#mcrsa

[whilomm]

at mcr san antonio. dilly dallys battery was running low. currently deciding if i want to pay $125 for a jacket.

[wraithcloud]

it's my birthday and gerard said happy birthday to someone in the crowd excuse me while i take that for myself

[cannabisbusinessexecutive]

California's Cannabis Distributor Rules Disrupt Model, Allow Licensees to Act As Their Own Distributors

California’s Cannabis Distributor Rules Disrupt Model, Allow Licensees to Act As Their Own Distributors

Under California’s now-repealed Medical Cannabis Regulation and Safety Act (“MCRSA”), would-be distributors would have had a field day (which became the subject of great debate industry wide). Under the MCRSA, California’s cannabis cultivators and manufacturers would have had to sell their products to licensed distributors who would then sell those products to licensed retailers.

MCRSA…

[thetiltedmystic]

Today's July 9th. Do you know what this means? It means tomorrow is 7/10 day! If you're still confused, pick up a copy of this week's 7/10 edition of OC Weekly! The issue comes with our Rolling Papers insert, providing you with the scoop on 7/10 day and highlighting some of the best oil companies in the game. I also wrote this week's cover story on the war that's raging between the unlicensed and licensed dispensaries in Santa Ana-- which obviously involves the City of Santa Ana and canna-industry monolith: Weedmaps. You won't be disappointed! Link to cover story in bio. If you want to check out the Rolling Papers, head to PotPlus.com 🖖🏽💚😚💨✨ . . . . @ocweekly @potplus #710 #710day #oilday #cannabisoil #kingharvest #jettyextracts #speakeasy710 #larefinery #santaana #dispensaries #prop64 #mcrsa #cannabisindustry #cannabiscommunity #cannabisreporter #lovewhatyoudo #coverstory #workhard (at OC Weekly)

[fortune420group]

California Passes SB 94 Regulating Medicinal and Adult Use Cannabis

#MustWeed http://www.fortune420.com/california-passes-sb-94-regulating-medicinal-and-adult-use-cannabis/

The California Legislature today passed Senate Bill 94, which effectively repeals the Medical Cannabis Regulation and Safety Act (“MCRSA”) and incorporates certain provisions of the MCRSA in the licensing provisions of the Control, Regulate, and Tax Adult Use of Marijuana Act (“AUMA” aka Proposition 64)[…] Read the rest: http://www.cannalawblog.com/breaking-news-california-passes-sb-94-regulating-medicinal-and-adult-use-cannabis

[centuryassociates]

Will California Be Ready For Adult Use Cannabis?

Our California cannabis lawyers are constantly asked how big sales and tax revenues will be in California once adult use cannabis becomes legal there. With recent reports of increased sales in Colorado and Nevada, everyone is expecting California – with its population of nearly 40 million people – to dwarf the sales of other adult use cannabis states. Many see California sales exceeding Colorado and Washington sales (together!) by at least ten times. To say our law firm is bullish on California would be an understatement; we literally cannot find good lawyers fast enough for our two California offices (Los Angeles and San Francisco).

When Californians voted for the Adult Use of Marijuana Act (a/k/a AUMA or Prop 64), you could smell the enthusiasm. Our California offices were deluged with a flood of investors looking to invest in California cannabis businesses. Then Governor Brown and the California legislature removed Prop 64’s in-state residency requirement with the enactment of the Medicinal and Adult-Use Cannabis Regulation and Safety Act (a/k/a MAUCRSA or SB 94) this past June. With residency requirements removed, my firm saw a significant increase in interest from clients outside California seeking to obtain cannabis business licenses in the Golden State.

Unfortunately, local legislators in California’s cities and counties have not kept pace with the enthusiasm on the business side. Prior to SB 94, the legal cannabis landscape consisted of California jurisdictions focused on their medical cannabis ordinances in step with the Medical Cannabis Regulation and Safety Act of 2015(MCRSA). The MCRSA was California’s first attempt at establishing a statewide regulatory and licensing regime. The MCRSA also allowed medical cannabis businesses to operate as for-profit businesses starting in 2018.

