Michigan's Cannabis Regulatory Agency (CRA) said that in response to requests from licensees, it has developed a way for licensees to compliantly create packages containing multiple flavors, colors, and strains of infused-edibles and vape cartridges.
The CRA defines a multi-pack as a package containing two or more varieties of the same item -- either infused edibles or vape cartridges -- packaged together and sold in a single package under one Metrc package tag. It will allow licensees to package and sell multiple varieties of an item in one package without the need to attach or scan multiple labels.
But the CRA warned that before creating a multi-pack, licensees should be aware that it will co-mingle separate SKUs/products under a single package tag in Metrc, which will also co-mingle the chain of custody and test results. As a result, any concerns that may arise with one product that has been combined into a multi-pack may necessitate action, including administrative holds and recalls, being taken on all of the products that were combined to create the multi-pack.
"Licensees should carefully consider all potential risks before creating a multi-pack," the CRA wrote in a technical bulletin.
CRA guidelines dictate that a multi-pack must contain items of the same item category. A licensee cannot create a multi-pack by combining different product types; for example, an infused edible and a vape cartridge may not be combined.
In addition, each product that is combined to create a multi-pack of infused edibles must contain the same target concentration and quantity of THC. For example, a licensee cannot create a multi-pack that includes a 10mg red gummy and 20mg blue gummy. Multi-packs of infused edibles are required to adhere to the maximum THC concentrations per serving and per package, subject to the allowable variance.
