New York Cannabis Packaging Regulations: A Complete Guide

A complete guide to New York cannabis packaging regulations, including child resistance, tamper evidence, labeling, PCR content, warnings, and documentation.

Regulations & ComplianceMarch 21, 2024

Last reviewed: August 25, 2026

New York’s adult-use cannabis packaging and labeling requirements appear in Part 128 of the state’s cannabis regulations. They apply to the complete packaging system, not only the container.

Brands must evaluate the immediate package, retail package, optional marketing layer, closure, label, tamper-evident feature, liners, seals, and other components together. The finished configuration must satisfy the requirements that apply to the product, material, package layer, and intended use.

New York has revised its packaging and labeling guidance since the adult-use market launched. The current framework addresses child resistance, tamper evidence, recycled content, labeling, warnings, documentation, sustainability planning, and annual reporting.

This guide focuses on adult-use cannabis products. Medical cannabis, cannabinoid hemp, transportation, non-consumer packaging, retail exit packages, and other activities may be subject to different or additional requirements.

Use the current Part 128 guidance and packaging checklists and the adopted Part 128 and Part 129 regulations when planning and reviewing a package.

The licensee remains responsible for determining whether the complete finished package complies with every applicable requirement. This guide provides general information and does not constitute legal advice.

Understand Which Package Layers Must Comply

New York distinguishes among several package layers and components:

Immediate package: The package in direct contact with the cannabis product.
Retail package: The package offered to the consumer at retail. It may be the immediate package or may contain the immediate package.
Marketing layer: An optional outer layer used for branding, marketing, or retail presentation.
Outermost layer: The retail package or, when one is used, the marketing layer visible to the consumer.
Non-consumer packaging: Packaging used for transportation, storage, or transfer that is not intended for the retail consumer.

Cannabis product packaging includes all packaging elements except non-consumer packaging. Labels, closures, liners, seals, inserts, and tamper-evident components should be evaluated as parts of the complete system.

Placing an immediate package inside a box, bag, or other outer layer does not eliminate the retail-package requirements. The retail package must still provide the functions assigned to it.

The outermost layer matters because required information, warnings, and the New York universal cannabis symbol must appear on the retail package or, when one is used, the marketing layer.

Before choosing a format, map every required function and label element to the package component responsible for providing it. Then review the complete assembled package.

Meet the Minimum Retail-Package Standards

New York retail cannabis packages must:

Be child-resistant for the entire life of the product
Be tamper-evident without covering or obscuring required labeling, including after opening
Fully enclose the cannabis product
Be sealed to protect the product from oxygen exposure, contaminants, and degradation
Avoid imparting toxic or harmful substances to the cannabis product
Be resealable when the package contains multiple servings

These requirements apply even when the immediate package is placed inside another package.

The rules do not create one universal claim that every package must be airtight, watertight, odor-proof, or leakproof. Required performance depends on the product and finished package. Test the complete configuration under the actual filling, storage, transportation, retail, and consumer-use conditions.

Document Child Resistance

New York requires licensees to maintain records showing that each retail package satisfies the applicable child-resistance standards.

The state points to the current 16 CFR 1700.15 effectiveness specifications and 16 CFR 1700.20 testing procedures.

Request documentation for the exact package and closure configuration being ordered. A certificate for a similar container, different size, different closure, or different material should not be assumed to cover the finished package.

Confirm that labels, bands, inserts, seals, and customization do not interfere with closure operation. Child-resistant does not mean childproof.

Plan Tamper Evidence Separately

Tamper evidence is separate from child resistance and resealability.

A child-resistant closure does not automatically provide visible evidence that a package has been opened. A tamper-evident label, band, seal, breakaway feature, or properly sealed package section may provide that evidence, but it does not make the package child-resistant.

The tamper-evident feature must not cover required information or cause required information to break away, become covered, or become unreadable when the package is opened.

Test the finished package to confirm that the tamper-evident feature performs as intended and does not interfere with the closure, label, universal symbol, warnings, or other required elements.

