Labeling cannabis products

Imagine you were in charge of regulating a legal cannabis market. What goes on the package label?

Imagine – just hypothetically – that a state decided to open a legal (at the state level) commercial market in cannabis, with some of the users intending to use the substance to treat some medical condition and others using it for other purposes.

Such a market would have an advantage over purely illicit markets that the state could require that the product be tested and labeled with its content of active agents. Those labels might (or might not) help consumers what experience to expect from roughly how much of the product, avoiding unintentional overdose. They might also “nudge” users toward less hazardous patterns of use.

We’re pretty sure that THC is the primary “stoning” agent and that CBD (cannabidiol) has some buffering properties against, e.g., panic attacks. It seems likely that lots of the terpenoids that help give the product its flavor and odor also have their own psychoactivity, but the detailed science mostly hasn’t been done. It may also be the case that user-to-user variation in reactions will be higher for cannabis than it is for alcohol.

With respect to edible products, the label might try to inform consumers about how the content of (e.g.) a brownie compares to the content of some more familiar dosage form, such as a joint.

Finally, the label might contain warnings of various kinds: e.g., not to drive under the influence.

Since there’s more relevant information than can be legibly placed on a package label, there could also be required package inserts (as for pharmaceuticals) and/or a state-maintained website with information about cannabis and about how to interpret the information on the label.

There must be some optimal labeling system, but I’m damned if I can figure out what it is.

So let’s try a little bit of crowdsourcing. Please restrict your comments to the real of the technical and pragmatic; attempts to refight the drug wars in this space will be zapped. Place yourself in the regulator’s shoes and ask what you could do with currently available information that would be better than doing nothing.

Author: Mark Kleiman

Professor of Public Policy at the NYU Marron Institute for Urban Management and editor of the Journal of Drug Policy Analysis. Teaches about the methods of policy analysis about drug abuse control and crime control policy, working out the implications of two principles: that swift and certain sanctions don't have to be severe to be effective, and that well-designed threats usually don't have to be carried out. Books: Drugs and Drug Policy: What Everyone Needs to Know (with Jonathan Caulkins and Angela Hawken) When Brute Force Fails: How to Have Less Crime and Less Punishment (Princeton, 2009; named one of the "books of the year" by The Economist Against Excess: Drug Policy for Results (Basic, 1993) Marijuana: Costs of Abuse, Costs of Control (Greenwood, 1989) UCLA Homepage Curriculum Vitae Contact: Markarkleiman-at-gmail.com

53 thoughts on “Labeling cannabis products”

  1. Why not have some wiki that contains all the information needed on a warning and information label and link to it with a web address and a QR code that computers and phones can read. Then just put “What they don’t want you to know” on the label pointing to the links and codes. Maybe clicks could be made worth something to the folks that look and the product sellers too.

    1. Seconded. Pharmaceutical package inserts are now so full of CYA detail as to be unreadable. The target group are young and almost certain to have smartphones.

  2. Treat it like any other drug. I mean, carefully refined, measured and prescribed pharmaceuticals have varying affects on different people; the endorphin rush of eating spicy food is hugely enjoyable (and I would say, addictive) to some, others can’t stand it. And believe me, peppers vary widely, despite the existence of the Scoville unit – I’ve bought Jalapeño peppers as bland as bell peppers, and also several times as hot as expected.

    Branding is probably more important than labeling, because it aligns incentives. Pot is substantially less harmful than a lot of less regulated things, so the cost of smoking/eating too much is substantially lower than with, say, alcohol. So long as brands are relatively consistent in potency, flavor, and balance of active ingredients, both medical and recreational users can relatively easily explore to find what works best for them.

    Since there isn’t one single active ingredient, labeling is hard, but I think a rough estimate of percentage of THC could help guide. But more important, I think, would be giving producers incentives to make a given brand consistent.

