California Cannabis Licensing Authorities To Readopt Emergency Regulations with Proposed Changes

California’s three cannabis licensing authorities, the Bureau of Cannabis Control, California Department of Public Health and California Department of Food and Agriculture, have proposed readopting their emergency regulations currently in effect for another 180 days.  Since the original regulations were released in November 2017, representatives from the three agencies have been soliciting feedback from stakeholders and the public.  As a result of that process, some changes are being made to the emergency regulations. 

“These proposed changes to our emergency regulations are based on feedback from our stakeholders, and information gathered over the first four months of implementation.”
–Bureau of Cannabis Control Chief Lori Ajax

In a series of upcoming blog posts, we will describe the changes made by each individual agency and analyze their impact on cultivators, retailers, manufacturers and other licensees.

But first, here are some highlights of the changes affecting all licensees, regardless of type:

  • License applicants can now submit just one application for both adult-use and medical cannabis licenses, and pay one licensing fee.  For applicants who want to operate in both markets, this is a much-desired change from the previous process, which required two applications and the payment of two separate licensing fees.


  • Any licensee can permanently conduct business with any other licensee, regardless of medical or adult-use designation.  The emergency regulations proposed a July 1, 2018 deadline for what was deemed a “transition period” that allowed medical cannabis licensees to contract with adult-use licensees.  That period has now been made permanent.

Once the California Office of Administrative posts the emergency regulations on its website, which it can do no earlier than May 25, 2018, the public will then have five days to comment on the re-adoption of the emergency regulations.   The revised emergency regulations can be found here.

If you have any questions about the regulations, please contact Justin Santarosa in our Los Angeles office.




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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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