Apply the 25% PCR Requirement Correctly

New York generally prohibits plastic packaging for cannabis products unless it contains at least 25% post-consumer recycled content.

This requirement applies to plastic packaging. It does not mean that every glass, metal, paperboard, or other non-plastic package must contain 25% PCR material.

New York defines post-consumer recycled content as material produced from recovered and reprocessed material that was originally sold for consumption and would otherwise have been discarded or processed as waste.

The definition excludes:

Post-industrial material
Material produced through combustion or incineration
Material produced through pyrolysis or gasification
Material produced through solvolysis
Chemical recycling
Other high-heat or conversion processes

Do not treat every recycled-content claim as proof that a plastic package satisfies New York’s PCR requirement. Request documentation that identifies the package component, material, percentage, and basis for the claim.

Understand the Limited Exceptions

The 25% minimum does not apply to:

Plastic components necessary to satisfy child-resistance requirements, such as push buttons or locking mechanisms
Items for which no option containing post-consumer recycled content is available

The second exception requires due diligence. The licensee must maintain proof that it examined packaging alternatives and found no PCR-containing option. That documentation must be readily available to the Office of Cannabis Management upon request.

New licensees have 12 months from their licensure date to comply with the 25% minimum and must provide evidence of compliance at their initial license renewal.

Documentation supporting compliance with the plastic-packaging restriction must also be available to the Office upon request.

Maintain the Required Sustainability Program & Records

Depending on the license type, processors, microbusinesses, cooperatives, and registered organizations must submit an environmental sustainability program for cannabis product packaging as part of the application and licensing process.

At renewal, applicable licensees must submit an environmental sustainability product packaging plan that reduces plastic use.

Licensees that package cannabis products for retail sale must also report packaging metrics annually, including:

Total packaging weight introduced into New York during the prior calendar year
Number of products sold in reusable packaging
Number of reusable packages refilled
Total packaging cost
Material composition for reporting required after December 31, 2025
Other information required by the Office

Create a packaging-data process before the reporting deadline. Track each packaging component by material, weight, quantity, cost, recycled content, and intended use.

Claims involving recycled content or recyclability must also comply with the FTC’s Green Guides. Keep environmental claims specific to the documented component and appropriately qualified.

Avoid Packaging & Labeling That Appeals to People Under 21

New York prohibits cannabis product packaging and labeling that is attractive to people under 21.

Prohibited elements include:

Cartoons or mascots
References or visual similarities to candy, cookies, soda, cereal, or other products commonly associated with young people, except for permitted cultivar names
The terms “candy” or “candies,” including spelling variations, except when used as part of a cultivar name
Characters, public figures, symbols, phrases, toys, or games commonly used in marketing to people under 21
Images of individuals who could reasonably appear to be under 21 unless the individual is at least 25 years old

The cultivar-name exception does not authorize a package to imitate youth-oriented food, candy, beverage, character, or entertainment branding.

Bright colors are not currently prohibited on their own. However, removing bright colors and cartoon-like fonts from the list of specific examples should not be interpreted as an endorsement. New York evaluates the total presentation.

Review the combined effect of:

Colors
Illustrations
Fonts
Characters
Product names
Package shapes
Flavor or cultivar references
Similarities to products commonly marketed to children
Digital and physical marketing presented with the package

Evaluate the finished package as a consumer would see it at retail, not as disconnected artwork files.

Plan the Label Around the Required Information

New York assigns different information to the principal packaging display panel and the outermost packaging layer.

The principal packaging display panel is the single panel that faces the consumer at retail. When a marketing layer is used, that layer becomes the outermost layer visible at the point of sale.

Select the complete package before finalizing the label. Package shape, panel size, closures, seams, tamper-evident features, and optional marketing layers can affect how the required information must be arranged.

