Greenspoon Marder Client Alert: Proposed Modifications to California’s Permanent State Regulations

Cannabis Blog Oct 22, 2018

On Friday, California’s State cannabis licensing agencies released the proposed modifications to the Permanent State Regulations.

These regulations are open for only a 15-day Public Comment period. All comments are due no later than November 5, 2018 at 5 PM. Click here for more information, proposed forms and regulations.

Now is the time to provide your input and voice your opinions and concerns to the State’s cannabis licensing agencies.

Key provisions include:

Heightened disclosure requirements for parties holding direct and indirect financial interests
Third-party delivery companies would be required to have state marijuana commercial licenses
A cannabis delivery vehicle would only be allowed to carry $5,000 worth of inventory, reduced from $10,000
Licensed cannabis events could be held outside of fairgrounds
Many packaging and labeling changes regarding THC and CBD content, as well as child-resistant packaging requirements
Modified testing requirements, meant to help lessen the amount of product failures and recalls
Agreements with legacy operators that did not have a state permit would be prohibited

If you are interested in commenting on any of the attached Regulations, than you may do so by submitting a comment in writing to:

Bureau of Cannabis Control – All General Licensing Requirements; as well as Distributors, Retailers, Delivery, Testing Laboratories, and Microbusinesses:
Submit written comments to:
Lori Ajax, Chief Bureau of Cannabis Control
2920 Kilgore Road
Rancho Cordova, CA 95670
E-mail: BCC.comments@dca.ca.gov

CDFA CalCannabis – Cultivation Licenses
Amanda Brown, Regulations Coordinator
California Department of Food and Agriculture
CalCannabis Cultivation Licensing Division
P.O. Box 942871
Sacramento, CA 94271
E-mail: CalCannabisRegs@cdfa.ca.gov

CDPH Manufactured Cannabis Safety Branch – Manufacturing Licenses
**Please include the title of the proposed regulations (DPH-17-010) with your comment.**
CDPH Office of Regulations
1415 L Street, Suite 500
Sacramento, CA 95814
Email: regulations@cdph.ca.gov

About Greenspoon Marder

Greenspoon Marder is a national full-service business law firm with over 200 attorneys and offices across the United States. We are ranked among American Lawyer’s Am Law 200, as one of the top law firms in the U.S. since 2015. Our firm was founded with the goal of providing the highest quality legal services at the highest value for our clients. Each of our clients is unique and so are their legal needs. We believe no one size fits all for professional services. Our lawyers offer flexible and creative solutions to meet our clients’ respective needs. Our mission is to understand the challenges our clients face, build collaborative relationships and craft solutions with a focus on strategic goals.

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