Cannabis Control Division November Newsletter

November 4, 2024

Solvent-Based Tinctures and Marijuana-Infused Tinctures

Tinctures made with alcohol are considered to be extracts/concentrates. ARM 42.39.601(60) includes these tinctures under the definition of “solvent-based marijuana concentrate and extract.” Tinctures made with alcohol must be tested as an extract/concentrate and categorized as such in Metrc. These tinctures must be labeled as a concentrate/extract not requiring heat, as required in ARM 42.39.318(1)(c)(ii). Alcohol-based tinctures cannot exceed 800 milligrams per package, per 16-12-224(8)(b)(iii), MCA.

Tinctures made without alcohol fall under the marijuana-infused product category, must be tested as such, and contain no more than 10mg THC per serving and 100mg THC per package. Tinctures made without alcohol must be labeled as a marijuana-infused product, as required in 42.39.316(1)(c). A 10% variance per serving and package for edible marijuana-infused products is allowed per 16-12-224(8)(c), MCA.

Possession limits and sale limits apply, based on ARM 42.39.118(2); these limits are no more than 8 grams or milliliters of alcohol-based tinctures and no more than 800 milligrams of a marijuana-infused tincture. The different requirements for testing marijuana and marijuana products can be found in the Quality Assurance Testing Requirements Appendix Version 1.0, link below:

Processing Times – Payments

Payments made for applications can take 3-5 business days to process and post. Worker permits and business applications cannot be processed until the payment has been posted. Full payment is required for a worker permit application, and the processing fee is required for a business application. The Cannabis Control Division cannot process these applications on the same day they are submitted.

Exit Packages – Required Statements

Per ARM 42.39.319, all marijuana and marijuana products provided to customers at the point of sale shall be in exit packaging that is child-resistant, opaque, and contains the following verbatim warnings as required by 16-12-215 MCA.

  • WARNING: Consumption of marijuana may cause anxiety, agitation, paranoia, psychosis, and cannabinoid hyperemesis.
  • WARNING: Consumption of marijuana by pregnant women may result in fetal injury and low birth weight.
  • WARNING: Consumption of marijuana by nursing mothers may result in infant hyperactivity and poor cognitive function.

A label template, with these warnings, are available online. Please note that two (2) sets of warnings are on each label to help save on associated costs. There is no differing set of required warnings for medical cardholders versus adult consumers.

Retail Price Study

This Retail Price Study reviews the top 6 selling product categories as reported to the Cannabis Control Division’s (CCD) seed-to-sale tracking system from January 2022 to June 2024. These product categories are Buds, Concentrate, Infused (Edibles), Pre-Rolls, Infused (Non-Edibles), and Shake/Trim. The product categories are presented in descending order based on their market share over a 30-month period:

  • Low sales volume product categories (Kief, Plants, and Seeds) are not included in the study.
  • Monthly sales volume stats for quantity sold, revenue, and average retail prices per unit are provided.
  • Reported seed-to-sale tracking system product sales volume totals encompass Adult Use and Medical sales.
  • Product revenue totals included in the report are based on Total Price amounts reported to the seed-to-sale tracking system from licensed dispensaries for products sold before tax and after any discounts.

This study can be found under the “Program Resources” section of the CCD website, or click the link below: