What Qualifies Something as a Tincture?

So that process is easy. I made exactly that just the other day. Stabilizing cannabinoids in a viscous syrup intended to be added to a larger volume of liquid isn’t very difficult with some basic emulsion additives. That’s a 600mg bottle with enough flavor concentrates to mask just about anything because it’s not intended to be consumed as is. The syrup itself would presumably taste horrible (over-concentrated flavor/sweeteners) but adding a tablespoon or two of it to a beverage would make it negligible. If it were just 8OZ of a watery Sprite-like beverage (rather than a syrup additive) with upwards to 1000mg of cannabinoids in it then I’d be very impressed.

Its possible. If you look at the holy grail of emulsion systems, regular old whole milk, there’s definitely room for oils in water. Just is very difficult to do and still be palatable and digestible, especially if the goal is a soft drink. I know of one way that follows a similar approach but it has a weird aftertaste to some people and the beverage itself costs just as much, if not more than the cannabinoids.

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I would take that as ‘don’t have any liquid, drink or sublingually administered product that doesn’t meet these guidelines’. Not worth the risk to me.

I again think how much can physically be disolved without making something that tastes horrible is still beside the point. It doesn’t have to be 1000mg either, it could definitely be 300mg and you’d still have the only high potency drink on the market.

And that does bring up another question, if tinctures are alcohol based, what’s stopping us from throwing distillate and vodka into an 8oz bottle and calling it a tincture? When in reality we are selling an alcoholic and cannabis infused beverage?

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Its called the alphabet boyz

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Oh okay then, 300mg I can get behind. I didn’t realize you were suggesting 1000mg arbitrarily. 300mg would be very doable from a practical sense. As far as regulatory guidelines, that’s going to depend on what state you’re operating in and what type of license. I don’t want to read the whole thread over but if you let me know which state it is and rec/med (or potentially both) then I could likely find the regs. There’s generally an entire section on tincture so it’s pretty straight forward what’s needed to comply. Some states treat it like a concentrate and disregard the carrier/liquid aspect entirely in rec but not on med.

As others have said, the question is of course if you want to take this risk. Sure, it might be compliant technically if you game the loopholes to pass it off as a tincture. Your state’s regulatory agency might not technically be able to reprimand you for the tincture but if they want to they may just bury you in audits until they find something they can hit you with. My point being pick your battles. I for one would not take such a risk knowing the costs of getting a license or the fines for a violation. If you want to take that risk then best you learn the regs like the back of your hand… and not just the tincture chapter.

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Definitely, I have been manufacturing in the regulated market sine Colorado transitioned from Med to Rec. I understand the need to thoroughly review the ordinance and that we are really in the business of compliance, and sell weed on the side. The question is what do you do when the ordinance is heavily lacking in clarification. This is California I am talking about, if you can find me the detailed list of compliance requirements to qualify something as a tincture, I would be happy to hear it. What I am saying is that I have looked, and I’m not finding anything definitive.

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