    1. If the peppers have been evaluated for Scoville units, the numbers are reliable. What you can’t do is use an old table of Scoville ranges and say, “Oh, jalapenos run 10K-20K Scovilles. This is a jalapeno, it must be somewhere in that range.” You can’t do that because:

      1. Breeders are constantly working on modifying the heat profile of their peppers. Paul Bosland at NMSU was awarded an igNoble Prize for developing heatless jalapenos for the food processing industry.
      2. Peppers are almost as promiscuous as … I’m not sure what. If you are growing hot and mild peppers near each other, they will almost certainly cross.
      3. Environmental conditions matter, too.

      I expect that something similar exists with the cannibinoid profile for marijuana varieties.

      Bottom line: for peppers, if you want to know how hot they are, you have to test (taste) them. For marijuana, I expect the cannibinoid profiles have to be measured.

      1. I think you are missing the point. I was trying to say that the harm rate with peppers (remember that people die from being sprayed with fluids derived from peppers) is lower than the harm rate from smoking or eating pot. (I’m unaware of the drug being used forcibly on anyone, but would love to be educated if you have any information.)

        It is less harmful than other things. Perhaps we would like to make those more harmful things harder to get; I don’t know, and that opens up a much wider discussion. But simply on the baseline we have, sure, some boilerplate legalese and maybe a scary graphic make sense, along with age restrictions.

        In the alternative, explaining why something safer than alcohol should be under stricter rules would help.

        1. People die from pepper spray every year. Last I checked, no one has ever OD-ed on marijuana.

          While this is an argument for stronger labeling on peppers and pepper spray, the harm rate from cannabis is substantially less than from peppers/pepper spray.

          1. Jamie,
            Fundamentally, we’re not. I really like your formulation here in particular:
            “So long as brands are relatively consistent in potency, flavor, and balance of active ingredients, both medical and recreational users can relatively easily explore to find what works best for them. ”

            This one seemed to be formulated in the opposite terms:
            “I was trying to say that the harm rate with peppers (remember that people die from being sprayed with fluids derived from peppers) is lower than the harm rate from smoking or eating pot.”
            Wouldn’t the harm rate for pot be LOWER than for peppers (as even your elliptical statement indicates)?

  3. I’d argue that a little labeling can go a long way, at least if it’s required. It’s not the labels that cost money so much as all the testing and bookkeeping needed to generate the required info. Thus a high intensity/high cost labeling regime will tend to favor large, industrial scale production, while a low bar/low cost labeling regime would help encourage craft production. My personal preference is to encourage small-scale, cooperative, personal production as a better long-term model than the boozy/industrial mass production model in regards to recreational cannabis, so keeping any required costs/bars to entry low is important to me.

    Frankly, since we’re gonna end up with some of that regulation stuff regardless, because we’re talking government and regulation, the best case is that herb oughta be labelled like wine. A couple of basic facts, alcohol percentage and place of production, are all that are legally required (maybe something about sulfites?)

    Really, that’s all that’s needed, THC percentage and place of origin, for smokable product.

    For ingested goods, than it should indicate grams per serving and serving size, plus THC percentage and place of origin.

    Marijuana users are pretty familiar as a group with the natural variances in it. In fact, for the average user, the greatest benefit of legalization will be easy access to a variety of marijuana, rather than only whatever’s left from the last pound your dealer purchased.

    Trying to require a number of specific attributes by listed will be an expensive regulatory and accounting nightmare. I’m still a little leery of even how to come up with a specific percentage of THC from a particular crop of even a single strain, given the wide variability in that based simply on position of the bud on the plant. Any legal requirement to do so would need to account for that wide variability.

    Of course, this could give rise to a tasting, testing, and labeling sub-industry, where herb connoisseurs are paid high fees to assess and document each batch for an official label….NOT! unless I get hired for that job. But really, the label should be subject to a few basic requirements and assume that the end-user is an adult.

  4. Why not let price do most of the work, in that you require the seller to give the unit dose price expressed as grams THC(primary active ingredient), where the “unit” is different based on whether the intende use is consumption in food, or in smoked form or in vaporized form (presumably each use requires a different blend or “grind”)

    You let sellers mix and match and grind/ shred for optimal use, and require the unit cost label and the number of doses (assuming intended pathway) to allow price comparisons of brands and pathways. Let the state’s unfair and deceptive practices law do the rest. Whoever said above that we should model these labels on wine and not saudades has it exactly right.

