Which Products Require CRP?

To help businesses determine packaging requirements, here is a breakdown of cannabis product types and the CRP formats they typically require:

Single-Use CRP (requires label notice):

• Cannabis flower
• Pre-rolls
• Topicals
• Dab, shatter, wax
• Vape cartridges

Multiple-Use CRP:

• Edibles
• Tinctures and capsules
• Suppositories

Note: A multiple-serving package is not required to be child-resistant if each serving is individually packaged in CRP-compliant material.

Penalties for CRP Non-Compliance

Violating child-resistant packaging (CRP) requirements can lead to serious consequences. While exact fine amounts are not always publicly disclosed, non-compliance may result in citations, license suspension, product recalls, or even license revocation depending on the severity of the violation. Misleading packaging or failure to include required warnings can also trigger enforcement actions.

Although cannabis-specific enforcement cases are limited, past actions under the Poison Prevention Packaging Act (PPPA) show that regulators treat violations seriously. In 2018, a large pharmaceutical company was fined $5 million in a federal consent decree for knowingly distributing prescription drugs in packaging that did not meet child-resistant standards. This was the first civil penalty issued for PPPA non-compliance and delayed reporting.

This case demonstrates the potential risk for any company that overlooks CRP requirements. Cannabis businesses should prioritize packaging compliance and avoid designs or branding that could appeal to children, as these are frequent sources of violations in state inspections.

Compliance Checklist

To ensure CRP compliance, cannabis businesses should:

• Confirm packaging meets PPPA or state-accepted CRP standards
• Use single-use or multiple-use CRP as required for the product category
• Apply required labels to non-resealable packages
• Request CRP certifications from suppliers
• Review local laws and product classifications before launch