Licensing Law & Compliance Attorney for California Cannabis Premises, 2020 Important News, Attorney Information & Updates


California Cannabis Premises


Frequently Asked Questions

Can a parcel of land have more than one licensed premises on it?

Yes, multiple licensees can be on a parcel of land.

Is a premises diagram required with the license application?

Yes, a premises diagram is required.

How close can the premise be from a school?

Unless otherwise allowed by local jurisdiction, the premise cannot be located less than 600 feet from a school. A school includes k-12th grade, day care, and youth centers.

How many licensees may occupy a premise?

Only one may occupy a premise. However, there is an exception if the licensee holds both an M-License and A-License for the same commercial cannabis activity (ex. Distribution, sale, processing, etc.)

If a business has more than one premise, does each premise need to be licensed?

Yes, each premise is required to be licensed.

Does premises mean parcel of land or property lot?

No, it is not the same.

Does the landowner of the premise have to approve of the commercial cannabis activity?

Yes, the landowner of the premise must provide approval.


Resources:








California Universal Symbol for Cannabis


California Universal Symbol for Cannabis

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laboratories remove THC/CBD manned motor vehicle CALIFORNIA BUREAU OF CANNABIS CONTROL track and trace system Local Authorization licenses for both medicinal and adult-use cannabis manufacturing at the same premises cannabis cartoons licensing scheme local jurisdiction authorization Application Checklist Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA) alcoholic beverages M-licensees Financial Interest supplemental label labels not be attractive required limits capsules Incorporating THC/CBD concentrates Edibles– Products Licensees Mycotoxins Testing re-sealable persons 21 years of age or older California Department of Public Health (CDPH) MCSB’s temporary license application Medical Cannabis Regulation and Safety Act of 2015 Business Information Manufactured Cannabis Licensing System (MCLS) carbohydrates and fat per serving M-license transportation and security valid waiver A-license 2020 recent news mandated warning statements license review process MANUFACTURED 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regulating commercial cannabis manufacturers Cultivation less than 10,000 loan provided to a commercial cannabis business licensing cannabis third-party testing laboratories Microbial Impurities Testing (A. fumigatus, A. flavus, A. niger, A. terreus) retailers commercial cannabis manufacturing in California at least 20% ownership interest sales of cannabis goods secured area licensing cannabis microbusinesses Category I Residual Pesticides Testing property for the commercial cannabis activity exit packaging inventory and quality control ANTICIPATED ANNUAL (NONTEMPORARY) LICENSE APPLICATION REQUIREMENTS 2020 compliance manufacturing activities transporting cannabis goods transportation Manufactured Cannabis Safety Branch at least 99% purity definition of owner activity for a period of 120 days Non-Storefront Retailer (Type 9) secondary package limited to a maximum of 10 mg of THC per serving Transition Period Industrial Hemp Advisory Board separate applications cannabis industries highly-concentrated oils or waxes stickers list of artificial food colorings packaging and labeling licensed cannabis manufacturers California Public Records Act waste management laws Water Activity Testing of Solid or Semi-Solid Edibles secondary packaging Cannabis Manufacturing 2020 important information Labor peace agreement 2020 laws operating premises Category II Residual Solvents and Processing Chemicals Testing minimum standards for extraction processes Terpenoids Testing meat and seafood, and other products Type S share facility space Homogeneity Testing of Edible Cannabis Products The Manufactured Cannabis Safety Branch (MCSB) extracts Retailer (nonstorefront) ingredient list regulations for medical and adult-use cannabis in California Local Jurisdictions 120 days disposal Foreign Material Testing 2020 fines Arranging for laboratory testing Distributor Transport Only equity interest in a commercial cannabis business supply chain medicinal and adult-use or both markets 2020 new 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formation documents consumption of alcohol or tobacco testing laboratories member