  5. re edibles : some warning that time of onset and duration are highly variable every time. Every edible must be used with plenty of time allocated. The users digestive condition can be an 8 hour variable at each use.

  6. I agree with Mike. Less is more. Labeling is a but outdated in the era of online crowd sourced reviews. I think it’s safe to compare marijuana to beer rather the liquor. Even the strongest beer (excluding those crazy expensive 40% alcohol “beers”) isn’t going to knock you out with less than a few of them, and all beer drinkers seem to manage with just alcohol percentage by volume. I think THC percentage is enough.

    I’ve only heard of CBD through you, and it’s never been discussed between any of my smoking friends. No sense in adding it if no one knows what it means. I’d leave that to more discussion at the retail outlets. I.e. growers should record CBD percentage and note it, even provide info to retailers, but no need to legally require it on the label if the consumer is unaware of it’s meaning. You can always add it down the road when you have more confidence in its usefulness.

    Up to this point, my comments were specifically for smoking or vaporizer usage. Oral products should have thc percentage, but there should also be a warning. Any type of brownie or other item taken orally must have a warning label I’d say. Warning people about delayed onset and continued increasing of intensity, or a simple “warning: the effects of taking cannabis orally vary significantly from smoking cannabis. If you have never taken cannabis orally before, do not take more than the recommended dose.” I know way too many people who have had a very bad day from eating one extra brownie. No one needs that.

    1. You’ve assuredly discussed ‘indica’ versus ‘sativa’ strains with your friends; these are essentially a stand-in for CBD-to-THC ratios. Indica strands, besides tending towards shorter and bushier (easier to grow in-doors), tend to produce more CBD than Sativas.

      Other culturally situated keywords for high-CBD marijuana are ‘couchlock,’ ‘stoniness,’ ‘body high,’ etc… These describe the psychotropic effects of CBD more than they do of THC.

      Beer still only has one known active ingredient: EtOH. This is very different from a species of plants that produces a variety of psychoactive chemicals, and have been cultivated for various blends of qualities.

      1. Is EtOH shorthand for ethanol? I should point out that beer has many more active ingredients than that. Hops happens to be a relative of hemp, and I suspect a detailed assay of some strong craft beers might reveal a far more interesting list of active ingredients.

  7. A reasonable “serving size” might be in the ballpark of 20mg THC. This would equate to roughly half of a 3/4 gram joint of commercial grade marijuana at ~5% THC content, or a little over .1 grams of sinsemilla at ~17% THC (assuming my math and potency estimates are correct). Among the frequent, relatively responsible users in my circle (i.e. folks who typically enjoy an evening smoke, once per day, but never more than that), this seems to be on the low end of what it takes to get comfortably stoned. Whatever dose you settle on, however, I’d probably shy away from making much of an analogy between a marijuana serving and a drink of alcohol. Sidestepping all the other differences between the two drugs, it probably takes more than one drink for the average drinker to start to feel intoxicated, while I’d imagine most recreational marijuana users will be seeking more than a barely-perceptible buzz.

    The label might implore inexperienced users to go slow at first–especially with edibles–where the inherent lag time between ingestion and intoxication could tempt a newbie to go way overboard with their dose.

    And aside from boilerplate warnings about driving, operating heavy machinery and so on, the label ought also to urge users to choose the proper setting to consume the stuff, e.g., “Use of this product may result in anxiety, panic attacks and impairment of judgment and/or memory. Please consume it responsibly in safe and familiar environment. Avoid alcohol and other drugs. Do not consume this product while caring for small children, the elderly or infirm.” Etc.

  8. Putting together Robert’s and Mike’s ideas, here’s a photo of Chinese wine labels. It looks as if it’s a regulatory standard.
    chinese-labels

  9. You are not labelling a product for therapeutic use.

    Manufacturers should be prohibited from labelling their product with THC/CBD information for the same reason tobacco companies are forbidden from publishing nicotine content on cigarettes in Australia – they mislead addicted consumers into thinking it is safer to just inhale smoke with less nicotine instead of quit. Smokers also self titrate their dose of nicotine when they smoke so it makes product strength information irrelevant.