Principal Packaging Display Panel

For cannabis products other than inhalable products, the principal packaging display panel must include:

Total THC in milligrams per serving and per package
Total CBD in milligrams per serving and per package, when required
Other marketed phytocannabinoids in milligrams per serving
Number of servings per package
Recommended serving size
Net quantity
Brand name

For inhalable cannabis products, the panel must include:

Total THC as a percentage of weight or volume
Total CBD as a percentage of weight or volume
Other marketed phytocannabinoids as a percentage of weight or volume
Net quantity
Brand name

The required information must remain unobstructed and conspicuous.

Outermost Retail or Marketing Layer

The retail package or, when one is used, the marketing layer must include:

All active and inactive ingredients in descending order by weight
Major allergens
Applicable nutrition or supplement facts
Solvents used to produce the cannabis product, when applicable
Expiration date for the unopened product
Proper storage conditions
Processor name, location, license number, and direct contact information
The New York universal cannabis symbol
Clear usage instructions, except for inhalable products
Lot identifier, lot number, or barcode
A scannable barcode or QR code linked to a downloadable certificate of analysis
A terpene profile when terpenes are marketed
Required warnings
Other information required by the Cannabis Control Board

The processor information must identify a business that actively manufactured the product, not a processor that only labeled or branded it. When multiple processors are listed, the manufacturer must be identified using the word “Manufacturer.”

Required label text must be:

Written or printed in English
Clearly visible
Legible against the background
No smaller than 6-point type after printing

Accurate translations may be added in other languages, but they do not replace the required English labeling.

Use the current Part 128 guidance and packaging checklists when preparing and reviewing the artwork.

Include the Universal Symbol & Required Warnings

Every cannabis product must display an approved New York universal cannabis symbol on the outermost layer of packaging.

Use one of the official square, vertical, or horizontal formats. The minimum dimensions are:

Square symbol: 1.25 inches high
Vertical symbol: 0.5 inch wide
Horizontal symbol: 0.5 inch high

The symbol must be conspicuous and use its approved design and colors. A contrasting outline may be used when needed for visibility.

Do not place the universal symbol on a tamper-evident seal or another removable part of the package.

Required Warnings

The retail package or marketing layer must include:

“This product contains cannabis and THC”
“KEEP OUT OF REACH OF CHILDREN AND PETS. For use only by persons 21 years of age and older”
“Warning: Do not use if pregnant or nursing”
“Poison Center 1-800-222-1222”

Product-specific warnings also apply:

Smoked, inhaled, or vaporized products: “Warning: Smoking or vaping is hazardous to health”
Orally ingested products: “Warning: Effects of this product may be delayed by 4 or more hours”
Topical products: “Warning: For topical use only. Do not eat or smoke”

If the word “Warning” appears as the header for the entire warning section, it does not need to be repeated before each warning.

Warnings must use Times New Roman, Calibri, Arial, or Helvetica and appear in text no smaller than 6-point type.

Rotating Health Warnings

Each package must also display one rotating health warning:

“Cannabis can be addictive.”
“Cannabis can impair concentration and coordination. Do not operate a vehicle or machinery under the influence of cannabis.”
“There may be health risks associated with consumption of this product.”
Another warning later required by the Office

Use one rotating warning per package. The warnings should be rotated and distributed so that each appears on approximately the same number of labels over the calendar year.

Small-Package Labeling

Accordion, booklet, expandable, extendable, dry-release, and peel-and-reseal labels may provide additional space on small packages.

However, the following information cannot be moved exclusively to those expandable areas:

Principal packaging display panel information
The universal symbol
“This product contains cannabis and THC”
“KEEP OUT OF REACH OF CHILDREN AND PETS. For use only by persons 21 years of age and older”

No required information should be placed only on a seal or label section that breaks, detaches, becomes covered, or becomes unreadable when the package is opened.

Review the finished printed label at actual size. A digital proof does not establish that required text, symbols, warnings, or codes will remain legible and functional after production and application.

Avoid Prohibited Labeling & Unsupported Claims

New York prohibits packaging or labeling that is false or misleading, contains health claims, promotes overconsumption, uses unauthorized special branding, or falsely implies authorization under the medical cannabis or cannabinoid hemp programs.