With most local jurisdictions playing catch-up with the MCRSA, it’s unlikely Californians will be able to purchase recreational cannabis on January 01, 2018. That’s because most California cities and counties are waiting on the state’s main cannabis regulatory agencies – the Bureau of Cannabis Control, the Department of Food and Agriculture, and the Department of Public Health – to publish their emergency regulations before they enact their own adult use cannabis ordinances. The emergency regulations should be released in mid to late November and the Bureau of Cannabis Control has stated that cannabis businesses will be able to apply for temporary permits online in December.

Though it might take a little longer than expected before adult use cannabis sales in California become commonplace, we are seeing local regulators moving in the right direction. In our Cannabis Countdown series, we keep our readers apprised of cannabis ordinance developments on the local level and the below is an updated snapshot of what’s going on across the state regarding adult-use commercial cannabis activities:

Los Angeles: On March 07, 2017, Los Angeles residents came out in full force and voted for Proposition M, a much-needed effort at clearing up Los Angeles’s previously confusing, complicated, and unfriendly position towards medical cannabis businesses. On June 8th of this year, the Los Angeles City Council released draft requirements for commercial cannabis activities – which we covered here. After the release of these draft requirements, there was a 60-day comment period and on September 22nd, the City Council revised the draft requirements – which we covered extensively here. On September 25th the City Council Rules Committee requested the Los Angeles City Attorney prepare and present a draft ordinance addressing the changes made in the revised draft regulations. Though Los Angeles will authorize seed to sale license types (indoor cultivation, non-volatile and volatile manufacturing, distribution, and retail) it’s unlikely it will have an adult use cannabis permitting process in place by the start of 2018.

San Francisco: The city of San Francisco (where I am located) proposed draft cannabis legislation on September 26th of this year. The proposed legislation requires creating an equity program, authorizes the issuance of temporary local licenses for medical cannabis businesses, and will have seed to sale license types (including the microbusiness license). It also allows for medical and adult use cannabis licenses, but adult use licenses won’t be issued until the equity program is in place. The ordinance does not cap the number of permits to be issued citywide, nor does it limit the number of licenses a person can hold – except that testing licensees cannot hold other cannabis licenses. However at a recent stakeholder meeting I attended, it was discussed that the Board of Supervisors (BOS) may revisit the issue of licensing caps (at the individual applicant and citywide level). It’s paramount that cannabis supporters stay politically active and fight complacency — don’t let what happened in San Luis Obispo happen in your city. San Francisco’s Office of Cannabis is to provide the BOS with an equity report, a medicinal access report, and a proposed fee schedule by November 1st of this year. Much like Los Angeles, San Francisco has proposed a cannabis-friendly ordinance that likely will not be ready for 2018.

Humboldt County: As part of the famed Emerald Triangle, Humboldt County is a cannabis business-friendly jurisdiction. On September 7th, Humboldt County’s Planning and Building Department released a draft cannabis ordinance that provides for the following:

Licenses all seed to sale commercial activities (including non-volatile and volatile manufacturing);

Allows farm-based retail sales, subject to receiving a retailer’s license from the state (we’ll have to see what the Bureau of Cannabis Control has to say about that);

Authorizes temporary special events for cannabis sales and consumption;

Allows on-site consumption for retailers and microbusinesses (for persons 21 years of age and older); and

Allows for cannabis tours and cannabis farm stays.

This proposed ordinance cements Humboldt’s reputation as a place that thinks outside the box when it comes to attracting cannabis businesses. Humboldt’s proposed ordinance was up for review and public comment on October 18 and we expect its enactment by early December. We are not sure whether Humboldt will allow current medical cannabis businesses to convert over to adult use and for-profit enterprises before January 01, 2018.

Though some of California’s biggest population centers will take their time before enacting adult use cannabis ordinances, we envision some of the more sparsely populated (and tax-starved) California jurisdictions will be the first to move into the adult use cannabis marketplace.