    You need plain packaging with prominent health warnings (that reflect actual risks) designed to deter use. Forget everything else.

    e.g.

    http://goo.gl/XJfUL

    http://goo.gl/FPmlN

    1. Among the risks documented should be what government agencies (CPS, VA), employers, etc. can do to you for using. Those are at least as real risks as the health-related ones, and they will help deter use. I assume the WA initiative still lets employer’s fire for testing positive?

      Can WA regulators not dictate the legal form it’s sold in? Make it only available as green, cigar-sized e-cigs with THC/CBD ratio prominently labeled. The size/color will discourage use where it’s likely to be inappropriate. If users must smoke they can crack the thing open and deal with the hassle, most users won’t.

      1. While this is a possible regulatory solution, it doesn’t resolve the problem that was posed by the voters. They want marijuana to be legal, not over-the-counter access to synthetic/distilled THC.

        1. Packadaysmackok,
          Excellent point and one that should be at the forefront of any viable regulatory scheme. People did NOT vote for a continuation of a “drug war lite.” They did not vote for medical marijuana, with medical qualification for access. They did not vote for cannabis with the intent of making this majority into second class citizens by virtue of their preferred intoxicant.

          Any regulatory scheme needs to carefully observe that it exists to serve the majority that put it into place. There are some public safety concerns and obviously people should take part in a system that encourages honesty in terms of their business dealings and tax payments.

          Besides that, it is a plant that is relatively easy to grow.

          Americans are not going to tolerate being treated like they’re in junior high by government over legal marijuana. That barrier was passed last November. Regulation must be common sense, easy to follow, and widely accepted as beneficial. Try twisting the cuffs back on with onerous and silly requirements and it’s just not going to work. The backlash will be harsh against those in government that think they’re gonna some how win back with bureaucracy what they can no longer do with law enforcement. I think present company is very much excluded, but there are signs that some would prefer to snatch their defeat back this way, anticipating the fact that they will inevitably lose.

    2. We should also be cautious about making false equivalencies between tobacco and cannabis. Cigarettes/nicotine/tobacco is one of the most physically addictive substances known, in sharp contrast with cannabis and its mostly subtle effects at discontinuance. Self-titration is a well-known effect of cannabis, while the urges to keep lighting up associated with tobacco use are infamous cravings. Putting numbers on the packages are useful for cannabis users, while the same for tobacco products is recognized as problematic as strayan states.

      The most important difference is that cannabis is intoxicating, while tobacco is not. The guidelines on alcohol percentage display help suggest limits to intoxication to the user, just as they would on cannabis packages. This is an important factor that also differentiates the implications of percentages on marijuana packaging as being substantially different from the prohibitions on their listing on tobacco packaging.

  10. When considering craft beer I haven’t tried before, I check the ABV and IBU on the label, and whatever else they’ve put on there about ingredients and complimentary foods to enjoy with it, and of course the brand is often an important consideration. For marijuana, THC and CBD labeling would offer information important to the consumer, as would information about flavor and other particulars about the cannabis plant it comes from. And I agree with Jamie that branding is also an important and useful consumer cue. As to the government warnings, you could pretty much duplicate the standard warning about driving and operating machinery.

    No need to over-think it. If it’s good enough for beer, which is potentially more hazardous to the consumer and society at large in every way, it’s certainly good enough for mj.

  11. I agree with the notion that less is better. Too much info and people will ignore it. There should be a standard “serving size” of THC, say 25mg. Then each product should give (a) how many servings of THC there are, and (b) the ratio of THC to CBD. That’s it. No comparison to alcohol is necessary or desirable. There is no risk of overdose. Also, everyone will know it is illegal to drive stoned, just as everyone today knows its illegal to drive drunk. No warning labels are necessary.

  12. Varietal information would be a very good supplement to/standin for precise ingredient labelling. CBD may be hard to translate to user terms, but “sour diesel is great for an afternoon playing in park”, “blackberry kush gives you couchlock”, “haze can make you paranoid if you overtoke” are comprehensible.