Tamper-evident features must not obstruct required information or separate required information from the package when opened.

Specific claims also require support:

Organic: The product must contain at least 70% certified organic ingredients, excluding salt and water, and the claim must satisfy applicable USDA requirements.
Craft: The processor must have the applicable Office of Cannabis Management designation.
Gluten-free: The product must satisfy the applicable federal definition.
Vegan: The product must contain no animal-derived ingredients.
Kosher: The product must satisfy applicable New York requirements.

Environmental claims require documentation for the exact package component and attribute being described. A supplier description, marketing phrase, or broad material assumption is not sufficient substantiation for the finished package.

Review health, compliance, performance, product, material, recycled-content, recyclability, biodegradability, compostability, reuse, and sustainability claims before approving the artwork.

Build a Documented Packaging Approval Process

Create a written package specification for each product and SKU.

Record:

Product type and intended use
Immediate package, retail package, marketing layer, and outermost layer
Material for every package component
Component weights
Documented PCR percentages
Closure and child-resistant configuration
Tamper-evident feature
Liners, seals, inserts, labels, inks, adhesives, and coatings
Product-contact surfaces
Package dimensions and capacity
Supplier and manufacturing location
Case quantities and order quantities
Artwork version and approval date
Lot, batch, expiration, and variable-data process
Intended storage, transportation, and filling conditions

Retain supporting documents, including:

Child-resistant test reports or certificates
Material and recycled-content documentation
Product specifications
Food-contact documentation when applicable
Approved proofs
Finished-package samples
Supplier confirmations
Due-diligence records for any exception
Annual packaging data
Legal and regulatory review records

Test production-representative samples with the actual product, closure, label, seal, insert, and other components. Evaluate closure operation, tamper evidence, resealability, product fit, label adhesion, code readability, handling, and distribution performance.

Use the Office of Cannabis Management’s current Part 128 packaging and labeling checklists as a starting point, then add the requirements that apply to the exact product and business.

Repeat the review whenever the package, supplier, component, product, label, artwork, process, market, regulation, or guidance changes.

Compare Packaging Options Against Each Required Function

Sana Packaging offers several products with documented attributes that can support a New York packaging configuration. However, no individual product should be described as automatically compliant with every New York requirement.

Compliance depends on the complete package, including its closure, label, tamper evidence, recycled content, documentation, intended use, and finished configuration.

PCR Pop-Top Tubes

Sana Packaging’s PCR Pop-Top Pre-Roll Tubes are made from 100% post-consumer-recycled polypropylene and feature certified child-resistant pop-top closures.

Available sizes include formats designed for individual pre-rolls. The tubes are documented as:

Made in the USA
Food-grade and FDA-compliant for applicable uses
Made from 100% post-consumer recycled polypropylene
Recyclable where #5 polypropylene is accepted
Equipped with certified child-resistant closures

The documented PCR percentage exceeds New York’s 25% recycled-content threshold for applicable plastic packaging. The brand must still confirm the complete package, labeling, tamper evidence, intended use, and required documentation.

PCR Pop-Top Multipacks

The 116mm PCR Pop-Top Pre-Roll Multipack can hold up to five 109mm pre-rolls.

It is made from 100% post-consumer-recycled polypropylene and features a certified child-resistant pop-top closure. Confirm the actual product fit, required tamper evidence, labeling area, and finished-package performance before ordering.

PCR Pop-Top Bottles

Sana Packaging’s PCR Pop-Top Bottles are designed for products such as flower, edibles, and other compatible cannabis formats.

The bottles are made from 100% post-consumer recycled polypropylene and use certified child-resistant pop-top closures. Available sizes, case quantities, and customization requirements should be confirmed for the exact bottle being ordered.

The documented recycled content can support compliance with the applicable New York material requirement, but it does not establish compliance with labeling, tamper-evidence, product compatibility, or market-specific requirements.

