October 1, 2016 Compliance Deadline Approaching for Transferring, Labeling, Concentration Limits, Packaging and Testing

The Oregon Medical Marijuana Program (OMMP) is approaching a compliance deadline of October 1, 2016, for transferring, labeling, setting concentration limits, packaging and testing of marijuana and marijuana products.

The next 60 days serves as a transition period to allow registrants to move into compliance with new rules. All rules related to medical marijuana may be found on the OMMP’s rule page at: www.healthoregon.org/ommprules

Transferring Cannabinoid Products, Concentrates and Extracts

Beginning October 1, 2016, dispensaries may only accept transfers of cannabinoid products, concentrates and extracts from a registered processing site. OAR 333-008-1230(2). On or after October 1, 2016, dispensaries may continue to sell already stocked cannabinoid products, concentrates and extracts that were transferred from unregistered processors to the dispensary prior to October 1, 2016, but the products, concentrates and extracts must meet labeling, concentration limits, packaging and testing rules found in division 7 as outlined below

Testing

Starting October 1, 2016, all marijuana items must be sampled and tested according to OAR 333-007-0300 to 333-007-0490 and OAR 333-064-0100 to 333-064-0110.  On and after October 1, 2016, any laboratory that tests marijuana items must be accredited by ORELAP and licensed by OLCC. Only accredited and licensed laboratories may sample and test marijuana items. A list of accredited and licensed laboratories will be made available on the OMMP laboratories web page. http://public.health.oregon.gov/DiseasesConditions/ChronicDisease/MedicalMarijuanaProgram /Pages/laboratories.aspx  

For Dispensaries:  On or after October 1, 2016, a dispensary may continue to sell marijuana items that were not sampled and tested by an accredited and licensed laboratory if:  The items are transferred to the dispensary before October 1, 2016; The items comply with the concentration limits, labeling and packaging rules found in division 7 of the rules; and The items are labeled with a label that reads “DOES NOT MEET NEW TESTING REQUIREMENTS” in 12-point font, and in bold, capital letters.  

A dispensary will only be allowed to transfer these products to patients, caregivers and consumers until January 1, 2017.  

Concentration Limits

Beginning October 1, 2016, all cannabinoid products, cannabinoid concentrates or extracts must meet the concentration limits as outlined in OAR 333-007-0200 and 333-007-0220. Lowdose cannabinoid edibles sold to retail customers from medical dispensaries during the early start period must continue to meet the definition found in OAR 333-008-1500(1)(k).