The Illinois Cannabis Regulation Oversight Officer (CROO) released a notice for cannabis business licensees concerning packaging and labeling products. Though the rules for packing and labeling have not changed, cultivation center, craft grower, infuser, and dispensary licensees must continue to comply with label requirements during the transition from BioTrack to Metrc.

According to the notice:

1) During transition, entire packages will need a new Metrc Tag number, but individual units will not need new labels. Pre-labeled products with BioTrack ID numbers do not need to be relabeled.

2) Dispensary names do not need to be added before shipping to dispensaries. However, dispensary names are required on the units before selling, and can be added by manufacturers.

The notice for packaging and labeling addresses information for the Illinois Department of Agriculture licensees (cultivation center, craft grower, infuser) and Illinois Department of Financial and Professional Regulation licensees (dispensaries). In addition, the notice lists resources for Metrc, saying that “the State has reviewed and provided feedback to Metrc for Retail ID but has not vetted all possible labels produced by Metrc. The responsibility is on the licensee to ensure compliance.”

Lastly, the notice lists State resources for the law and labeling requirement for licensees.

410 ILCS 705/55-21 [Cannabis Regulation and Tax Act Labeling Section] 8 Ill. Admin. Code 1300.10 [Adult Use Production Definitions]

8 Ill. Admin. Code 1300.930 [Adult Use Labeling Rules]

8 Ill. Admin. Code 1000.420 [Medical Labeling Rules]

410 ILCS 705/15-70(b) [“A dispensing organization must include the legal name of the dispensary on the packaging of any cannabis product it sells.”] For example, XYZ Cannabis Company, LLC d/b/a ABC Dispensary would need to have ABC Dispensary displayed on the product prior to sale.

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