by Rick Thompson/January 4, 2021
On January 4, the Michigan Marijuana Regulatory Agency issued their first technical bulletin of the new year, titled “Process to Obtain Agency Approval for Production of Marijuana-Infused Beverages”. The regulations it contains includes guidance “for the submission and approval of a marijuana-infused beverage,” as well as “expectations for ongoing research and product development”.
You can read the bulletin HERE.
“All marijuana-infused beverages must be shelf-stable and should be produced in such a way as to ensure a product is safe for ingestion and consistent in production,” the Bulletin reads in part. Shelf-stable means “foods that can be safely stored at room temperature,” per the USDA, so refrigerated beverages are not authorized by this Technical Bulletin.
Alcoholic beverages are not allowed for consumption or sale at Marijuana Regulatory Agency licensed facilities, so cannabis infused beer, wine and spirits are also not authorized by this Bulletin.
Those wishing to produce cannabis-infused beverages must conduct a product stability and THC-leeching study before the product is released. THC cannot vary more than 15% from the quantity at packaging, or the beverage fails to meet the MRA standards for product launch. If a beverage is studied for six months and is proven stable in content for that period, then six months will be the expiration date for the beverage once produced for sale.
At least fourteen different characteristics of the beverage must be monitored during the research period, including pH and sedimentation. “The result of these studies should be submitted to the agency when the producer is ready to launch the infused beverage and quarterly thereafter for a year,” per the Bulletin.
One sticking point is the requirement that any processing facility producing cannabis-infused beverages must be “in the process of receiving Good Manufacturing Practices (GMP) certification.” This is a non-governmental certification standard which is very controversial. In other states, large corporate entities have tried to establish difficult standards for industry to meet, with the intent of making it impossible for small companies in the space to compete profitably. GMP is one of those certification standards. Processors of cannabis-infused foods are not currently required to meet the GMP standards, which makes this an inexplicable inclusion.
In Michigan, the legislature in 2016 established cannabis testing standards which were considered by many to be toughest-in-the-nation; most observers noted that this was a tactic to reduce competition within the testing industry, which it did. Since the 2016 MMFLA program was initiated, those testing standards have been modified multiple times in multiple ways to allow for larger batch sizes, more favorable contamination standards and to allow remediation procedures for cannabis harvests which don’t pass the rigorous standards.
Standards for cannabis-infused beverages are the same as for other infused products, but with three additions, per the Bulletin. Beverages will have to undergo testing for pH, terpenes and for homogeneity, under a standard specific to beverages.
Director Brisbo spoke about cannabis-infused beverages on a recent edition of Four20Post. The about social consumption lounges and beverages begins at approx. 53:30 in the broadcast. View that broadcast HERE.
View testimony in opposition to banning cannabis-infused beverages from three years ago at this YouTube video from Michigan’s senate.
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