We will be sure to keep you posted on new developments in our Cannabis Countdown series.

Will California Be Ready For Adult Use Cannabis? posted first on http://ift.tt/2lnEzMp

[cannabisresins]

Known as the Medicinal and Adult Use Cannabis Regulation and Safety Act (MCRSA), the bill consolidates the two laws that regulated legal cannabis ... Read More...

[garudabluffs]

The AUMA contained a residency requirement that’s now been repealed by the MAUCRSA. The MCRSA never had a residency requirement, but this is still a significant development since it means out-of-staters and even foreign companies can set up shop in California for medical and recreational marijuana. However, don’t put it past some California cities and counties to implement their own “locals only” standards.

Cannabis News Roundup: JUNE 23,2017                                                        R

READ MORE http://kalw.org/post/cannabis-news-roundup-cannabis-cocktails-come-castro

Recreational and medicinal marijuana are now one in California New regs will allow dispensaries to pay taxes in their county, not in Sacramento Don’t count on legal pot in Nevada next week Cannabis cocktails at Castro café Neighbors object to “green rush invasion” Bank to MPP: Your money’s no good here Testing, Testing! Cal/OSHA: No special rules needed for medical pot industry Mexico moves toward legalizing medical marijuana Beware “stoner barf’ What happens when someone tries to sneak hundreds of pounds of pot onto an Air Force base Study: Marijuana use up at Oregon colleges since legalization Study: Insurance industry finds increase in vehicle accidents after legalization

[coloradoweedshops]

California Cannabiz – What’s the Deal with Vertical Integration?

The state of California recently consolidated the rules and regulations for both medical cannabis and recreational cannabis, officially merging the Medical Cannabis Regulation and Safety Act (MCRSA) and the Adult Use Marijuana Act (AUMA) to form the Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA).  MAUCRSA serves as the all-encompassing, official set of [...]

The post California Cannabiz – What’s the Deal with Vertical Integration? appeared first on The Weed Blog.

from http://ift.tt/2smGTDo

[marijuananewsonline]

Facts About the New Marijuana Laws in United States

Knowing the  marijuana laws  is imperative if you want to ensure you are not getting caught smoking pot in a restricted area or in an illegal way. Be reminded that there are states that allow medicinal marijuana, but prohibit recreational marijuana use. Nonetheless, there are more states in America that provide leeway to medicinal cannabis use to treat several diseases, particularly pain in patients.   The  marijuana laws  may vary from state to state. The regulations are specified for both individuals and businesses who are engaged in smoking pot or supplying cannabis. Given below are among the new and important regulations on marijuana use you may start studying about:    Residency Requirement in California.  The promulgated  marijuana laws  in California explained that there is no explicit standard in residency for the cannabis business yet. Nonetheless, this may be altered in the future amendments of the law. However, there is a part in Medical Cannabis Regulation and Safety Act in California (MCRSA), particularly in Proposition 64’s Section 26054.1(a). The regulation states that there is no organization granting license renewal or providing authorization to someone who cannot prove his or her residency in the state from or prior January 1, 2015.    Federal Level Illegality.  You should be aware that  marijuana laws  are still not finalized in the federal government. In other words, marijuana use is still illegal on a nationwide basis. You may only smoke pot in several states that allowed the use of the pot either medicinally or recreationally. One of the reasons why the federal government does not accept marijuana use as legal in the entire country is the difficulty of tracking the industry’s aspects. There is no legitimate banking body that is attached to the marijuana business yet.   Moreover, in case  marijuana laws  will reach the federal level, these will be under the power of U.S. Food and Drug Administration. There will also be considerations in edible safety, potency of cannabis, and storage of the plant.    Marijuana Possession in Boston.  Although the use of marijuana in Massachusetts is now legal, the issuance of license to retail cannabis stores is yet to be carried out. There is no other choice for users but to look for illegal dealers. Also, cannabis possession is illegal for people aged less than 21. Outside your residence, you may have an ounce of marijuana but not less than two ounces, provided you are 21 years or above in age.    Integration Issue. Marijuana laws  may be present in several states, including recreational use, but there is still a loophole in integrating cannabis to other industries. With tons of researches and studies revealing the potential of cannabis as the future of medicine, more manufacturers and companies are becoming interested with the industry. According to experts, marijuana may cover food production, agriculture, and retail industry, among others. Nonetheless, until now, there is no legal basis that can support setting up actual marijuana industry unified with typical markets.    Investments.  In California, investments in marijuana businesses by financiers are legal. In the case of the state getting more monetary support from Oregon, Nevada, and Illinois, there will be an overload of investments. Take note that these states have no residency requirements when it comes to cannabis use. It is anticipated for the law makers to clarify more on the financing area for both medical and recreational use of marijuana.    Consumption Rule.  Smoking pot in Massachusetts is still not legal in any public area, such as recreational places, sidewalks, parks, and streets. It is very easy to comply with since you only need to avoid smoking pot in places where the rule of “no cigarette smoking” is implemented.   Being aware of the  marijuana laws  is one of the means of ensuring that you will not be fined with any amount or be brought to the police for not following orders. Stay tuned for in the following months, revisions in regulations will definitely be submitted.                  MANTIS_RECOMMEND =          property: ‘5908c9b5908db4341145e6fe’,         render: ‘mantis__recommended__wordpress’     ;        var z = document.createElement(”script”);  z.type = “text/javascript”;  z.async = true;  z.src = “//assets.mantisadnetwork.com/recommend.min.js”;  var s = document.getElementsByTagName(’head’)[0];  s.parentNode.insertBefore(z, s);       The post  Facts About the New Marijuana Laws in United States  appeared first on  Marijuana News Online | The Cannabis Generation’s Digital Voice .

