Licensing Law & Compliance Attorney for California Cannabis Distributors, 2019 Important News, Attorney Information & Updates

California Cannabis Distributors

Frequently Asked Questions

Who can transport cannabis goods?

Only a distributor can transport cannabis goods.

Who can a cannabis Distributor Transport Only (Type 13) transport to?

A distributor can transport cannabis goods to the following parties:
  • licensed cultivators
  • licensed manufacturers
  • licensed distributors

Can a Distributor Transport Only (Type 13) licensee transport cannabis goods to a licensed retailer?

No, a Type 13 Distributor licensee cannot transport cannabis goods to a licensed retailer. However, they can transport for immature live plants and seeds from a licensed nursery.

Can a Distributor Transport Only (Type 13) licensee engage in any other distributor activities?

No, a licensee cannot engage in any other distributor activities.

What are the responsibilities of a cannabis Distributor (type 11)?

  • Transporting cannabis goods
  • arranging for laboratory testing of cannabis goods
  • conducting quality assurance review of cannabis goods
  • ensuring goods comply with all packaging and labeling requirements.
  • Storage of cannabis goods

What are the key requirements of Distributors?

  • CDTFA seller's permit
  • Alarm system must be on transport vehicles
  • If they are clearly identified, Medicinal and Adult-use cannabis goods can be transported together
  • Shipping manifest prior to transport must be created

What different types of Distributor Licenses are there?

Distributor (Type 11) and Distributor Transport Only (Type 13)

State Authority & Contact:

Bureau of Cannabis Control (CA Department of Consumer Affairs)
PO Box 419016, Rancho Cordova, CA 95741-9106
Phone: 1-833-768-5880

Scope of Licenses:

  • A-Type 11 (Adult-Use Recreational Distributor)
  • A-Type 13 (Adult-Use Recreational Distributor Transport Only)
  • M-Type 11 (Medicinal Non-Storefront Distributor)
  • M-Type 13 (Medicinal Distributor Transport Only)


  • Evidence of legal right to occupy and use the proposed premises location.
  • Premises Diagram Form
  • Business formation documents, including all documents filed with the CA Secretary of State (SOS). Foreign corporations must include a copy of the Certificate of Qualification from the SOS.
  • Evidence of premises compliance with local jurisdiction, if applicable.
  • Labor peace agreement or notarized statement indicating that you will enter into and abide by the terms of a labor peace agreement, if applicable.
  • Limited sovereign immunity waiver, if applicable.
  • Evidence of exemption from, or compliance with, the California Environmental Quality Act.
  • Proof of commercial general liability insurance in the aggregate of no less than $2 million and no less than $1 million for each loss.
  • Financial Information Form
  • Proof of surety bond in the amount of $5,000, payable to the State of California.
  • Transportation procedures
  • Inventory procedures
  • Quality control procedures
  • Security procedures
  • Evidence of compliance with the Compassionate Use Act of 1996 and its implementing laws before September 1, 2016, if applicable.

Licensing Fees:

  • $1,200: Revenue Up to $500,000
  • $5,000: Revenue between $2 million to $8 million
  • $36,000: Revenue between $8 million to $80 million
  • $125,000: Revenue greater than $8 million
Distributor Transport Only Self-Distribution
  • $500: Revenue Up to $2 million
  • $2,000: Revenue between $2 million to $8 million
Distributor Transport Only
  • $800: Revenue Up to $2 million
  • $2,500: Revenue between $2 million to $8 million



