The CCC’s Public Health and Safety Advisory is not a “Recall”
Jeff Rawson, Ph.D.
Institute of Cannabis Science

Last Thursday, the Cannabis Control Commission of Massachusetts (CCC) issued an advisory about cannabis products that may be contaminated with mold. The Advisory stems from the June 30th Summary Suspension Order that closed Assured Testing Lab (ATL) over allegations of fraud.
This advisory is not a recall. A recall is when a company recovers sold goods. The recalling firm notifies the distribution chain and the public about the affected stores and SKUs, contacts recipients of products, provides compensation or replacement. There are notices with pictures of the packages so that it’s easy for consumers. The CCC’s advisory provides inconsistent descriptions of products and brands, and consumers are left to search 7606 spreadsheet entries for their product’s 24-character code.
The CCC is long overdue in prioritizing Investigations and Enforcement, and much more is needed. We advised years ago about data-based enforcement and testing off-the-shelf that could ensure that regulations were bringing consumers safe, accurately-labeled cannabis. The CCC’s own Chief of Research warned, in statements to journalists and a conference abstract published in July of 2024, that several labs in Massachusetts displayed data signatures which indicated fraud similar to that at ATL. Yet today, we wonder whether any of these other labs will be investigated.
The CCC’s ‘Secret Shopper’ program has yet to be deployed systematically, due to a single mischosen regulatory phrase, and a discussion of it at the July 28th Public Meeting failed to get Commissioners onto the same page. This could impact the rollout of Social Consumption, as ‘Shoppers’ are needed to test the success of age restrictions at events, but it also means that CCC is still not regularly screening products off-the-shelf to learn whether any of these regulations work.
Consumer protection is driven by accountability. The Commonwealth’s consumers of cannabis demand that the responsibility of returning fraudulently-sold product be placed upon the sellers, not the buyers. Labs that test cannabis will provide accurate results when their own clients, the producers, require them. That will be so when producers have the risk of shelf-testing and responsibility of recalls, as is true for every other consumer good in the United States.
