A group of recreational cannabis flower products purchased in October at Brilliant Buds in Bethel were fully compliant with state requirements.

The stickers for the “Find.” brand products displayed required warnings, strain names, potency values, processor license information and batch identifiers.

But when the recreational stickers were peeled back after being purchased on Oct. 24, medical cannabis labels were found underneath. The labels included Curaleaf’s Auburn facility address and medical-style batch data. Curaleaf is one of the largest multistate medical cannabis operators in the United States.

Was it a labeling error? Was the product for medical use instead of recreational? Was it simply a case of recycled packaging?

Those questions and more are at the core of labeling irregularities in Maine’s cannabis packaging, verification and retail compliance model: repurposed or mislabeled consumer packages can move through intake, stocking and point-of-sale without triggering an alert.

One recreational-use bag labeled “Turnpike Cookies” revealed a medical label beneath it printed with the strain “MAC 1.” A second bag of “Mintz Snackz” had the same label. In both cases, the originally labeled strain name was faintly visible through the sticker.

The discovery does not establish wrongdoing or intentional misconduct, but it does raise questions for consumers and regulators who may not necessarily be able to distinguish if a product on the shelf had an old label that was not properly removed or if the product was intended for one market but was being sold in the other without following all required rules.

In the case of the layered labels at Brilliant Buds, it was all legal. Maine’s recreational cannabis rules do not prohibit layered labels, and the final, visible sticker is treated as the compliance record at retail.

With labels from different regulatory programs remaining visible beneath a retail sticker, however, it has created confusion among consumers who want to know exactly where their cannabis is from and raised questions about packaging quality control.

Under Maine rules, the label itself is the mechanism by which retail compliance is communicated and enforced. The Office of Cannabis Policy allows multiple labels on a recreational package, provided required information is not obstructed.

Maine’s recreational cannabis program includes mandatory testing, track and trace, stringent labeling and universal symbols. The medical cannabis program does not require mandatory testing or track & trace.

Kaspar Heinrici, chief executive director of SeaWeed Co. in Portland, said the recreational cannabis market operates under a level of scrutiny that is often misunderstood by the public.

“There is still a misperception that cannabis operators are putting a plant into a bag with little oversight,” he said. “The reality is that regulated recreational operators are working with a level of organization, testing and standard operating procedures closer to the medical or financial services industries.”

Maine’s recreational system requires cannabis sold at retail to be identifiable for recall purposes through batch information printed on the label.

Heinrici said Maine’s batch-based approach is intended to balance public health protections with operational practicality.

“If there is an issue with one unit of a product, it likely extends to the rest of the package and potentially the package it came from,” he said. “Being overly specific at the individual unit level is not going to provide additional benefit.”

At the retail shelf, compliance and recall depend on the accuracy of the information printed on the visible retail label. Inspection quality can vary depending on staffing levels, lighting, workflow and training. Batch numbers are often printed in small type.

The rule does not require individual retail units, such as eighths, quarters, ounces or pre-rolls, to carry a unique electronic identifier, radio frequency identification tags or scannable code. But it does for cultivation and wholesale inventory movement.

Maine uses Metrc (short for Marijuana Enforcement Tracking Reporting Compliance) a track-and-trace inventory system adopted in many cannabis jurisdictions.

Other states use different track-and-trace platforms. For example, Connecticut uses BioTrack. In Connecticut, each retail cannabis unit carries a printed unit identification number with a machine-readable barcode, as well as a QR code with a link.

Curaleaf is headquartered in Stamford, Connecticut, and operates more than 150 operates medical and recreational dispensaries nationwide.

Maine consumers do not have a comparable consumer-facing verification tool.

Heinrici said that while testing and traceability are essential, additional regulatory layers do not always translate into better consumer outcomes.

“The track-and-trace and testing requirements are important for public health, but they verge on being overly detailed and overly burdensome for the end consumer,” he said. “More regulation always comes with a cost, and that cost ultimately shows up at the register.”

Curaleaf entered Maine in 2016 through its relationship with Remedy Compassion Center, one of the state’s original eight nonprofit medical cannabis dispensaries and the first to open under Maine’s medical program.

While Curaleaf exited recreational retail storefronts in Maine in 2023, citing competitive pressures, the company remained active in the state’s medical cannabis program as well as recreational cultivation and manufacturing.

It appears Curaleaf is dipping its toes back into recreational retail. In late November, job postings for Curaleaf-managed operations at Brilliant Buds in Bethel signaled a return through a licensed partner rather than a Curaleaf-branded store. Additional Curaleaf job listings in Bangor indicate a recreational retail component planned for that location.

Curaleaf did not respond to repeated requests for comment for this article. Attempts to seek comment from Brilliant Buds were also unsuccessful.

A reporter visited the Bethel store in person but was asked to leave upon entry. A follow-up phone call to the store and subsequent emails seeking comment were not answered.

Office of Cannabis Policy Data Analytics Director Eric Miller said recently that recreational sales are strongest in western and southern Maine, particularly in border-adjacent regions near New Hampshire, a factor that may help explain Curaleaf’s focus on Bethel.

John Hudak, the director of Maine’s Office of Cannabis Policy, said sales data suggest some border effects, but emphasized they are not the primary driver of Maine’s recreational market.

“I think New Hampshire is having an impact in York and Cumberland County, but it’s not the major driver of Maine’s cannabis economy,” Hudak said, adding that tourism and Maine consumers account for most recreational sales.

Maine regulates cannabis under three distinct frameworks: medical cannabis, recreational cannabis and hemp-derived products. Each system operates under different statutes, labeling rules, testing standards and tax structures.

Recreational cannabis is overseen by the Office of Cannabis Policy and is subject to labeling rules, mandatory third-party testing, Metrc oversight and a 10% excise tax. As of late 2025, Maine lists roughly 180 licensed recreational cannabis stores, along with 78 cultivation facilities and 81 manufacturing facilities statewide.

Maine’s medical cannabis program is also overseen, separately, by the Office of Cannabis Policy. Maine lists 86 active medical dispensaries and approximately 1,554 registered caregivers statewide. A medical cannabis caregiver is an individual or business authorized to grow and sell cannabis directly to registered patients, often operating at smaller scale and under less prescriptive labeling and testing rules.

“From a caregiver standpoint, testing and transparency matter because trust is everything,” said a Franklin County-area medical cannabis caregiver who requested anonymity. “Even unintentional confusion around labeling or testing can make patients question whether a product is safe.”

In July, cPort Credit Union notified many medical cannabis caregivers and caregiver storefronts statewide that their business accounts would be closed, citing evolving compliance expectations and regulatory risk. The decision did not apply to licensed medical dispensaries, which are subject to higher levels of oversight.

“Patients ask more questions now than they did a few years ago,” said the Franklin County caregiver. “Public perception around safety is shaped as much by labeling and communication as by the product itself.”

The labeling incident in Bethel illustrates a possible hole in Maine’s recreational oversight model. Cultivation and wholesale movement can be tracked with some accuracy, but at the retail shelf things can get much more dicey, relying on individual inspectors and label accuracy — rather than actual traceability.

At the point of sale, the sticker is the system. Against that backdrop, state regulators are continuing broader discussions about testing standards and consumer protection.

The Office of Cannabis Policy hosted a Cannabis Conversation on Testing Lab Standards on Dec. 22, hosted by director Hudak, which focused on how the state and the Maine Center for Disease Control and Prevention work together to ensure certified cannabis testing labs, examining laboratory procedures, oversight and public health standards. The video can be watched on Maine OCP’s YouTube page.