by Rick Thompson/July 5, 2022
On July 1st Michigan’s Cannabis Regulatory Agency (CRA) issued new guidance for the production and sale of cannabis-infused tinctures.
The CRA maintains that there is no legal definition of ‘tincture’ contained within either the MMFLA, the state’s medical business law, or the CRMLA, the state’s adult-use business law. The accepted common definition of tincture is a mixture with a base of alcohol; the CRA feels Michigan cannabis manufacturers are not adhering to the regulations when producing this product for sale.
From the bulletin:
CRA policy has been that a product labeled as being a tincture must contain alcohol. The CRA recently reviewed products produced and sold by several licensees that are labeled and sold as tinctures. The products appeared to be non-compliant because they were labeled as a tincture but contained no alcohol and exceeded the allowable THC limit of 100 mg per container in the adult-use market (per the THC limits contained in this bulletin). The CRA has been notifying licensees that the sale of these products is a violation.
CRA Guidance for Tinctures, July 1, 2022
The CRA’s solution is to issue a warning and offer a 60-day amnesty period where the now properly-informed cannabis manufacturers can change their methods and ingredients. After August 30, 2022, Michigan manufacturers are expected to follow published guidelines.
Read the entire CRA bulletin from July 1, 2022 by clicking HERE.
