Iowa: from grow to dispensary, what the label has to show

Step by step: Iowa

1. Step 1: Licensed manufacturer grows it (Manufacturer (grow)) Iowa licenses only two medical cannabidiol manufacturers, and each grows its own plants. A batch is dried flower of one strain, harvested at the same time with the same crop inputs. Plants, inputs, transport and sampling are all logged in the state’s secure sales and inventory tracking system, with some data entered in real time and inventory reconciled at least every two weeks.
2. Step 2: Only allowed forms, never smokable (Manufacturer) The same manufacturer turns the harvest into an approved form: oral (capsules, tablets, tinctures, sublingual), topical (gels, creams, lotions, patches), nebulizable or vaporizable inhaled forms, or suppositories. It may not make anything that can be smoked, and it may not make edible products, meaning food items that contain it. Each lot gets a unique lot number built from the manufacturer’s number and a sequence.
3. Step 3: Manufacturer samples, state may watch (Manufacturer) In Iowa the manufacturer pulls the sample, but only under written sampling protocols the department approved before any samples go to a lab. Samples must be representative, every sampling event is documented, and the department or its designees may observe. A reserve sample of at least twice the quantity needed for all tests is kept for one year from manufacture.
4. Step 4: State Hygienic Laboratory tests it (Approved laboratory) Testing goes to the State Hygienic Laboratory at the University of Iowa or another independent lab accredited to ISO/IEC 17025, registered with the DEA and the Iowa Board of Pharmacy, with no ownership in a manufacturer and approved by the department. HHS said in 2025 that all product testing runs through the State Hygienic Laboratory. The manufacturer pays.
5. Step 5: Pass or fail certificate (Approved laboratory) The lab tests cannabinoids, residual solvents and processing chemicals, pesticides, microbes and metals, with quantitation limits below the department’s action levels. It issues a certificate of analysis for each primary sample, stating pass or fail for the sample and the whole lot, signed by its quality officer, and makes it available to the manufacturer and the department. An unlisted contaminant means telling the department and holding the final certificate.
6. Step 6: Fail: remix, retest or destroy (Manufacturer) If the primary sample fails for residual solvents or pesticides, the whole lot fails. Each manufacturer keeps a written procedure for failing results that says when remixing and retesting are warranted, how to destroy product when they are not, and how to find the source of contamination. Otherwise the lot is rejected and destroyed. Pass or fail limits come from the department’s Laboratory Acceptance Criteria Document.
7. Step 7: Label goes on after the pass (Manufacturer) Only after a passing certificate for the lot, and before it ships to a dispensary, does the manufacturer label each package with the lot number, manufacture date and an expiration date one year out unless longer stability is approved. Packaging also shows THC, THCA, CBD and CBDA label claims, servings, directions, ingredients, warnings and the department’s universal warning symbol.
8. Step 8: Dispensary checks the 90-day cap (Dispensary) A licensed dispensary confirms the buyer holds a valid Iowa registration card; out-of-state cards do not count here. It may not provide more than 4.5 grams of total THC to a patient and caregiver in 90 days, unless a practitioner documents a terminal illness or certifies the limit is not enough. It adds a label with a sales tracking number and the patient registration number.