http://www.marijuananewsonline.com/regional/facts-new-marijuana-laws-united-states/

[whilomm]

i am excited to find out gerards outfit today. yesterday he was Da Jokar apparently. i liked the shorts. the blood was fun too. and the just rolled out of bed look. many pissabilities............ gerard fashion icon....

[focusvmconsulting-blog]

Cannabis & Due Diligence

Everyone is talking about the business of cannabis and how could they not? With many states moving to legalize the recreational favorite, the market is recognizing it’s vast earning potential. Just this morning I opened up one of my daily blogs to see the headline “Seth Rogen and Evan Goldberg are Launching a Cannabis Company” - it is all truly spectacular. New marijuana strains, dispensaries, suppliers, distributors, ancillary providers, delivery facilitating and dispensary locating start-ups (hello to my friends at Weedmaps) and investors are popping up almost daily. As the industry continues to expand, many questions are presented. The biggest question, how can we legitimize this once completely illegitimate product for mass commerce?

Each state that has legalized marijuana to any extent has its own regulations regarding its sale, and they are all quite complex. After reviewing California’s Proposition 64 and Proposition 215 one can see the truly complex myriad of regulations that apply to this emerging market. On January of 2018, the state passed the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA). The MAUCRSA established a “comprehensive system to control and regulate the cultivation, distribution, transport, storing, manufacturing, processing and sale” of marijuana in the state of California. The regulations imposed by MAUCRSA are strict and apply across the supply chain. Not only are the regulations strict, but they are imposed by three different authorities - The Bureau of Cannabis Control, The California Department of Food and Agriculture, and the California Department of Health each have their own regulations related to specific parts of the supply chain. All of these regulations have to be met with scrutiny and local interpretation, in order to obtain a license to participate in California’s growing marijuana market. With these rules effective, the business in California has taken on a slew of new issues to navigate.

