🚨 S4847 Update: NJ enforcement expanding with no Legacy Pathway.
Enhancing Consumer Safety and Transparency Through Extraction Method Labeling
New Jersey’s cannabis consumers currently have no visibility into the extraction methods used to create concentrates and infused products. This lack of disclosure limits consumer choice, creates potential safety risks, and undermines transparency across the market.
Extraction methods directly affect the safety, purity, and quality of finished products. Solvent-based processes (such as hydrocarbon or ethanol extraction) may carry residual solvent risks if improperly purged, while solventless or mechanical extraction methods (such as rosin or ice water hash) are often viewed as safer and more natural.
Without clear labeling, consumers—especially medical patients and those with sensitivities—cannot make informed decisions. Meanwhile, manufacturers who invest in cleaner, higher-quality extraction techniques receive no marketplace recognition for their standards.
Multiple U.S. jurisdictions already require labels to disclose the extraction method and/or solvents used to produce cannabis concentrates and infused products—including Washington, Illinois, Nevada, Maine, and Colorado—providing clear, enforceable precedent for the CRC to adopt similar transparency standards.
The Manufacturing Committee recommends that the CRC amend product labeling requirements to include extraction method disclosure for all cannabis products, both medical and adult-use.
Key elements include:
Label Disclosure: Require all concentrate and infused product labels to specify the extraction process used (e.g., solventless rosin, CO₂, ethanol, hydrocarbon, distillate, etc.).
Standardized Terminology: Develop CRC-approved definitions and labeling terms to ensure consistency and prevent misleading or vague claims.
Verification and Enforcement: Mandate that laboratories include extraction method verification on Certificates of Analysis (COAs) to ensure labeling accuracy.
Medical Priority: Emphasize extraction transparency for medical-use products to protect patients with chemical sensitivities or compromised immune systems.
Implementing extraction method labeling will:
Enhance Consumer Health and Safety: Provide patients and adult-use consumers with clear information on solvents, chemicals, or extraction techniques used, empowering them to avoid products that may trigger sensitivities, allergies, or health risks. This transparency supports safer consumption decisions and aligns with public health best practices.
Strengthen Consumer Trust: Demonstrate that New Jersey manufacturers are committed to integrity, transparency, and product safety—building confidence in both the regulated market and CRC oversight.
Promote Regulatory Consistency: Align New Jersey’s labeling standards with other states, including Washington, Illinois, Nevada, Maine, and Colorado, which already require disclosure of extraction methods or solvents.
Recognize Manufacturing Integrity: Reward operators who invest in clean, solventless, or environmentally responsible extraction processes by enabling them to market their methods transparently and differentiate their products.
Support Informed Purchasing Decisions: Provide consumers, medical patients, and retailers with standardized labeling terminology that clarifies product characteristics and potency origins.
Advance Public Health and Equity Goals: Protect vulnerable populations—especially medical patients, seniors, and immunocompromised individuals—through full transparency of ingredients and processing methods, reinforcing New Jersey’s commitment to a safe, equitable cannabis market.
Including extraction methods on product labels is a simple, achievable step that advances consumer protection, aligns with public health goals, and reinforces New Jersey’s leadership in responsible cannabis regulation.
To ensure consistency, prevent misleading claims, and facilitate compliance, the Manufacturing Committee recommends that the CRC adopt the following standardized definitions and labeling terminology for extraction methods. These terms should appear on both product labels and Certificates of Analysis (COAs) when applicable.
1. Solventless Extraction
Definition:
A mechanical or physical process that separates cannabinoids and terpenes from cannabis plant material without the use of chemical solvents. Methods include ice water separation, rosin pressing, or dry sift (kief) collection.
Label Term: “Solventless Extract” or “Solventless Rosin.”
Example Use: Extraction Method: Solventless Rosin (Heat & Pressure).
2. Hydrocarbon Extraction
Definition:
A process using hydrocarbons such as butane, propane, or blends thereof to extract cannabinoids, terpenes, and other compounds from cannabis material. The extract is subsequently purged to remove residual solvents.
Label Term: “Hydrocarbon Extract.”
Example Use: Extraction Method: Hydrocarbon (Butane/Propane).
3. Ethanol Extraction
Definition:
A process using food-grade ethanol as a solvent to extract cannabinoids and terpenes from cannabis material. Post-processing includes solvent recovery and purification to ensure residual solvents are within allowable limits.
Label Term: “Ethanol Extract.”
Example Use: Extraction Method: Ethanol.
4. CO₂ (Carbon Dioxide) Extraction
Definition:
A method utilizing pressurized carbon dioxide (supercritical or subcritical) as the solvent for cannabinoid and terpene extraction, followed by controlled depressurization to separate the extract.
Label Term: “CO₂ Extract.”
Example Use: Extraction Method: CO₂ Supercritical.
5. Distillation
Definition:
A post-extraction refinement process in which cannabinoids are separated by heat and vacuum to achieve high purity. Distillation may follow any primary extraction method and should be labeled in conjunction with that method.
Label Term: “Distillate.”
Example Use: Extraction Method: Distillate.
6. Mechanical Separation (Non-Solvent Infusion)
Definition:
A process that uses mechanical pressure, heat, or agitation to infuse cannabis oil or concentrate into another product (e.g., butter, oil, or syrup) without chemical solvents.
Label Term: “Mechanically Infused.”
Example Use: Extraction Method: Solventless Mechanical Infusion
7. Hybrid or Multi-Step Extraction
Definition:
Products produced using multiple extraction processes (e.g., hydrocarbon followed by distillation) must disclose each stage to ensure transparency.
Label Term: “Hybrid Extract” or list all applicable methods.
Example Use: Extraction Method: Hydrocarbon to Distillate.
The CRC should publish these definitions in a technical guidance bulletin and require that extraction methods be displayed in the “Processing Method” field on all packaging and COAs.
Labels should list only approved terms and use consistent capitalization (e.g., “Extraction Method: CO₂” rather than marketing terms like “clean extraction”).
The CRC may allow limited secondary descriptors (e.g., small batch, cold-pressed) only if verifiable and not misleading under existing advertising rules.