The California Department of Public Health, Office of Manufactured Cannabis Safety, released proposed regulations on April 28, 2017 that would create a new license type, the “Type P” license, for “entities that only package or repackage medical cannabis products or label or relabel the cannabis product container.” Entities that package and label their own products are not required to hold a Type P license.
§40118. Manufacturing License Classifications.
The following license types are available from the Department:
(a) “Type P,” for entities that only package or repackage medical cannabis products or label or relabel the cannabis product container. Entities that engage in packaging or labeling of their own product as part of the manufacturing process do not need to hold a separate Type P license. For purposes of section 19328 of the Business and Professions Code, a Type P license shall be subject to the same restrictions as a Type 6 license.
The ISOR for Section 40118 explains the reasoning behind the new “Type P” license.
“Manufacturing License Classifications. The Act establishes two license types for manufacturers – Type 6 for manufacturers using nonvolatile solvents and Type 7 for manufacturers using volatile solvents. (Bus. & Prof. Code §19300.7 subd. (k) and (l).) However, Business and Professions Code section 19302.1(f) allows the Department to create additional license types as needed. This section is necessary to make specific the Department’s licensing authority.
The above information is provided for informational purposes only and is not intended as legal advice. Please contact a lawyer for legal counsel.
If you would like legal assistance in advocating for changes to the proposed regulations, please get in touch with us. If you are interested in a legal consultation about the “Type P” license, the Medical Marijuana Regulation and Safety Act (MCRSA), or compliance with California’s cannabis laws, please contact the Law Offices of Omar Figueroa at (707) 829-0215 or at (415) 489-0420.