Bureau of Cannabis Control
Cannabis Advising Partners: for Cannabis Consulting

California Universal Symbol for Cannabis

California Universal Symbol for Cannabis

Download PNG file or Download JPG file

This site focuses or refers to information and services regarding medicinal and adult-use or both markets immature live plants and seeds being transported from a licensed nursery transport cannabis goods to retailer at least 20% ownership interest Labor peace agreement onsite sale and consumption of cannabis goods pre-made or purchased regulations for medicinal and adult-use cannabis three state cannabis-licensing authorities conditional license tinctures secondary packaging Owner ISO/IEC 17025 accreditation shipping manifest Fingerprints basic nutritional information some nutritional facts Ethanol Transport vehicles alarm system regulations for medical and adult-use cannabis in California temporary license Premises Information investment into a commercial cannabis business Business Information Bond in the amount of $5,000 limited to a maximum of 10 mg of THC per serving secured area security and cannabis waste disposal Licensees edible products amount of THC content public Licensee Lookup Tool destruction of cannabis goods at least 99% purity health impacts of cannabis quality control sanitary workplaces diagram of the business’s layout Transition Period storage of cannabis goods commercial cannabis manufacturing licensed physical location (premises) Form # CDPH-9041 commercial cannabis manufacturing activity Cannabis Manufacturing manufacturing Application Checklist stickers annual license application Homogeneity Testing of Edible Cannabis Products security Category II Residual Solvents and Processing Chemicals Testing cannabis plants cannabis sales and/or consumption track and trace system testing laboratories Licensee Information member manager Microbial Impurities Testing (A. fumigatus, A. flavus, A. niger, A. terreus) primary panel requirements Category II Residual Pesticides Testing property for the commercial cannabis activity medicinal and adult-use markets public health and safety licensing cannabis retailers state cannabis licensing A-license and an M-license extracts emergency regulations meat and seafood, and other products 2019 problems cannabis cartoons manufacturing cannabis products disclosure of all criminal convictions local jurisdiction authorization Local Issuing Authority California Public Records Act manufacturers who package for other producers cannabis products in container or wrapper for sale medicinal commercial cannabis activity labels not be attractive re-sealable CDPH-issued universal symbol Proposition 64: The Adult Use of Cannabis Act of 2016 Arranging for laboratory testing child-resistant outer package alcoholic beverages product guidelines transporting cannabis goods 2019 important information 2019 regulations retailers financial interest holder labeling hydrocarbon-based solvents certified by a California-licensed engineer manufacturing practices Category I Residual Solvents and Processing Chemicals Testing edibles packaging opaque 2019 fines small product packaging consumption of alcohol or tobacco manufacturer's name activity for a period of 120 days Medical Cannabis Regulation and Safety Act of 2015 Identifying information packaging and labeling Local Authorization capsules 2019 proposed changes 2019 new laws 2019 issues Local Authorization Attachment volatile solvent Department of Public Health’s Manufactured Cannabis Safety Branch identity of the product ANTICIPATED ANNUAL (NONTEMPORARY) LICENSE APPLICATION REQUIREMENTS list of artificial food colorings access to the area(s) MCSB’s temporary license application adult-use commercial cannabis activity Mechanical local jurisdiction’s requirements commercial cannabis manufacturers The Bureau of Cannabis Control (BCC) 2019 resolutions payable to the state of California convicted of a substantially related crime Individual Owner carbohydrates and fat per serving Cultivation less than 10,000 an officer or director of a cannabis business cannabis adult-use products Microbusiness inventory and quality control licensed cannabis cultivators cannabis industries compliance with regulations licensing cannabis distributors Moisture Content Testing equity interest in a commercial cannabis business child-resistant packaging unique ID/batch number tamper-evident Type S share facility space protocol loan provided to a commercial cannabis business product formulation final form Industrial Hemp Advisory Board Completed Temporary License Application Form licensing and regulating commercial cannabis manufacturers limited to a maximum of 1,000 mg per package finished product highly-concentrated oils or waxes sampling standards Premises Diagram licenses for both medicinal and adult-use cannabis manufacturing at the same premises 100 mg of THC per package product as a candy prohibited scaled to the gross annual revenue of the licensed premises Butane/Hexane/Propane Incorporating THC/CBD concentrates remove THC/CBD testing lab Extractions using CO2 health claims Proposition 65 paper inserted into the packaging ownership premises is not within a Government cultivation topicals CalCannabis Cultivation Licensing licensed cannabis distributors opaque exit package definition of owner Live Scans for each owner compliance with local jurisdiction motor carrier permit 2019 recent news Carbon Dioxide (CO2) Track