In California, two Assembly bills, AB 2532 and AB 2249, propose new product and packaging standards that directly affect how cannabis products are labeled and reach consumers. In New York, on June 2, 2026. lawmakers have passed A10698, the Cannabis Supply Chain Integrity and Anti-Inversion Act, targeting illicit cannabis in the licensed supply chain. These bills show how states are expanding their definition of consumer safety in cannabis, from what's in the product to how it's presented, to where it came from. Here's what operators need to know.

Key Takeaways

  • AB 2532 caps individual cannabis edible servings to 10 mg THC, and if a beverage contains multiple servings, the bill requires a device or instrument that allows the consumer to measure a single serving for consumption. It also requires all edible cannabis products and cannabis beverages to display the national Poison Help line on their labels. It is likely to take effect on July 1, 2027, to allow the selling off of existing products. 
  • AB 2249 prohibits cannabis products and packaging that are attractive to children, with an expanded, detailed definition therein, including more restrictions on cartoons, depictions of fruits, vegetables, the use of various fonts, and other items deemed attractive to children. It requires the Department of Cannabis Control to develop a standardized compliance rubric by July 1, 2027, and allows sales until January 1, 2028.
  • NY A10698 defines and penalizes cannabis inversion, the introduction of illicit cannabis into the licensed supply chain, with civil penalties up to $10,000 per day and a rebuttable presumption of license revocation for violations.
  • California's SB 54, separate from these bills, required operators to register with CalRecycle as a producer by June 1, 2026, and then transition to recyclable or compostable packaging by 2032. Operators should be planning for material changes now, especially if they have not already registered as a Producer.

California: AB 2532 — Beverage Potency Caps and Label Warnings

Assembly Bill 2532 proposes two changes to California's cannabis labeling and manufacturing requirements. The bill passed the Senate Committee on June 8th and was then referred to the Senate Appropriations Committee.

What AB 2532 Addresses

The bill would require all edible cannabis products and cannabis beverages to include the toll-free number for the national Poison Help line on their labels and inserts. Separately, it would cap the total THC content per serving in cannabis beverage containers at 10 mg — consistent with California's existing 10 mg per-serving limit for other edible cannabis products.

Why It Matters

Multi-serving cannabis beverage formats that exceed 10 mg total THC per container would “require a consumer to be offered, at the time of purchase and at no additional charge, a measuring instrument or measuring device that allows the consumer to measure a single serving for consumption.” The Poison Help line requirement is a labeling change that affects all edible and beverage SKUs, and operators should evaluate current label templates and lead times now rather than waiting for the bill to advance.

More broadly, AB 2532 continues California's pattern of bringing cannabis edibles into closer accordance with the safety infrastructure that governs food and drug products generally. The Poison Help line requirement, in particular, reflects an acknowledgment that cannabis ingestion incidents — especially accidental over-consumption — require a consumer response mechanism that is standardized and visible at the point of use.

What to Monitor Next

  • Committee movement and any amendments
  • DCC guidance on label formatting for the Poison Help line requirement
  • Implementation timeframes if the bill is passed

California: AB 2249 — Child-Attractive Packaging Prohibition

Assembly Bill 2249 proposes a wider prohibition on cannabis products and packaging attractive to children and establishes new compliance processes. 

What AB 2249 Addresses

The bill would prohibit the sale, distribution, or manufacture of cannabis products, packaging, or labeling that are attractive to children. The definitions are explicit: “a depiction, illustration, or rendering of a human, animal, object, or fictional character that includes exaggerated features, anthropomorphic characteristics, emotional expressions, attribution of unnatural or extra-human abilities, or attribution of animal, plant, or other object characteristics to humans, in a manner that is reasonably likely to appeal to children.” These are a significant expansion of existing restrictions that already prohibit designs "made to be attractive to children" but leave interpretation to the DCC.

To operationalize this, the bill requires the DCC to develop a standardized rubric by July 1, 2027, to determine whether a product or its packaging is attractive to children. The rubric must identify and describe prohibited design elements with specificity.

The bill also creates a voluntary pre-review process. Licensees would be able to submit proposed packaging to the DCC for a written determination of compliance before going to market, reducing uncertainty for operators investing in new product lines. The DCC may charge a reasonable fee for this service, and neither licensure nor the sale of a cannabis product may require a licensee to request one.

