Cannabis Recall
Last reviewed · By Chad Griffith
A cannabis recall is the regulated removal of cannabis products from the supply chain due to potential health risks (failed lab testing, contamination, mislabeling) or compliance violations. Most state Cannabis Regulatory Authorities require licensed cannabis businesses to maintain a written recall plan covering: recall classifications (Class I imminent health hazard, Class II potential health hazard, Class III low-risk regulatory issue), recall initiation procedures, customer/retailer notification methods, recovery and quarantine of recalled products, METRC reporting of recall events, and disposal of recalled products. Recalls can be voluntary (initiated by the licensee) or mandatory (ordered by the CRA). Failure to maintain a written recall plan or execute a required recall promptly results in escalating enforcement actions.
Frequently Asked Questions
What triggers a cannabis recall?
Common triggers: failed retest of a previously-released batch (potency, microbials, pesticides), contamination identified post-distribution, mislabeling discovered after distribution, a customer health complaint traceable to a specific batch, or CRA inspection finding non-compliant product in commerce. Some states (Massachusetts, California) have published recall classification frameworks borrowed from FDA food recall practice.
What must a cannabis recall plan include?
State CRA recall plan requirements typically include: designated recall coordinator, recall classification framework, customer/retailer notification procedures (timelines, communication methods), product recovery and quarantine procedures, METRC reporting steps, disposal protocols (including witnessed destruction in some states), corrective action documentation, and post-recall effectiveness review. Plans must be reviewed and updated periodically (typically annually).
Who must be notified during a recall?
Notification requirements vary by recall class but typically include: the state CRA (immediately or within 24 hours), all licensees who received the affected product (within state-specific timeframes), end consumers (for Class I imminent hazard recalls — typically through dispensary notification, public press release, and in some states direct customer notification via QR-code-tied sale records), and in some states the state Department of Health.
What happens if a licensee fails to execute a recall?
Failure to comply with recall requirements is among the most serious enforcement actions in cannabis regulation. Penalties typically include: civil money penalties (often $25,000+ per violation), license suspension pending compliance, mandatory third-party recall execution at licensee expense, and in cases of willful non-compliance license revocation. Some states criminalize failure to comply with health-and-safety recalls.
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