and Trace 2,000 mg of THC per package for the medicinal-use market 120 days aggregate interest of 20% or more sales of cannabis goods Temporary event up to 4 days nonlaboratory quality control supply chains for medicinal and adult-use cannabis products licensed premises 2019 laws exception for testing laboratories medicinal and adult-use cannabis manufacturing cannabis market government warning statement label exit packaging microbusinesses Department of Consumer Affairs’ Bureau of Cannabis Control Medicinal and Adult-Use Cannabis Regulation and Safety Act Bond and Insurance Information premises diagram evidence of the legal right to occupy the premises commercial cannabis activity designated structure ingredient list CO2 and ethanol extractions hang tag or a peel-back label Criminal History cannabis event organizer license CDPH-9041 2019 updates Temporary License Application concentrate contaminants conducting quality assurance review Operating Procedures M-licensees chain of custody Foreign Material Testing contaminant free amount of sodium Proposed Section 40133 licensing scheme medicinal and adult use cannabis goods transported together comply with all packaging and labeling requirements waste management laws required limits Business Organizational extraction infusion Manufactured Cannabis Safety Branch Percentage of ownership informational panel regulatory framework amount of THC/CBD per serving and per package Manufactured Cannabis Licensing System (MCLS) cannabis waste must enter certain events Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA) workshops hosted by the Bureau of Cannabis Control tobacco products written procedures for inventory control 600-foot radius of a school packaging licensed cannabis manufacturers transportation and security local jurisdiction separate applications Food-grade Butter/Oil A-licensees transportation of cannabis goods valid waiver Heavy Metals Testing period of 120 days The California Department of Public Health's loop system 600 foot radius of a school license review process allergen information minimum standards for extraction processes manned motor vehicle Temporary Cannabis Event persons 21 years of age or older packaging and labeling requirements laboratory quality assurance Office of Environmental Health Hazard Assessment (OEHHA) testing of cannabis goods operating procedures Distributor Transport Only three cannabis licensing authorities onsite consumption of cannabis goods cannabis cultivation licensing CDTFA seller’s permit delivery vehicle $3,000 of cannabis goods Manufactured Cannabis Safety Branch (MCSB) California Department of Public Health (CDPH) mandated warning statements cannabis training Personnel Requirements M-license manufacture cannabis products packaging and labeling requirements for pre-rolls Vehicle Requirements 2019 revisions structure and formation documents transportation shaped like a human, animal, insect, or fruit MCSB CALIFORNIA BUREAU OF CANNABIS CONTROL commercial cannabis products Conducting quality assurance review of cannabis goods commercial cannabis manufacturing in California distributors Water Activity Testing of Solid or Semi-Solid Edibles licensing cannabis third-party testing laboratories Seller’s permit number cultivation (on an area less than 10,000 square feet) inhalable cannabis Business and Professions Code section 26050.1 no added caffeine Water/Food-grade Dry Ice evidence of rehabilitation managing member Non-Storefront Retailer (Type 9) Licensee Lookup Tool Retailer (Type 10) recordkeeping good manufacturing practices vape cartridges dried flower The Manufactured Cannabis Safety Branch (MCSB) Financial Interest shared-use manufacturing facilities persons with a financial interest in the cannabis business Distributor transport no infusion of nicotine operating premises supplemental label purchasing cannabis products on tribal lands commercial kitchens shares of stock that are less than 5% of the total shares in a publicly traded company procedures for inventory control periods of 90 days extensions Premises diagram surety bond sugar supply chain Financial information waste disposal MANUFACTURED CANNABIS SAFETY BRANCH Category I Residual Pesticides Testing A-license and an M-license for the same commercial cannabis activity Edibles– Products secondary package Temporary License Application Information Local Jurisdictions online licensing system highly-concentrated THC/CBD such as oil, wax and resin Poison Prevention Packaging Act of 1970 (PPPA) manufacturing (Level 1 manufacturing, Type 6) THC levels testing methods Retailer (nonstorefront) Microbial Impurities Testing (Escherichia coli and Salmonella spp.) LICENSE APPLICATION REQUIREMENTS medicinal and adult-use commercial cannabis activity 2019 compliance sanitary and hazard-free environment requiring refrigeration Physical address no infusion of alcohol Manufacturing (non-volatile) A-license local jurisdiction’s ordinances and regulations disposal Standard Operating Procedures (SOPs) the commercial medicinal and adult-use (recreational) potentially-hazardous foods Terpenoids Testing Mycotoxins Testing disposal and destruction methods BUREAU OF CANNABIS CONTROL inventory Department of Food and Agriculture’s CalCannabis Cultivation Licensing division California Department of Public Health Cannabinoids Testing manufacturing activities entry into the legal, regulated market licensing cannabis microbusinesses and more.

