On June 27, 2017, Governor Brown signed SB-94, a budget trailer bill that makes significant changes to California’s commercial cannabis regulatory scheme. The new law, called the combines the medical and adult-use cannabis systems into one licensing structure with the same regulatory framework governing medical and adult use facilities. The […]
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On Thursday June 15, the California Senate and Assembly passed two bills, SB-94 and AB-110, which are the state legislature’s versions of Governor Brown’s Trailer Bill. The Trailer Bill is the administration’s effort to reconcile the medical and adult use cannabis systems in California. Now that these bills have passed, […]
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WARNING: New Proposition 65 Notice Requirements Coming Soon! May 24, 2017 OVERVIEW California’s Proposition 65, a voter initiative passed in 1986, created the Safe Drinking Water and Toxic Enforcement Act (Health & Safety Code § 25249.5 et seq.), which requires that the seller of a product that contains chemical(s) […]
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State Water Resources Control Board Releases Forms to Comply with CalCannabis Licensing If you are planning to obtain a California Department of Food and Agriculture Cannabis Cultivation (CalCannabis) License beginning on January 1, 2018, you must provide documentation of your water supply source with your cultivation license application. Certain water […]
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One way to challenge California’s proposed medical cannabis regulations is to argue that the record of rule making fails to establish the need for a particular regulation. California Government Code § 11349(a) defines necessity in the context of proposed regulations: “‘Necessity’ means the record of the rulemaking proceeding demonstrates by substantial […]
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The proposed medical cannabis regulations released by California’s medical cannabis regulatory agencies — the Bureau of Medical Cannabis Regulation (BMCR), the Department of Food and Agriculture (CDFA), and the Department of Public Health (CDPH) — would require licensees to submit a new application any time there is a change […]
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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 N” license, for “manufacturers that produce edible products or topical products using infusion processes, or other types of medical cannabis products other than extracts […]
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The California Department of Food and Agriculture, CalCannabis Cultivation Licensing, released proposed regulations on April 28, 2017 that would create a new license type, the “Processor” license, for “a cultivation site that conducts only trimming, drying, curing, grading or packaging of cannabis and nonmanufactured cannabis products.” While licensed processors may […]
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In 2015, the California legislature passed the Medical Cannabis Regulation and Safety Act (MCRSA), which set up a regulatory structure for medical cannabis within the state. In 2016, California voters approved Proposition 64, also known as the Adult Use of Marijuana Act (AUMA), which quasi-legalized cannabis for adult use. AUMA […]
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On Friday May 5, the Bureau of Medical Cannabis Regulation (a.k.a. the Bureau of Marijuana Control) released the proposed regulations for medical cannabis laboratory testing facilities in California, beginning a 45-day public comment period. “These proposed testing laboratories regulations for medical cannabis follow the same process as those regulations announced […]
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