The MAUCRSA has an adverse impact on those adhering to the previous legislation passed in 1996, Proposition 215, informally known as The Compassionate Use Act. The Compassionate Use Act made California the first state to legalize medicinal marijuana use for patients. It also created a culture that allowed patients to legally procure marijuana for medicinal use, allowing distributors to donate cannabis to those carrying a prescription. MAUCRSA, by contrast, follows cannabis products through the supply chain with a “track-and-trace-system”, requiring every step to pay a tax from cultivation to sale. This makes it nearly impossible for manufacturers to make “donations” as once dictated by the Compassionate Use Act. Dennis Perone, who authored Proposition 215, is quoted as saying this is “the government’s way of extorting people and turning the marijuana industry into a profit-based culture for big business". The fact is, regulation is a prerequisite for the legalization of any drug on a federal, state and local level. No matter how much free-market enthusiasts disagree, as the industry expands, so will the regulations.

Although MAUCRSA has introduced more regulations, it has surely opened the market up for cannabis. Before MAUCRSA, the use of marijuana was only legal for “patients” under the Medical Cannabis Regulation and Safety Act (MCRSA). Under MCRSA guidelines, patients could legally cultivate 100 square feet of marijuana and 500 square feet per five patient “collective”. This allowed unlicensed commercial collectives to spring up, becoming a favorite for customers. The unlicensed collectives will become illegal circa December of 2019 after a year was given to get their act together once The Bureau of Cannabis Control officially started issuing licenses. The idea of becoming licensed and facing cultivation guidelines from The Department of Food and Agriculture is off-putting for individuals and collectives. Lawmakers in California did their best to write strict rules regarding cultivation to keep legal marijuana clean and those rules will begin to be implemented in June of 2019. It behooves the licensed business to keep a steady eye on their supply chain if they wish to remain legitimate. Inherently, the industry will continually attract those who are willing to break the law (Federal Law be damned) and there will soon be a very thin line between those who are abiding by the law. “People who have been in this quasi-legitimate business, they’re comfortable being criminals, and that creates this untrustworthy element where you can’t keep anybody accountable for anything”, Meital Manzuri, a California Attorney who represents cannabis businesses, told Rolling Stone in an article about “clean pot” cultivation. Many growers still have not figured out how to produce a clean product that will meet regulation standards, nor do they care, choosing profit over quality.

It is imperative for manufacturers and distributors wishing to operate a legitimate business in the cannabis industry to perform enhanced due diligence all the way down their supply chain. Along with proper third party screenings, businesses will receive the information necessary to shield themselves from becoming a party to a list of regulatory violations. States like California are taking all the legislative steps necessary to make cannabis a clean product that benefits its market, the state, and most importantly the citizenry. Moving forward, each state will implement regulatory oversight and more severe punishments for violators as they deem necessary to ensure legalization does not come back to haunt them. With tax benefits and the safety of its communities being the main motivators for government, neglecting due diligence will be accompanied by legal and reputational jeopardy.

Works Cited

“California (FINALLY) Begins Crackdown on Gray Market Marijuana.” Canna Law Blog™, 12 Mar. 2018, www.cannalawblog.com/california-finally-begins-crackdown-on-gray-market-marijuana/.

California, State of. “Cannabis Regulations.” Cannabis, cannabis.ca.gov/cannabis-regulations/.

Carreon, Mary. “California's New Cannabis Laws Squeeze Out Compassionate Care Programs.” Forbes, Forbes Magazine, 24 Mar. 2018, www.forbes.com/sites/marycarreon/2018/01/29/californias-new-cannabis-laws-push-out-compassionate-care-programs/#6b86d05a25fd.

Lewis, Amanda Chicago, and Amanda Chicago Lewis. “Meet the Crusaders for Clean Pot.” Rolling Stone, 25 June 2018, www.rollingstone.com/culture/culture-news/inside-the-weird-and-wild-crusade-for-clean-pot-198873/.

“The Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA).” California NORML, www.canorml.org/MAUCRSA.html.

[cannabisbusinessexecutive]

What's the Deal with Vertical Integration in California?

What’s the Deal with Vertical Integration in California?

