The Mistakes to Avoid When Making a Pre-Roll: a Q&A With Custom Cones USA

They call themselves the pre-roll experts. And Fredrik Rading and André Bayard certainly know their stuff. They could tell you the levels of chromium New York allows in its inhaled products (it’s 110 parts per million, if you were curious) and probably recite the inner parts of a cone filing machine from memory. A lot of the time, however, Fredrik and André find themselves telling pre-roll manufacturers where they may be making mistakes

“The mistakes that we see happening are: not doing due diligence before you purchase your raw materials to produce your product,” says Fredrik.

Fredrik is the co-founder of Custom Cones USA, a pre-roll and packaging provider to the cannabis industry. Primarily, the company sells products (rolling paper, filters, packaging machines) to clients. But recently, Fredrik and his colleagues have found themselves dispensing plenty of basic regulatory documents, too.

“We’ve noticed a lot of customers will purchase products from us, and then three, four weeks after they’ve already received the raw materials, they say, ‘Oh, actually, we need the MSDS [Material Safety Data Sheet], we need the product specification sheet, we need the CoA [certificate of analysis], etc.,” says Fredrik.

“It just shows like a lack of preparation beforehand,” he adds. “And, luckily, we have all those documents in place, and we’re able to quickly provide them. But we’ve seen other people put themselves into the position where they buy all this material, and then they go to the vendor and then they realize the vendor can’t supply the correct documentation in order for them to be able to legally launch the product, and then they go on to test it and it fails for something.”

Cutting corners with cones

Why are some pre-roll producers so unprepared for these checks and balances? Well, when new states markets go live and there’s suddenly a rush for customers, it seems some companies are keen to skip any steps they can.

“I think that customers and license holders are trying to find the easiest entry into the market,” says André Bayard, compliance manager and product specialist at Customer Cones USA. “And so if they can cut corners, they will.”

And this kind of regulation evasion is only becoming more common as more states and companies enter the industry, according to André.

“I’m seeing an increase,” he says. “Testing costs a lot of money. Adhering to the regulations takes a lot of time, so that can delay products getting into the market.”

“I just think that’s where, unfortunately, a lot of customers are going until they get hit with that fine.”

“But then, on the flip side,” André interjects, “I’m also seeing states easing up on regulations, because it is too hard of an entry.”

While perhaps well intentioned, this kind of regulatory loosening can irk the companies that have put the work in to be compliant (with the now defunct rules).

“The states… they don’t make it easy for the companies to stay on top of the regulations,” says Fredrik. “One example is when New York first legalized. They said the chromium limit was 2.0.”

“And the problem is – we spoke with our rolling paper mill about chromium levels in paper – that it’s very, very difficult to lower the amount of chromium in paper; the actual fiber that they purchase already has a certain level of chromium in it,” he explains.

“They [the rolling paper mill] were going to start researching and looking into how they could possibly even do this. And, then three months later, New York’s like, ‘Oh, actually, the chromium limit is now [110 ppm].’ And so all that work that happened for that rolling paper mill is essentially wasted.”

Preparation advice

Such last-minute changes aren’t easy to prepare for. But pre-roll manufacturers can still anticipate some minor state testing rule changes if they base their product compliance, not around their own state’s rules, but those of a stricter state, such as California. This is the strategy Fredrik and André have been recommending to their clients.

“We don’t limit what we are providing based off of the state,” says André. “We find the most strict state out there, or country out there, and closely follow those regulations, and hope that that blankets all of the states.”

“So as long as we are at least modelling Canada’s or California’s requirements, I think that satisfies most of the states here in the US and some of the other countries that are starting to legalize.”

Fredrik concurs. “We currently do our pesticide testing as a mix between what’s required for Canada and California,” he says.

“I think doing a mix of testing and looking at what other states are doing and just making sure that you’re always following the strictest regulations out of all the states that you’re in, regardless of where you’re doing the testing, just so that you can future-proof yourself for any potential new regulations that may come up in a certain state.”

Beyond this strictest-state mantra, the Custom Cones USA team also recommend the following practices to their clients, in order to avoid pre-roll contamination and testing failures:

• Produce one product at a time. Make sure only the materials needed for that product are in the production area.
• Make sure to thoroughly clean and disinfect all production equipment and tools used in production before switching to another product. This may include cannabis grinders, filling machines and trays, holding trays, measuring tools and calipers, and any other tools used in the production process.
• Make sure all batch numbers are recorded of the materials used, along with production dates and times of all products, to ensure traceability of all materials used in the production of the pre-roll.
• Also, it’s important to wear protective coverings on your hands and mouths to avoid contamination from germs humans can carry.
• It’s important to keep moisture sensitive products in proper storage containers or rooms. A product can build up mold if not stored properly.
• It’s also important to keep the various components of the product stored and secured properly and separate from other components. This will help with preventing contamination.
• Rolling paper and wraps may have byproducts in them to prevent drying, give it its color, and binding agents, which are normal byproducts in mostly all papers and wraps. However, if not sourced from an accredited and well-known milling source, then the paper and wraps can already be contaminated. Therefore, testing all components prior to production is important.
• It’s important to test all components of the product to make sure all components are not contaminated. This should be done prior to production.

That’s one extensive to-do list. But if a pre-roll company is serious about getting into – and staying in – the cannabis industry and protecting consumer health, then these are the kind of cautious steps it’s going to have to implement, say Fredrik and André.

And, if nothing else, a thoroughly-tested product might just be a more popular product, at least if the Custom Cones USA team are buying.

“We’re also consumers,” says André. “So when I go to a dispensary, I’m like, ‘Okay, what’s tested? What’s your top-quality product?’ I don’t want any stuff that’s on the bottom shelf, or is cheap, right? Because I’m already going to assume that’s just not good quality.”

“Knowing what they [certain cannabis companies] put into their pre rolls, I’m, like, ‘Oof. I can’t believe you guys are doing that or saying that. I would never buy your product.’”

*This article was updated on May 26, 2023, to change the word "calibres" to "calipers".