The advertising and marketing code, which was made public Oct. 8, includes a set of guiding principles to ensure that Cresco markets and promotes its brands and products responsibly. The standards include guidance on commercial communications to help prevent underage appeal and ensure companies make appropriate claims about cannabis’s benefits. The code also offers best practices for consumer-facing promotional events and merchandising.
Here, Cresco COO Greg Butler and SVP of Brand Marketing Cory Rothschild share why the company developed and published these standards, as well as how they will ultimately benefit the industry as it continues to grow.
Melissa Schiller: Why did Cresco develop these standards? What was the company’s overall goal in releasing these to the industry?
Greg Butler: The reason why we wanted to publish this is, as we look to the end of this year and into next year, what we expect to see in the U.S. cannabis market is an increase in investment across all companies in building their brands. There are a couple key trends driving that. One is competition that continues to grow, so everyone is fighting to grow their brand with customers. The second is companies are strengthening their financial positions. They’re able to invest more in brands. And then the third is we’re also seeing more opportunities for cannabis brands to invest in marketing, so there are more ways they can spend money. With that, there are a lot of tailwinds that are driving toward more spend for brands in the space.
As we looked at it, as we’re competitive and we expect everyone to be competitive, we wanted to create some guidelines that set a series of best practices to ensure that we’re building brands the right way and that it’s always in service of what’s best for consumers.
Cory Rothschild: We obviously operate under different laws and regulations in every state that we compete in. Foundationally, we do believe that there are some standards that shouldn’t change or vary depending on where you’re talking about cannabis. Even in certain states that have more relaxed laws, there are certain things when it comes to conversations around promoting responsible consumption or avoiding underage-appealing imagery. Those don’t change, and we must commit to those as an industry, not even just as a company, if we’re going to build a category that not only reaches its potential, but does what is best for consumers along the way.
MS: What do Cresco’s Responsible Advertising and Marketing Standards entail? What are some key best practices that are outlined in these standards?
CR: If you look at our guidelines, in some ways, it’s just some things that shouldn’t even be up for debate, from [the fact that] you should never advertise to a minor to how [to] display pictures of people and images in your ads to the claims that you make, and then how do you run events to ensure we’re doing everything in our ability to operate in a way in which a young consumer wouldn’t see our marketing? So, the gambit of our code reaches everything from media through to experience.
MS: What was the overall process like for developing these standards?
CR: It started with developing our own internal standards and adhering to those in all the work that we do on an ongoing basis. Our company is founded on being professional and helping to normalize the industry, and what that [means] is holding ourselves to standards that are above what is being asked of us. So, we developed this set of norms to what we felt was appropriate and to what we believed was the right way to operate our business.
We did look to other codes and responsible use practices that exist in the broader CPG space, whether that’s in alcohol or pharmaceuticals, to look to how we could set our own industry standards above and beyond the regulations that are imposed on us currently to make sure that we are proactively building the right category.
MS: How will these standards help prevent underage consumption?
CR: I would hope that these standards are overwhelmingly a no-brainer for most people. We hope that people nod as they read them because they seem reasonable and responsible. So, to point to a few—one is that when we show individuals in our advertising, those people should be over the age of 21, and that should be made clear in the ways in which they’re shown. This is something that’s commonly practiced across other CPG categories where there are age restrictions around usage, and there’s no reason we shouldn’t be doing the same. There are examples within our industry where there are underage individuals being shown or at least seemingly underage individuals being shown in advertising that wouldn’t be appropriate.
The other piece is showing imagery that would be somehow juvenile, whether that’s a logo, an endorsement, [or] some sort of imagery or dress that connotates use or young culture. That’s not appropriate to connect to cannabis when you’re building and making advertising. That’s something that we believe is common sense, but it’s worth us committing to as a group because we know that this is a product that can have an appeal to underage individuals if frequently shown in advertising.
MS: How will these standards help Cresco and other cannabis advertisers make appropriate claims about cannabis’s benefits?
GB: One of the things that’s difficult in an industry like cannabis is you don’t have a lot of FCC guidelines or health and safety guidelines of what product claims you can or cannot make. There isn’t a lot of oversight for brands that are making claims. As you think of an industry that’s brand new with consumers, you don’t want to allow brands to make misleading statements that might cause confusion or even misuse of products. So, in a world where you’re not governed by bodies that ensure you’re using clinical trials, we want to encourage everyone to be responsible on how they make or allude to product claims associated with product.
MS: How do the standards help establish best practices for promotional events and merchandising?
CR: I think the part that is unclear at the local level is, how should companies interact with people who are under 21 with product? Of course, if you’re hosting an event in California that has a license to sell cannabis, that’s a 21-and-over event by definition and is obviously associated with ID checking and all kinds of age gating, but that’s not the case when you’re putting up a booth at a community fair or a booth at an arts festival. These are all things [where] anyone can have a booth or show up, and you have to make judgement calls around whether or not you’d like to participate in those events. Then, when individuals at the event want to approach your booth and have a conversation with your company, how do you make sure you’re having appropriate conversations with appropriate individuals?
A lot of the code is trying to fill in some of those gray spaces that we’ve run into as a company on a daily basis as we try to do different events in different states. These are meant to be a complement to existing regulation and law as opposed to either rewriting or stating the obvious.
MS: How will these standards be distributed, or how do you hope they will be adopted by the industry?
GB: Our hope by publishing them is that it’s somewhat of a call to action. We hope that everyone looks at their own business and maybe finetunes and creates their own [standards]. While we’re all building our brands, we all want to do it the right way, so we’ll make [our standards] publicly available on our website for anyone who wants to read [them], and our only real objective on this is that others read, understand and adapt to it or their own version.
CR: Just to build on that, we’ve gotten a great response from other businesses that are interested in partnering, and we’re just beginning to have some of those conversations. My hope is that this becomes bigger than just Cresco Labs, as Greg mentioned, and that it pushes us to work together as an industry to build what’s right for our category. We [want to] continue to open more and more opportunities with partners in the media space, vendors [and] agencies so that more people are able to participate in cannabis and we can have greater and better marketing overall.
Editor’s Note: This interview has been edited for style, length and clarity.