The July 1, 2021 deadline for “Inhalable Cannabinoid Products with Non-cannabis Additives” (“ICP”) is rapidly approaching.  Generally, ICPs are vape cartridges and pre-rolls with non-cannabis terpenes or flavorings. On and after July 1, 2021, licensees cannot possess or transfer these products unless they comply with the new rule standards.

Before July 1, 2021, licensees can sell, destroy (waste), or return to the processor any ICPs that do not comply with the new rules – but if returning to another licensee, the ICPs will still need to be wasted in compliance with OLCC rules prior to July 1, 2021.

Licensees can use the following to spot labels subject to the “sell down” (cannot be possessed or transferred on and after July 1, 2021) and what labels are not subject to the sell down:

• Labels subject to the sell down contain product identities like “marijuana extract with non-marijuana terpenes” or “marijuana extract with natural and artificial flavors” and ingredient listings that state “natural” or “artificial flavors.” Here is an example;
• Labels that are NOT subject to the sell down contain product identities and ingredient listings that contain the words “non-cannabis additives” and list all the ingredients in the product – either on an insert or on the exterior label. Here is an example.
• Licensees may no longer utilize generic labels for ICPs created on and after April 1, 2021.

Questions related to the rules or labeling should be directed to marijuana.packaging@oregon.gov.

Questions related to Metrc should be directed to marijuana.cts@oregon.gov.