information includes the following: Harvest date, "best by" date, and manufactured dates.
(9) Accompanying materials. Accompanying materials must be provided with a marijuana product or made available to the consumer purchasing marijuana products.
A producer or processor must provide the following product-specific information, for as long as the product is for sale, through an internet link, web address, or QR code on the product label as follows:
(a) A statement disclosing all pesticides applied to the marijuana plants and growing medium during production of the ((usable)) useable marijuana or the base marijuana used to create the concentrate or the extract added to infused products;
(b) A list disclosing all of the chemicals, compounds, additives, thickening agents, terpenes, or other substances added to any marijuana concentrate during or after production.
(10) Upon request materials. A consumer may request the name of the certified lab and quality assurance test results for any marijuana or marijuana product. A retailer must provide the information upon request.

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Click this link to view the new WSLCB rules WSR-20-01-72
https://lcb.wa.gov/sites/default/files/publications/rules/2019%20Proposed%20Rules/WSR_20-01-172.pdf

Flavored Vapor Products Banned in Washington State

The Washington State Board of Health met in early October and took action on America’s vapor crisis as it pertains to Washington consumers and banned the sale of all flavored vapor products. Governor Jay Inslee, days before, issued Executive Order 19-03; Addressing the Vaping Use Public Health Crisis in response to numerous cases of lung injury and deaths across the country, including several cases in the state of Washington.

The Order defines a characterizing flavor as a “distinguishable taste or aroma, or both, other than the taste or aroma of tobacco or marijuana or a taste or aroma derived from compounds or derivatives such as terpenes or terpenoids derived directly and solely from marijuana, as defined in RCW 69.50.101(y), or hemp plants that have been grown and tested as required by state law, imparted by a vapor product.” The key part in that first sentence is “other than the taste or aroma of … marijuana or a taste or aroma derived from compounds or derivatives such as terpenes or terpenoids derived directly and solely from marijuana.”

Consumers can be happy to know that Washington vapor products won’t contain any additives other than genuine cannabis terpenes and terpenoids. This DOES NOT mean those added terpenes have to be the exact profile of any single strain. Not at all.  Genuine cannabis terpenes are added in precise amounts to extracted oils in order to produce a desired aroma or taste - the sky really is the limit.

Evident in the terpene profile below, whole cannabis flowers are tested to evaluate a crop, but can also be used to identify a strain (shown is Laughing Buddha, as grown by Raven; 2019). Those with the most pleasant and fragrant terpene profiles sell very well, and, it is suspected, are often given branded names that further obscure strain identities.

Shown is the terpene profile of Laughing Buddha, as grown by Raven, 2019. 

On the very basic positive side, this means a talented extractor with a high-quality set of terpenes can take a mixed batch of low-grade flower containing very little oil, perhaps testing around ten percent Total THC (perhaps devoid of scent and therefore rejected from most retailers), and turn it into a golden treasure as recognizably delicious as Dutch Treat, Strawberry Cough or any number of combinations.

Before declaring a negative side, one should ask if this artificial creation from natural sources is any different than the selective breeding that created the strain and its distinctive terpene profile? Is a breeder selecting a chosen scent any more noble than a terpene scientist adding microliters of selected terpenes to a volume of oil to duplicate that scent?

The commercial realm of perfume has no stigma against the artificial or natural. The terpenes in your cannabis vapor product will be only those derived from wholesome cannabis plants.  Ambergris however, one of the world’s rarest components of perfumes, is extremely rare because it is found only in the bowels of whales.

We like things that smell pleasant, right?  If one thinks a certain way, ambergris can be considered something other than whale uh… excrement, but is it? All we seem to care about is that it is safe, and that it does what we want it to do - impart an attractive scent.

Whether natural cannabis terpenes are already present in whole flower or re-introduced post-extraction to an oil, they have been evaluated as safe by the Food and Drug Administration to enhance the flavor and aroma of cannabis products. Terpenes create the taste and aroma of cannabis - and they simply belong.

In coming reports Seattle Bliss editor, Jeff Cole will attempt to demonstrate how flavors are preserved, enhanced or re-created in cannabis oils available to Washington consumers. Be sure to subscribe at SeattleBliss.com.