The state of California recently consolidated the rules and regulations for both medical cannabis and recreational cannabis, officially merging the Medical Cannabis Regulation and Safety Act (MCRSA) and the Adult Use Marijuana Act (AUMA) to form the Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA). MAUCRSA serves as the all-encompassing, official set of rules and regulations…

[growlegalweed-blog]

Legal Weed Resources

Check out... https://legalweed.gq/420/manzuri-law-blog-post-the-cannabis-advisory-committee-going-from-puppeteering-to-action/

Manzuri Law Blog Post: The Cannabis Advisory Committee: Going from Puppeteering to Action

BLOG POST

Authored By: An-Chi Tsou

An-Chi Tsou is the principal at Tsou Consulting, LLC, specializing in state and local regulatory and legislative compliance, guidance, and advocacy. Prior to opening her own firm, she was appointed as Senior Policy Advisor at the Bureau of Medical Cannabis Regulation, where she developed regulations and negotiated with stakeholders regarding the implementation of the Medical Cannabis Regulation and Safety Act (MCRSA). She was the lead staffer and drafter of the MCRSA at the California State Legislature in 2015. 

http://www.manzurilaw.com/an-chi-tsou

California’s Cannabis Advisory Committee (CAC) was scheduled to meet on March 27 for its first meeting of 2019. But now that the regulations are finalized, what’s left for the CAC to do?

Officially formed in October 2017 as a result of statutory mandate, the CAC is tasked with advising the three cannabis licensing authorities “on the development of standards and regulations” for the industry. There will likely be additional regulations that are published by the licensing authorities – for example, Manufactured Cannabis Safety Branch staff have publicly discussed working on enforcement regulations starting sometime this year – but any new regulations aside, there is still a great deal of work to be done with respect to standards in the industry.

As most people know, state law provides very generous authority to local jurisdictions regarding operational requirements and standards. However, neither the state nor the locals have really provided any best practices for the industry. The state has published one-pagers on issues like packaging and labeling requirements, but the industry is still waiting on formal guidance for important issues like white labeling, and greater movement on policies such as compassionate use and social equity. Perhaps the state has not done anything about issues like these because they lack the expertise in these areas. If that’s the case, this is where the CAC should come in. It is, after all, a group of experts who have the authority to bring in outside speakers to discuss best practices and can confer and formally advise the licensing authorities about these policies.

This begs the question of what topics the CAC should cover in their upcoming quarterly meetings. The committee has covered issues that are out of the state’s control like banking, but there is plenty of room for discussion on other controversial issues. In addition to more in-depth discussions on white labeling and compassionate use, it would be very useful to have further public discussions on even more complex regulatory topics such as social equity programs. Major cities, such as Los Angeles and Oakland have struggled for months on the design of their equity programs, resulting in significant delays to business licensing, and major frustration from hopeful business owners, community members, and city officials. As local jurisdictions slowly come online with their cannabis regulatory programs, they are becoming more interested in implementing their own version of a social equity program. These cities and counties can learn a lot from those who have gone through these headaches before, including city officials and staff, community members, and business owners.

The problem with this setup is that none of the three licensing authorities are legally required to follow the recommendations provided by the CAC. During the regulatory process, state staff often appeared reluctant to heed any advice from the committee or the public. As a result, it can sometimes be difficult to see the CAC as little more than a puppet show to keep the public happy.

There is still hope though for the CAC to spearhead change this year, and with it, good reason to continue pushing policy recommendations at its meetings. California’s cannabis industry is likely still years away from operating in a smooth regulatory environment. Many members of the Legislature are still chomping at the bit to influence cannabis policy, eager to champion the issue of helping the industry prosper. And with Governor Newsom a staunch supporter of the industry, it is unlikely that California will see a slowdown in the number of cannabis bills introduced in the next few legislative sessions. As a result, many legislators and their staff are actively looking for ways to amend the law to help the industry; and if state law changes, the state licensing authorities are required to implement it.

With the regulatory agencies preoccupied with keeping the nascent industry afloat in its first full year of annual licensing and full regulations, the CAC is one of only a few outlets for drawing the state’s attention to more nuanced yet still widely applicable operational issues. Plus, informing and influencing lawmakers through a conduit of their own creation can’t hurt. Stay tuned — or even better, get involved — to see where the CAC wields its power in 2019.     

[fortune420group]

California cannabis industry lauds governor’s ‘pro-business’ proposals

#MustWeed http://www.fortune420.com/california-cannabis-industry-lauds-governors-pro-business-proposals/

California marijuana businesses apparently have an ally in the governor’s mansion.

Many in the MJ industry are applauding a series of overhaul proposals issued Tuesday by Gov. Jerry Brown for his state’s regulatory system, which will begin overseeing the cannabis trade starting in January.

The proposed changes are expected to cut regulatory red tape and bolster MJ companies’ bottom lines[…] Read the rest: https://mjbizdaily.com/california-cannabis-industry-lauds-governors-pro-business-proposals/

[centuryassociates]

California Cannabis Processors: You Asked, We Continue To Answer!

Three of our California cannabis lawyers recently did a webinar on the Medicinal and Adult-Use Cannabis Regulation and Safety Act (“MAUCRSA”) and how it repealed the Medical Cannabis Regulation and Safety Act (“MCRSA”) while consolidating some of MCRSA’s provisions with the licensing provisions of the Adult Use of Marijuana Act (“AUMA”). If you missed the webinar don’t you worry, we’ve got you covered right here. During the webinar we received so many great questions from our attendees (close to 1,500 people signed up!), we decided to address them here on the Canna Law Blog. Last week we discussed the future and unknowns surrounding onsite consumption in California. This week we’re going to discuss California cannabis processors.

If you find yourself thinking you never read anything about about cannabis processors in the MAUCRSA, go ahead and give yourself a pat on the back because it does in fact nowhere mention processors, nor is there any mention of processors in the California assembly and senate bills that made up the MCRSA. Upon passage of the MCRSA, the California Department of Food and Agriculture (“CDFA”) held eight public workshops to solicit feedback from the public and interested stakeholders. After the workshops, the CDFA published a scoping report detailing some of their findings. When the CDFA released its proposed regulations for the medical cannabis cultivation program it also released a companion Initial Statement of Reasons (“ISOR”) and it is in the ISOR where we are first introduced to processors.

In the ISOR, the CDFA states “it was brought to the Department’s (that’s the CDFA) attention that some cultivators send untrimmed, uncured, or unpackaged cannabis to locations off-site for processing” and decided to add the processor as a new license type. Under the proposed regulations, a processor can also hold different types of cultivation licenses but would not be allowed to grow cannabis plants at the processing facility. The proposed annual license fee for processors was $2,790 – which was on the lower end for cultivation license type fees. The CDFA went on to define a processor in the proposed medical regulations as a cultivation site that conducts only trimming, drying, curing, grading or packaging of cannabis and non-manufactured cannabis products.

What caught many people’s attention is how CDFA classified pre-rolls as a type of non-manufactured cannabis product. Though consumer feedback on the quality of pre-rolls varies, there’s also a burgeoning marketplace for cannabis businesses that promote quality and brand themselves accordingly. The CDFA also envisioned an increased interest in processor licenses as they assumed approximately 20% of California’s cannabis production would be processed through California licensed cannabis processors. As you can imagine, our cannabis attorneys were getting a boatload of inquiries regarding this license type, but then California Governor Jerry Brown signed MAUCRSA into law and just like Keyser Söze, it was gone.

But is the processor license type gone for good here in California? Will those with cultivation licenses under MAUCRSA be allowed to conduct cannabis processing on their premises or will the CDFA bring back from the dead the processor as a separate license type in California? We’ll have to wait until the CDFA publishes its new proposed regulations in the fall under an emergency rule-making process so that the state will be able to issue cannabis licenses beginning on January 02, 2018. Since the processor license type was so short-lived, even if the CDFA does re-create it as a license type it will probably take some time for cities and counties to add processors to their licensing structure.

We’ll keep you posted on any new developments.

California Cannabis Processors: You Asked, We Continue To Answer! posted first on http://ift.tt/2lnEzMp