Packaging and Labeling & Marketing and Advertising Guidance for Adult-Use Licensees
Originally Published: September 1, 2022 Page 37
Updated: March 10, 2023
Appendix B: Health Claims
Licensees cannot make health claims in the packaging, labeling, marketing, or advertising of adult-
use cannabis products. This means licensees cannot characterize the relationship of any cannabis
product to a disease or health-related condition or symptom.
Some examples of behaviors that would be considered making health claims and are, thus, prohibited
include, but are not limited to:
• Licensees cannot claim—expressly or by implication—that a relationship exists between the
presence or level of a substance in a cannabis product and a consumer’s disease or health-
related condition or symptom. Claims that a cannabis product can prevent specific illnesses or
diseases or will treat any specific symptoms are not allowed.
• Licensees cannot claim that cannabis products, or any ingredients within a cannabis product,
are “curative”, “beneficial”, “therapeutic”, “antibacterial”, or “medicinal” in packaging, labeling,
marketing, advertising, or advertisements.
• Licensees cannot target pregnant people or people who are chest/breastfeeding in packaging,
labeling, marketing, advertising, or advertisements.
It does not matter whether a licensee believes that a health claim can be substantiated through
scientific research or if the claim is endorsed by a medical professional. Licensees cannot make any
health claims in packaging, labeling, marketing, advertising, or advertisements.
Some claims made in the packaging, labeling, marketing, advertising, and advertisement of cannabis
products may be permissible in other jurisdictions but would be considered health claims (and, thus,
prohibited) by this guidance. Some examples of health claims are:
• “Our cannabis product will treat pain better than prescription medication.”;
• “It is theorized that CBD has such a positive effect because of its impact on cannabinoid
receptors inside the brain of someone with Autism. CBD appears to ‘open’ these receptors’
pathways to allow molecules to act on them.”;
• “According to Dr. Cannabis, CNN's mental health expert, this product can restore the chemical
imbalance and help in dealing with depression, leading to improved sleep.”; and
• “Our product has also been hailed as a valuable substance for treating endometriosis with
some experts suggesting applying the topical directly to the pain site to help soothe
discomforts and aches.”
In addition to being made explicitly, such as the examples above, health claims can also be made
implicitly. Implicit health claims include statements, symbols, branding, or other communications that
suggest a health claim based on their context. In some scenarios, two pieces of content that would
not be considered implicit health claims when used on their own could, when used in combination,
create an implicit health claim, depending on the nature of the content. For example, a heart symbol
used on packaging or labeling may be allowed, depending on the context, but if a heart symbol is
used in conjunction with a plus sign or a check mark, then the context created by using these
symbols together would create an implicit health claim, which is not allowed.