Why It Matters

These prohibitions are an important limitation for brands that have built a visual identity around them. Operators in the edibles and beverage categories, in particular, are advised to assess their current packaging assets against this standard, even though implementation timelines extend to 2027.

The voluntary determination process is a useful development for operators who want regulatory insight before committing to a product launch. For established brands, it may also create an opportunity to get ahead of enforcement by formally validating packaging that falls in gray areas.

What to Monitor Next

  • After passing the Senate Committee, it was re-referred to the Appropriations Committee. 
  • Amendments to the specifics of the definitions continue to be made
  • DCC rulemaking process for the standardized rubric
  • Whether the voluntary determination process is implemented before or after formal rulemaking is complete.

New York: A10698 — The Anti-Inversion Act

New York Assembly Bill A10698, the Cannabis Supply Chain Integrity and Anti-Inversion Act, targets one of the most direct threats to the regulated cannabis market: the introduction of illicit cannabis into the licensed supply chain, a practice the bill formally defines as "cannabis inversion." 

What A10698 Addresses

The bill amends the New York Cannabis Law to define cannabis inversion as any act or omission involving illicit cannabis, which includes untaxed product, cannabis sourced from unlicensed entities, and cannabis imported into New York state. Licensed operators, registrants, permittees, and laboratory testing facilities are all within scope.

Prohibited conduct includes: using fraudulent or materially unreliable certificates of analysis, falsifying or omitting required inventory or chain-of-custody records, possessing cannabis without documentation showing a complete chain of custody, and selling or transferring illicit cannabis to any licensee. Where electronic inventory records are missing or inadequate, the burden of proof falls on the licensee to demonstrate the product is not illicit through video, photographic, or other evidence.

Violations carry civil penalties of up to $10,000 per day, plus an additional penalty of up to five times the revenue from any prohibited illicit cannabis sale, or three times the projected revenue for illicit product found in possession. License revocation carries a rebuttable presumption for lab facilities that submit, use, or issue fraudulent certificates of analysis in furtherance of cannabis inversion.

Why It Matters

Illicit cannabis in the licensed supply chain harms licensed operators on two fronts: it undercuts compliant businesses on price, and it exposes consumers to products that have not been tested or taxed under the regulated framework. A10698 establishes an accountability mechanism for the supply chain, placing liability on licensees who handle, document, or certify untraceable products.

For distributors and retailers in New York, the chain-of-custody requirements in this bill are a compliance pressure point. Operators who rely on informal or incomplete record-keeping practices face meaningful exposure under this policy, particularly given the burden-shifting provision. The lab COA provision is also notable: it signals that New York intends to hold testing facilities directly accountable for the integrity of results used to move product through the regulated market.

What to Monitor Next

  • OCM rulemaking to implement enforcement procedures and chain-of-custody documentation standards
  • Lab partnership and vendor due diligence practices in light of the COA revocation provision
  • How regulators apply the burden-shifting provision for missing inventory records in early enforcement actions

California: SB 54 and the Packaging Obligation Operators Shouldn't Miss

Separate from the three bills above, California's SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, is now in effect with meaningful consequences for cannabis operators. The law requires that by 2032, all single-use plastic packaging sold in California be recyclable, compostable, or substantially reduced.

California approved the Circular Action Alliance as the state's first Producer Responsibility Organization. The framework covers cannabis packaging, which accounts for a significant volume of single-use plastic in the form of pouches, containers, and child-resistant packaging.

Operators should not treat 2032 as a distant deadline. Packaging design, supplier sourcing, and compliance documentation all take time, and the regulatory conditions around what qualifies as recyclable or compostable continue to evolve. Anyone qualifying as a “Producer” under CalRecycle's definitions was required to apply by June 1st, 2026, to begin complying with the ongoing requirements. 

Wider Industry Implications

These developments reinforce a shift that has been building across regulated cannabis markets: consumer safety is not assessed solely by what is in the product. It encompasses how the product is perceived by young people, its traceability, and, increasingly, what happens to the packaging after purchase.

For operators, the practical takeaway is the same as it has always been — politics is business. AB 2532, AB 2249, A10698, and SB 54 each have direct operational consequences for packaging design, supply chain documentation, lab relationships, and product strategy. Legislative engagement and internal compliance review are not passive activities. They are part of running a licensed cannabis operation in 2026.

Monitor these bills, audit your packaging against AB 2249's emerging standards, review your chain-of-custody documentation for New York operations, and start the conversation with your packaging suppliers about SB 54 compliance.

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