Flexible PCR Pouches

Sana Packaging’s Flexible PCR Pouches can be configured with standard materials or structures containing up to 65% post-consumer recycled content.

The exact configuration matters:

Not every pouch structure contains PCR material.
Not every zipper configuration is child-resistant.
A configured child-resistant zipper can provide child resistance when supported by the applicable documentation.
The heat-sealed section above the zipper can provide tamper evidence when properly filled and sealed.
The selected structure must contain at least 25% qualifying PCR material to support New York’s applicable plastic-packaging requirement.
Multilayer flexible structures are generally not accepted through conventional curbside recycling programs.

Confirm the material structure, PCR percentage, closure, sealing process, documentation, and intended use in the project quote.

Tamper-Evident Components

Customizable Stone Paper Tamper Bands can provide visible evidence that a package may have been opened.

A tamper band does not make a package child-resistant and does not replace a required label. Its placement should not cover the universal symbol, warnings, product identity, or other required information.

Test the band on the finished package to confirm that it tears as intended without interfering with the closure.

Other Material Formats

Glass, metal, and paperboard formats are not automatically subject to the 25% PCR requirement that applies to qualifying plastic packaging. However, plastic closures, liners, seals, labels, inserts, and other components may require separate evaluation.

For every format, map each New York requirement to the package component responsible for providing it. Then confirm that the complete assembled package performs as intended.

Plan Printing & Labeling Around New York Requirements

Select the complete package before finalizing the label or direct-print artwork.

The package shape, closure, tamper-evident component, printable area, and required information determine how the artwork should be structured.

Before beginning design, confirm:

The exact package and closure
The current product-specific artwork template
The principal display panel
The outermost package layer
Available label or print areas
Closure clearance
Tamper-evident band or seal placement
Required warning statements
Universal-symbol placement and size
Required cannabinoid information
Net-quantity placement
Ingredient and allergen information
Lot, batch, expiration, and storage information
QR-code size and readability
Number of SKUs
Variable-data requirements
Minimum type size
Production and application method

Labels, direct printing, and tamper-evident components should be planned as one system. A label or band should not interfere with the child-resistant closure or obscure information required to remain visible.

Sana Packaging may support pressure-sensitive labels, label printing and application, direct printing, or other product-specific customization methods. Availability, minimum quantities, templates, and production schedules vary by product and project.

Label printing and application means that labels are printed and applied to the packaging before shipment. This can reduce the number of vendors, production steps, and in-house application work.

Direct printing applies artwork to the package surface instead of using a separate pressure-sensitive label. It requires a product-specific template and careful review of printable areas, seams, closures, moving components, color tolerances, and production limitations.

Learn more about Sana Packaging’s Printing & Labeling services.

Before approving the artwork:

Confirm that all required New York elements appear on the correct package layer.
Verify the principal display panel and outermost-layer requirements.
Check the dimensions of the universal symbol and warning statement.
Confirm the correct rotating health warning.
Verify cannabinoid, serving, ingredient, allergen, and net-quantity information.
Test QR codes and barcodes at their final printed size.
Confirm that the label or band does not interfere with child resistance, resealability, or tamper evidence.
Review the exact finished package under normal handling, storage, transportation, and opening conditions.

A digital proof can confirm copy, placement, orientation, print areas, and basic production setup. It does not independently establish legal compliance, finished-package performance, final color, label adhesion, or closure operation.

The licensee remains responsible for reviewing and approving the finished package for every New York market requirement that applies.

Complete a Final New York Packaging Review

Before approving a package for production, complete a final review of the entire packaging system.