In addition, Medium Indoor Type P Packaging & Labeling Only Mixed-light Tier 1 Type 3B (Cultivation; Mixed-light; Medium) Type P – for packaging and labeling only Processing aid Watts per square foot Department Type 3A (Cultivation; Indoor; Medium) Processing Serving Immature plant Environmental pathogen Track-and-trace systems Actual yield Type 1B (Cultivation; Specialty mixed-light; Small) Labeling In-process material Allergen cross-contact Allergen Cannabis product Specialty Cottage Mixed-Light Tier 1 Microorganisms Adulterated Type 1A (Cultivation; Specialty indoor; Small) Dried flower Type N Infusions (optional packaging and labeling) Harvest Batch Specialty Cottage Outdoor Medium Mixed-Light Tier 2 Medium Outdoor Mixed-light Tier 2 Specialty Outdoor THC Type 11 (Distributor) infused pre-rolls cannabis concentrates Kief Pre-roll products similar to traditional food products prohibited Infusion Wet weight Type 14 (Cannabis Event Organizer) Quality Lot Canopy Adequate Licensee THC limit of 10 milligrams per serving and 100 milligrams per package Unique identifier Premises Nonvolatile solvent Specialty Mixed-Light Tier 2 Ingredient CBD from industrial hemp DPH-17-010E Mature plant Type 7 – for extraction using a volatile solvent (ex: butane, propane and hexane) Cultivation gross annual revenue for first year in operation under MAUCRSA Type 6 – for extraction using a mechanical method or non-volatile solvent (ex: CO2, ethanol, water, or food-grade dry ice, cooking oils or butter) Edible cannabis product track and trace system Specialty Indoor infused butters and oils as concentrates Type 12 (Microbusiness) Volatile solvent Qualified individual Informational panel Manufacture Type 5B (Cultivation; Mixed-light; Large) Type N – for infusions Specialty Cottage Indoor Type 7 (Manufacturer 2) Extraction: Volatile Solvents Outdoor cultivation Adult-use Market Verification Proposition 65 warning statement Type 13 (Distributor Transport Only) Quality control personnel Type 2A (Cultivation; Indoor; Small) Small Mixed-Light Tier 2 UID Component MCSB 90-day extension periods Small Outdoor Topical cannabis product package flower or pre-rolls Applicant Type 8 (Testing Laboratory) Universal symbol Indoor cultivation Distribution Specialty Cottage Mixed-Light Tier 2 Type 1C (Cultivation; Specialty cottage; Small) Commercial cannabis activity cakes, cookies, beverages and juices, tea and coffee, chocolates, gummies, gum, and mints Holding M-license Manufacturer licensee Track and trace system Raw material Processor Cultivation site Type 10 (Retailer) Type 4 (Cultivation; Nursery) Finished product Type 5A (Cultivation; Indoor; Large) Limited-access area Theoretical yield Package Type 6 (Manufacturer 1) Extraction: Non-volatile Solvents, Mechanical Methods Type 2 (Cultivation; Outdoor; Small) Small Mixed-Light Tier 1 Type S (coming soon, shared-use manufacturing facilities) Flowering Validation Pest Hazard Nursery Request for Live Scan Monitor adulteration list of cannabis manufacturers Type 5 (Cultivation; Outdoor; Large) Type 9 (Non-Storefront Retailer) Product Identity Pathogen alternate use of a manufacturing premises Commercial-grade, non-residential door lock Specialty Mixed-Light Tier 1 Extraction Small Indoor Nonmanufactured cannabis product Contact surface Mixed-light cultivation Medium Mixed-Light Tier 1 Type 2B (Cultivation; Mixed-light; Small) Net weight CBD Primary panel Type 1 (Cultivation; Specialty outdoor; Small) Sanitize Quality control operation Process Batch Personnel Type 3 (Cultivation; Outdoor; Medium) Preventive controls Quarantine Bureau and more.

Disclaimer: Informational and educational purposes. Self-help services (not legal advice). Site is not affiliated with any state agency. Note that site might not contain the most updated information. Your receipt of any information from this site does not create a relationship. Prior results do not guarantee or suggest a similar result in other matters. No promise is made with regard to services or content's reliability, availabilty, or ability to meet any needs. Information and services provided "AS IS."

All Rights Reserved