    1. I expect much of that would be revealed in the marketing campaigns rather than on the labelling. Since even individual strains can have a lot a variation depending on how they are grown, different brands will develop different reputations as having the dankest or schwagiest buds, and the effects of each strain will filter into the collective consciousness, like the knowledge of which wine to go with your meal.

  13. My inclination would be the folowing:

    First, one very desirable property of a legal, regulated marijuana market would be “dominated by small-scale producers. This preference sharply limits the required labeling.

    Second, it would be desirable for users to have a good idea of the effects of what they buy. This preference would indicate “more is better.”

    The required label would be simply a warning, and “grams of marijuana” or equivalent, with a state-specified conversion for things like hash to “equivalent grams.” Producers over a certain size would be required to label with THC and CBD per gram. (This is comparable to the food labeling regime.)

    My preference would be a state-maintained website with basic information for the top few known-or-thought-to-be-active ingredients, as well as any differences by form of product (smoked vs ingested).

    I’d also strongly prefer a clear delineation between required information and other information, just as in food labeling. The required nutrition information is easy to distinguish for the promotional copy.

  14. Can’t you do a test by putting subjects on a driving simulator? How much induces how much impairment of attention/motor control? How are responses correlated with the subject’s weight? And then compare those results to known results on alcohol.

    You have several times hoped that the Federal government might be inclined to cooperate with Washington State; if so, they might even allow these tests to be made legally. The information would certainly be widely useful.

  15. I suggest this, easy to comprehend, graphic representation of potency: between one and five tiny illustrations of Häagen-Dazs cartons.

    1. Or just do it with the heavy metal umlauts:
      Häagen-Dazs
      Häägen-Dazs
      Häägën-Dazs
      Häägën-Däzs
      Some heavy metal bands spray random umlauts over the consonants too, but that’s beyond WordPress’ ASCII limitations.

  16. THC content: high, medium or low (relative to some defined dose of THC)
    Cannabidiol content: high, medium or low
    For more info see QR code.

    Simple and easy, but has more info available for those who want it.

    1. There is enough natural variation that more precision than high, medium or low is single sample effect.

      I’d modify my previous to have brand/strain to be the required part and let the market reward those that can deliver a consistent product. No couchlock should clearly be on the equivalent part of the label as goes well with chicken.

  17. I don’t know a damn thing about this problem. But I do know who does. The CFBP–Elizabeth Warren’s brainchild–has done a lot of empirical work with disclosures. Somebody there will probably be very useful.

  18. Who is the label aimed at? First time users, occasional users or heavy users? You might want to emphasize different information for each group. Heavy users are more likely to buy larger quantities – you might actually change the labels for different sized packages.

  19. Tony C is onto something– a simple reiterated-symbol scale to indicate potency, combined with terse disclosures/warnings/cautions/YVMV concerning driving, power tools, emphysema & other smoke-related ills.

    This should suffice until Altria or Brown & Williamson enter the “recreceuticals” field with weed laced with the sauces long used in commercial tobacco manufacture, perhaps sweetened to create a threshold product.

  20. Minimal info on the actual packaging but point to expanded info online.

    On Package:
    Raw Product
    THC %
    CBD %
    THC/CBD Ratio

    Same stats for processed/concentrated to oil or budder then show method water/solvent, chemicals, residue
    Food: Show cannabis-form origin of food products (raw or processed) and related stats.

    Consumers will quickly educate themselves on the role of CDB.
    As for dose – it is so dependent on use and related tolerance levels, so ratings should be made for (and IDed as) first-time/occasional users
    Harm reduction ie vaping should be promoted and it eliminates 2cnd hand smoke.
    Good Luck.

  21. Here’s what’s crucial:

    For dried inflorescences and extractions
    Acidic cannabinoids
    Neutral cannabinoids
    big six terpenoids (most others only found as trace)
    All in milligrams per gram/milliliter
    List anything over .5% by dry weight

    Extractions must be defatted/dewaxed or refrigerated.

    All products must have expiration dates.

    Must be tested for aerobic & anaerobic bacteria & molds/yeasts. Acceptable levels extrapolated from EU Pharmacopeia herbal medicine rules, and informed by their inhalation guidelines. No aspergillus allowed or 10 spores per gram.
    Pesticides in lieu of EPA thresholds must meet minimum levels of residue for food crops in the state.

