Homogenization of THC in Products

It has come to our attention that some licensees are spraying or coating THC on edible products. This message is to inform licensees that spraying THC on products without additional processing is out of compliance with WSLCB rules.

WAC 314-55-077 includes the following requirements:

• (5)(c) Marijuana-infused solid edible products must be homogenized to ensure uniform disbursement of cannabinoids throughout the product.
• (6)(c) Marijuana-infused liquid edibles must be homogenized to ensure uniform disbursement of cannabinoids throughout the product.

Including the word “throughout” means that the THC must be uniformly disbursed all the way through marijuana-infused edible products. Surface sprays or coating products are not generally sufficient to meet this requirement in rule. In other words, the THC must be three-dimensionally incorporated into a product, not just two-dimensionally on the surface of a product.

This requirement was included in WSLCB rule to ensure standard, consistent serving sizes, and to address public safety concerns surrounding risk of exposure to children.

Since the homogenization requirement is a WSLCB rule, the Washington State Department of Agriculture (WSDA) does not have the authority to authorize THC homogenization methods or techniques in their review of product recipes or ingredients. WSDA may make suggestions to licensees regarding homogenization concerns when they receive information on the processing process the licensee is using or plans to use, but WSLCB is the final approval authority regarding homogenization.

Product approval is a two step process, WSDA approval of recipe or ingredients and WSLCB approval of the product. WSDA approval of a recipe or ingredient list for marijuana-infused edible products does not mean the product also meets WSLCB rule requirements