Tinctures made with alcohol are considered to be extracts/concentrates. ARM 42.39.601(60) includes these tinctures under the definition of “solvent-based marijuana concentrate and extract.” Tinctures made with alcohol must be tested as an extract/concentrate and categorized as such in Metrc. These tinctures must be labeled as a concentrate/extract not requiring heat, as required in ARM 42.39.318(1)(c)(ii). Alcohol-based tinctures cannot exceed 800 milligrams per package, per 16-12-224(8)(b)(iii), MCA.

Tinctures made without alcohol fall under the marijuana-infused product category, must be tested as such, and contain no more than 10mg THC per serving and 100mg THC per package. Tinctures made without alcohol must be labeled as a marijuana-infused product, as required in 42.39.316(1)(c). A 10% variance per serving and package for edible marijuana-infused products is allowed per 16-12-224(8)(c), MCA.

Possession limits and sale limits apply, based on ARM 42.39.118(2); these limits are no more than 8 grams or milliliters of alcohol-based tinctures and no more than 800 milligrams of a marijuana-infused tincture. The different requirements for testing marijuana and marijuana products can be found in the Quality Assurance Testing Requirements Appendix Version 1.0, link below: