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

October 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

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About Greenspoon Marder

Greenspoon Marder LLP is a full-service law firm with over 215 attorneys and more than 20 office locations across the United States. With operations from Miami to New York and from Denver to Los Angeles, our firm attracts some of the nation’s top talent in key markets and innovation hubs. Our core practice areas include Real Estate, Litigation, and Transactional Services, complemented by the capabilities of a full-service firm. Greenspoon Marder has maintained a spot on The American Lawyer’s Am Law 200 as one of the top law firms in the U.S. since 2015, and our goal is to provide exceptional client service by developing a thorough understanding of each client’s business needs and objectives in order to provide strategic, cost-effective solutions.

Cynthia Howard Chief Marketing Officer (720) 370-1182
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