If you’re a dispensary owner or brand selling in Minnesota, New York, Illinois, Missouri, Ohio, New Jersey, Maryland, or Connecticut, your current child-resistant packaging probably won’t cut it in 2026.
Regulators are moving from the old “16 CFR 1700.20 poison prevention” standard to the new ASTM D3475-2024 + full CPSC senior-friendly testing requirements. Translation: a lot of the cheap CR bags, pop-top bottles, and exit bags you’ve been using for years will become non-compliant on January 1, 2026.
One failed re-test = immediate product recall + $25K–$250K per SKU in repackaging costs + possible license suspension.
The good news? You can switch to fully compliant packaging right now for less than 3–9¢ extra per unit if you do it smart.
What’s Actually Changing in 2026 (State-by-State Breakdown)
| State | New Rule Effective | Key Change vs Today | Testing Required |
| Minnesota | Jan 1, 2026 | Must pass full 200-child + 100-senior ASTM protocol | CPSC-certified lab only |
| New York | Jan 1, 2026 | Exit bags no longer exempt; must be CR-certified | Full re-test of every SKU |
| Illinois | July 1, 2026 | 95% child-resistant effectiveness (up from 85%) | New senior-friendly re-test |
| Missouri | Jan 1, 2026 | Liquid edibles <5 mL must be in opaque CR bottles | Full ASTM + opacity certification |
| Ohio | Mar 1, 2026 | All pre-roll tubes must have permanent CR caps | No more slide-lock tubes |
| New Jersey | Jan 1, 2026 | Printed “This Bag Is Not Child-Resistant” banned | Exit bags must now be fully CR |
The 3 Packaging Items That Will Get You Fined Fastest in 2026
- Current 1.0 mylar exit bags → 2026: Must be lab-certified child-resistant (not just “resealable”).
- Pop-top vials that pass 16 CFR but fail the new 200-child panel → Most cheap 13/19/30 dram vials fail the updated protocol.
- Non-opaque liquid tincture bottles → Missouri & NY now require you can’t see the liquid through the bottle.
Cheapest Way to Be 100% Compliant Before January 2026
Do this exact 5-step switch and you’ll spend $0.02–$0.09 more per unit instead of $0.25–$1.00 in panic mode next year.
Step 1 – Audit Every SKU This Month
Make a simple spreadsheet: SKU | Current Package | Passes New ASTM? | Cost to Switch.
Step 2 – Switch to These Proven 2026-Compliant Options (All Under 9¢ Premium)
| Product Type | 2026-Compliant Choice | Extra Cost vs Today | Best Supplier (2025 Pricing) |
| Flower (1–28g) | Certified CR mylar + ASTM sticker | +2–4¢ | Pollen Gear, CRatelabs, Impak |
| Pre-rolls | Hinged-lid CR tubes (no slide locks) | +3–6¢ | Green Rush Packaging, Cannaline |
| Edibles | CR tin or blister + opaque sleeve | +5–9¢ | The Tin Box Co, CR Solutions |
| Vapes / Concentrates | Permanent-cap CR cartridges + CR box | +4–7¢ | iSpire, Greenlane, Kush Supply |
| Tinctures (<5mL) | Opaque black glass + CR dropper cap | +6–8¢ | Berlin Packaging, TricorBraun |
| Exit Bags | Fully certified resealable CR bags | +3–5¢ | Dymapak, CRatelabs |
Step 3 – Buy 6–9 Months of Inventory Before December 31, 2025
Most suppliers are raising prices 18–28% in Q1 2026. Lock in 2025 pricing now.
Step 4 – Add the New Mandatory Labeling (Free Template)
Download the 2026-compliant universal symbol + “Keep Out of Reach” artwork pack here: [free 2026 label templates]
Step 5 – Get One Pre-Certification Test ($650–$1,200 per package type)
One CPSC lab test now prevents $100K+ recall later.
Your 2026 Packaging Compliance Calendar (Pin This Up)
- Nov–Dec 2025 → Finish SKU audit & lock suppliers
- Jan–Mar 2026 → Phase in new packaging on all new orders
- Apr–Jun 2026 → Sell through old inventory (legal in most states)
- July 2026 → 100% new packaging only
FAQ – Cannabis Packaging Compliance 2026
Q: Can I still use my current exit bags in 2026?
A: No — New York, Minnesota, and New Jersey require certified child-resistant exit bags starting Jan 1.
Q: Are ASTM-certified stickers enough?
A: Yes for flower/concentrate mylars if the bag itself passes re-close testing.
Q: How much will this actually cost my dispensary?
A: Most operators see 3–6% total packaging spend increase if they switch early. Wait until 2026 = 25–40% increase + recalls.
Don’t be the owner repackaging 40,000 units in a parking lot in January 2026.
Switch now, spend pennies extra per unit, and sleep easy knowing you’re 100% compliant when regulators walk in next year.
Disclaimer: Regulations evolve quickly. Always verify final rules with your state regulator and legal counsel.
✍️ By Daniel Sabet, Cannabis CFO & Financial Advisor at @GreenGrowthCPAs. Daniel advises cannabis operators nationwide on finance, compliance, and strategy.
