September 16, 2025
As the U.S. landscape for THC beverage child-resistant packaging evolves in 2025, regulatory scrutiny is intensifying. With more states allowing hemp-derived THC drinks but enforcing age-21 sales, potency limits, and packaging rules, both cannabis business operators and compliance professionals face urgent questions. A single compliance misstep—a non-certified closure, or a misleading child-resistant (CR) claim—can trigger enforcement action at state and federal levels.
This article answers pivotal questions about child-resistant packaging for THC beverages: When (and why) are reclosable closures required? What pitfalls trip up even sophisticated brands? And what actionable steps must beverage manufacturers and retailers take now to navigate the patchwork of state and federal rules?
The Poison Prevention Packaging Act (PPPA) 16 CFR part 1700 empowers the U.S. Consumer Product Safety Commission (CPSC) to require child-resistant packaging for substances that may cause serious harm if ingested by children. A package is considered CR if it is “significantly difficult for children under five years of age to open or obtain a toxic or harmful amount of the substance” (CPSC guidance).
While the CPSC has not (as of 2025) directly enforced CRP for most cannabis or hemp products, states are increasingly importing PPPA and CPSC standards into state-level law or regulation for THC beverages—especially for multi-serving containers.
In 2025, THC-infused drinks are regulated by a dynamic patchwork of state rules. Most states with legal cannabis or legalized intoxicating hemp beverages impose some degree of child-resistant packaging, especially where beverages have more than one serving. For example:
Takeaway: If you are manufacturing or selling a THC beverage—whether cannabis- or hemp-derived—expect a default expectation of CR packaging. If your product is multi-serve and/or reclosable, regulators almost universally require compliant reclosable CR closures.
A child-resistant closure (CRC) is one that meets performance standards as defined by the CPSC: it must be extremely difficult for children under five to open, but accessible for most adults. For beverages, this generally means caps with push-and-turn, squeeze-and-turn, or similar mechanisms—simple twist-off tops or snap caps typically do not qualify.
Reclosability is a growing focus. Any beverage or edible “reasonably expected to be consumed in multiple sittings” must have a closure that maintains child resistance throughout its intended life of use. This is a stricter bar than for many single-serve edibles.
Even established brands make mistakes. The most frequent compliance failures seen in 2024–2025:
Request a test report and certificate for every closure from an accredited lab, showing the closure meets:
Verify that the closure supplier runs ongoing batch checks as part of their quality system, not just one-off certification.
Keep all certificates, lab reports, and supplier attestations on file and ready for audit by state or federal inspectors.
When referencing CR functionality on packaging, use only validated, non-promotional language. Avoid "child-proof" (which is disfavored by CPSC) and do not feature CR features as a marketing draw, which regulators may view as indirectly appealing to children.
Sample language (per FDA guidance for OTC drugs):
“This closure is certified as child-resistant under 16 CFR 1700.”
Key states setting strict benchmarks for CR closures on multi-serve or reclosable THC beverages include:
For beverage manufacturers, brand owners, and distributors, the following compliance checklist is essential:
Stay current: The intersection of hemp-derived THCs, intoxicating beverage innovation, and state-specific cannabis compliance is only getting more complex. Operators must build compliance by design—starting at the closure.
Ready for more updates, compliance checklists, and tailored state-by-state guidance? Visit CannabisRegulations.ai for the latest regulatory intelligence and workflow tools for your team.