Confirm that the project team has:

Identified the immediate package, retail package, optional marketing layer, and outermost layer.
Mapped child resistance, resealability, tamper evidence, and product protection to the components responsible for providing them.
Obtained documentation for the exact child-resistant package and closure configuration.
Confirmed whether each plastic component is subject to the 25% PCR requirement.
Collected documentation identifying the qualifying recycled-content percentage.
Documented any exception being used and the required due diligence.
Confirmed that the package and label do not appeal to people under 21.
Placed all required information on the correct package layer.
Verified the universal symbol, warnings, type sizes, and rotating health warning.
Tested QR codes, barcodes, label adhesion, tamper evidence, and closure operation on the finished package.
Reviewed every product, compliance, health, and environmental claim for adequate support.
Established a process for retaining package specifications, proofs, certificates, test records, supplier documentation, and annual packaging data.
Rechecked the current Part 128 guidance and packaging checklists before production.

Requirements and guidance can change. Repeat the official-source review when the package, product, artwork, supplier, regulation, or intended use changes.

Frequently Asked Questions About New York Cannabis Packaging Regulations

What are New York’s cannabis packaging requirements?

New York adult-use cannabis products must use packaging that satisfies applicable child-resistance, tamper-evidence, sealing, labeling, warning, recycled-content, and documentation requirements. The exact requirements depend on the product, package layers, materials, and intended use. Review the current Part 128 guidance and packaging checklists before approving a package.

Does cannabis packaging in New York have to be child-resistant?

New York retail cannabis packaging must be child-resistant throughout the life of the product. Child resistance depends on the complete package and closure configuration, not the container alone. Request documentation that matches the exact package being ordered and test the finished configuration after labels, seals, and other components are added.

Does New York require tamper-evident cannabis packaging?

Yes. The retail package must include a tamper-evident feature that provides visible evidence if the package has been opened or altered. Tamper evidence is separate from child resistance, so a child-resistant closure does not automatically satisfy the tamper-evidence requirement.

Does every cannabis package in New York need 25% PCR content?

No. New York’s 25% post-consumer recycled-content requirement generally applies to plastic cannabis packaging. It does not mean that every glass, metal, paperboard, or other non-plastic package must contain PCR material. Limited exceptions may apply to plastic components necessary for child resistance and items for which no PCR-containing alternative is available, but the licensee must maintain the required supporting documentation.

What information must appear on a New York cannabis label?

Required information can include cannabinoid content, serving information, net quantity, brand name, ingredients, allergens, processor information, storage conditions, expiration date, usage instructions, lot information, a QR code linked to a certificate of analysis, the universal cannabis symbol, and required warnings. Some information must appear on the principal packaging display panel, while other information must appear on the outermost retail or marketing layer.

Where must the New York universal cannabis symbol appear?

The approved New York universal cannabis symbol must appear conspicuously on the outermost layer of packaging. It must meet the minimum dimensions for the selected square, vertical, or horizontal format. Do not place it only on a tamper-evident seal or another removable package component.

Can cannabis packaging in New York use bright colors?

New York does not currently prohibit bright colors on their own. However, the complete packaging and labeling must not be attractive to people under 21. Review the total presentation, including colors, illustrations, fonts, characters, product names, shapes, and references to products commonly marketed to children.

Are individual packaging products automatically compliant with New York requirements?

No. A product may have documented attributes that support specific requirements, such as a certified child-resistant closure or qualifying PCR content, but that does not establish compliance for the complete finished package. The licensee is responsible for confirming the package, labeling, tamper evidence, documentation, product compatibility, and all other applicable New York requirements.

Request a Project-Specific Packaging Quote

Provide enough information to evaluate the complete package rather than an individual component.

Be prepared to share:

Cannabis product type
Intended use
Package size and capacity
Number of servings
Product-contact requirements
Child-resistance requirements
Tamper-evidence requirements
Preferred material and PCR target
Package and closure configuration
Order quantity
Number of SKUs
Label or direct-print requirements
Variable-data requirements
Target production date
Shipping destination
Sample-testing requirements

Sana Packaging can help identify packaging options, customization methods, documentation, and samples for further evaluation. The licensee and its legal or regulatory advisors remain responsible for determining whether the complete finished package complies with applicable New York requirements.

Contact Sana Packaging to compare packaging options and request a project-specific quote.

Compare requirements across U.S. markets in State Cannabis Packaging Regulations: A Complete Guide.