    Infused products must be in childproof packaging and not exceed 45 milligrams of THC equivalent. No limit on infusions of non-psychoactive cannabinoids, such as CBD.

  22. RBC readers know a staggering amount about this! It’s like wandering into a bar of hardcore sports fans on local derby day.

  23. @Mark/8:34

    I thought both THC and CBD are in base form in the raw plant. Heating (and extracting by solvent) convert it to the psycho-active acidic state.

    Sure, list the terpenoids if it is not too costly for the producers. Someday we might even find out what they do. 😉

    Also – I’d be OK with “Packed on” dates rather than best before.

  24. @Ron

    Nope, living cannabis only produces cannabinoid acids; though time and room temperatures will very slowly break them down into neutral cannabinoids post harvest…

    Terpenes aren’t crucial, but do help the consumer learn what kind of effect can be expected, certainly more than some silly and inconsistent name, in lieu of standardized varietals. Terpene/cannabinoid interaction is emerging science, but patterns are pretty clear.

    Expiration dates should be the goal for perishable products and these are perishable products.

    1. If stored in a cool, dark place in an airtight container, herb can keep for years & years. Left in a hot car in an open jar, it will be crap in a few days. I think directions on optimal storage would be better than an expiration date.

      1. @Artor

        Actually, only the cannabinoids can keep for years and years, provided they are not exposed to light, oxygen or heat, but the lighter terpenes are lost much, much more quickly. These terpenes are pharmacologically active and partially responsible for the distinctive effects among different cannabis varieties and their aroma.

        1. I agree that Date Packaged is most useful here. Just for simple stockkeeping and inventory use, this should be on the label.

          There should also be some requirement that this date be within 30 days of harvest. That would allow for harvesting, trimming, and a “soft” drying routine for optimal preservation. Or it could just be Harvest Date, instead.

          While Expiration Date could be useful, quality really depends on how it is stored. This is out of the hands of producers and distributors once it’s in the hands of consumers. A firm Expiration Date might convey the mistaken message that it applies regardless of storage conditions. An * citation leading to an online discussion of this topic would be useful in advising consumers on how to best store their cannabis…

          In reality, most cannabis is and will likely be consumed close enough to time of purchase that Expiration Date is really not very useful in comparison to a Date Packaged or Harvest Date.

          1. That depends on the resin content. For flowers with exceptionally high resin content or extractions, the highly polyunsaturated fats produced by the plant oxidize quickly. Rancidity among samples of high-resin content samples from California and Colorado is high.

            The “dude, this long cure sh*t tastes bueno to me” doesn’t pass muster in a post-prohibition world. If you contend that cannabis doesn’t spoil… prove it with science. Opinions are valuable, but this requires facts.

  25. the testing place “budgenius.com” has an informative graphic for THC, CBN, etc and effects.

  26. @Ron

    @ Ron

    The statements in the article you cite, about the uses of cannabinoid acids and their bioavailability from juicing a few cannabis leaves, were discredited in a more recent article by Martin Lee working with a respected cannabis testing lab in Southern California.

    There was a study published in April 2012 with a very small cohort (8 participants) that supposedly indicated that unheated acidic CBD had higher bioavailability than the heated decarboxylated neutral form. That contention appears to be incorrect according to experts in cannabinoid pharmacokinetics.

  27. Having re-read Mark Kleiman’s original post… let me revise my comment.

    The issue seems to be ascertaining what information is of evidence-based value to the medical user and the normal consumer. There are other considerations, such as information for doctors, substance abuse professionals, law enforcement, and poison control.

    While there is talk in Colorado of developing a system that is akin to proofing alcohol, that is challenging because of the inherent multi-drug active constituency of cannabis and the variation among the populace based on their genetic variation and their individual level of receptor down regulation. This variation is very apparent when attempting to determine what actually constitutes impaired driving while using cannabis.

    Dose guidance based on cannabis constituency is very difficult and becomes harder, the more potent the cannabis product.