manager security and cannabis waste disposal written procedures for inventory control 2,000 mg of THC per package for the medicinal-use market California Department of Public Health 2020 resolutions identity of the product Retailer (Type 10) licensed cannabis cultivators Premises Information ownership premises is not within a Government Financial information The Bureau of Cannabis Control (BCC) investment into a commercial cannabis business destruction of cannabis goods shares of stock that are less than 5% of the total shares in a publicly traded company Local Authorization Attachment Criminal History comply with all packaging and labeling requirements Owner entry into the legal, regulated market Licensee Lookup Tool health claims volatile solvent local jurisdiction Business and Professions Code section 26050.1 purchasing cannabis products on tribal lands three state cannabis-licensing authorities 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In addition, Specialty Cottage Mixed-Light Tier 2 Environmental pathogen cakes, cookies, beverages and juices, tea and coffee, chocolates, gummies, gum, and mints Watts per square foot Processor Extraction cannabis concentrates Pest Pathogen Volatile solvent Primary panel alternate use of a manufacturing premises Department Indoor cultivation Specialty Indoor Type 11 (Distributor) Manufacturer licensee THC Type 5A (Cultivation; Indoor; Large) Mixed-light Tier 2 Edible cannabis product Adulterated track and trace system Specialty Cottage Outdoor Validation Bureau Mature plant Proposition 65 warning statement Type 9 (Non-Storefront Retailer) Quality control operation DPH-17-010E Net weight MCSB 90-day extension periods Lot Type 13 (Distributor Transport Only) Informational panel Commercial-grade, non-residential door lock Harvest Batch THC limit of 10 milligrams per serving and 100 milligrams per package Serving Type 1C (Cultivation; Specialty cottage; Small) Specialty Cottage Indoor Qualified individual Type 3B (Cultivation; Mixed-light; Medium) Unique identifier Universal symbol Quality Small Mixed-Light Tier 2 Nonmanufactured cannabis product Ingredient UID Adult-use Market Type 14 (Cannabis Event Organizer) Manufacture Type 2 (Cultivation; Outdoor; Small) Premises Flowering gross annual revenue for first year in operation under MAUCRSA Personnel Licensee Product Identity list of cannabis manufacturers Mixed-light cultivation Medium Mixed-Light Tier 1 Type S (coming soon, shared-use manufacturing facilities) Type P – for packaging and labeling only 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) CBD from industrial hemp Type 2B (Cultivation; Mixed-light; Small) Small Outdoor Topical cannabis product Nonvolatile solvent Processing aid Wet weight Cultivation site Type P Packaging & Labeling Only Outdoor cultivation products similar to traditional food products prohibited Type 10 (Retailer) Type 1 (Cultivation; Specialty outdoor; Small) Process Type 4 (Cultivation; Nursery) Type N Infusions (optional packaging and labeling) Cannabis product Type 3 (Cultivation; Outdoor; Medium) adulteration Type 5 (Cultivation; Outdoor; Large) package flower or pre-rolls Type 3A (Cultivation; Indoor; Medium) Type 2A (Cultivation; Indoor; Small) Medium Outdoor Type 7 (Manufacturer 2) Extraction: Volatile Solvents Nursery Quality control personnel Verification Commercial cannabis activity Limited-access area Infusion Actual yield Pre-roll Cultivation Preventive controls Specialty Mixed-Light Tier 1 Specialty Outdoor Canopy Batch Quarantine Sanitize Processing Contact surface Theoretical yield infused butters and oils as concentrates Medium Mixed-Light Tier 2 Medium Indoor Type 1B (Cultivation; Specialty mixed-light; Small) Package Type 6 (Manufacturer 1) Extraction: Non-volatile Solvents, Mechanical Methods Distribution Specialty Cottage Mixed-Light Tier 1 M-license Allergen Request for Live Scan Specialty Mixed-Light Tier 2 CBD Small Mixed-Light Tier 1 Type 7 – for extraction using a volatile solvent (ex: butane, propane and hexane) Track and trace system Type 8 (Testing Laboratory) Track-and-trace systems Kief Immature plant Microorganisms Type 12 (Microbusiness) Allergen cross-contact Finished product Monitor Raw material Adequate Type 5B (Cultivation; Mixed-light; Large) Holding In-process material Hazard Type N – for infusions infused pre-rolls Component Dried flower Applicant Type 1A (Cultivation; Specialty indoor; Small) Labeling Mixed-light Tier 1 Small Indoor and more.


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