    Interaction between cannabinoids and interaction between cannabinoids and terpenoids is unpredictable enough to likely prevent looking at a label that listed all the potential active ingredients and determining the individual outcome. In other words, it’s tough today to look at an analytical test result and predict what’s going to happen.

    The one thing that has happened to some degree in California concerning analytical testing is that a subset of users just choose the most potent product as being the best product. I feel that’s akin to believing that Everclear is the best alcoholic beverage because it is the most potent. It is interesting to speak with people that used cannabis back in the 70s and today. I’ve heard on several occasions that they preferred Colombian Gold from those days to today’s Alien Dawg Kush. The average THC potency of Colombian Gold was 4%. Average Alien Dawg is 25% THC.

    I think a label that helps the consumer gauge the type of effect to expect might be more useful than just test results. For poison control and medical use, the test numbers could be helpful, but even for poison control those numbers won’t drastically influence the treatment options.

    1. I would argue that medical labeling is a distinct issue. As others have noted, too much information that is REQUIRED can be problematic for a number of reasons. On the other hand, medical use seems to call up a whole range of issues that go beyond what the recreational user desires. And there is no free lunch with labeling, which overdone can add a costly layer of complexity that would be discouraging to many small producers.

      Your point on dose guidance is a pertinent one. It’s hard to do, even if cost is no object.

      Which is not to say that some producers may want to emphasize certain features of their product. This leads to the question where some things need to be kept off labels. Hard to argue that THC% should not be on the label, with your example of some consumers just buying the highest number interesting. Fortunately, society will not be impacted as much by that as it would it they were drinkers and went for the everclear, every time. Again, required labeling should stick to representing social and practical consumer needs. What’s beyond that is largely marketing any way, so best leave that choice of what to represent — except for factors that need to be kept off — up to the producer.

      1. I agree that medical labeling is a distinct issue. I think that Mark Kleiman’s idea about inserts might address where such information for medicinal uses could go, instead of being placed on the label. But the label really needs to encourage informed dose. And by dose I mean dose for recreational consumption. There is some concern about how to handle THC/CBD products. My experience is that people overdose on these cannabinoid combinations, thinking that the CBD is going to stem the adverse effects of too much THC. The problem is when a person consumes some CBD with THC, then switches to a solely THC product. Bad times can, and often do, ensue…

        As far as impact of potency on consumers, I think it might be premature to say that the impact of tacitly encouraging the consumption of higher THC cannabis would be less than the impact of drinkers choosing Everclear. No one knows the long term effects of consuming high-THC cannabis or extractions. There is some evidence that cannabinoid receptor down regulation is taking place and that this down regulation is reversible. But when you’ve got phytocannabinoids that mimic substances that help regulate the systems in the body responsible for basic functions such as to “relax, eat, sleep, forget, and protect”, to quote a noted paper on endocannabinoid function, some caution might advised to encourage rational patterns of use.

        The problem with my own Everclear analogy, is that Everclear is not palatable, therefore dilution is mandatory for consumption. Most well cultivated or well-extracted cannabis products are typically pretty palatable, especially when the cannabis extractions are infused into food . And many of the most potent cannabis extractions are impossible to distinguish from much milder products. A cookie containing 500 milligrams of THC in the form of de-waxed cannabis oil is indistinguishable from a cookie containing no cannabis at all. That’s risky, since there is no cue delivered as to what is being delivered. In California, it is not uncommon to see cannabis cookies in dispensaries containing 1000 milligrams of decarboxylated THC. The threshold for psychoactivity is considered around 5 milligrams. 10 milligrams can produce a panic attack in a cannabis naive individual. Cannabis won’t kill you, but if it gives you a panic attack you just might think otherwise. This is why labeling is important: to help a person gauge the effects of consumption.

  28. Since there is so much difference between people’s reaction to various amounts of THC and other compounds plus the differences in how the Cannabis is ingested I think running a serving size measure plus time to effect, which may need to be tested for differing levels of canaboids in a product. So we can imagine a strain that had 5% THC and 5% CBD and/or other effective compounds, that through testing has found what the variability of onset of effect is. Then each strain is tested to allow for an insert that says what the serving size is and how much time between dose and effect there is for different types of ingesting.

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