It’s been almost a year since the first provisional licenses were issued, and those licenses are beginning to expire. That means it’s time to get ready for license renewals. We’ve put together information to help you get ready, starting with a quick refresher on AB 97, followed by a to-do list.
Assembly Bill 97, signed into law on July 1, 2019, contained changes related to temporary and provisional licensing:
The industry is currently awaiting guidance about the transition process. State agencies have not yet disclosed the exact procedure to transition a provisional license to an annual license or renew a provisional license. We expect this to be forthcoming in the coming months.
We do know that the procedure to transition to an annual license or to renew a provisional license will not be the same as renewing an annual license.
When does your provisional license expire?
Your surety bond expires each year and must be renewed.
Has your business, ownership, and/or financial interest holder information changed since you submitted your annual application?
Have you looked at your premises or property diagram lately? Is it an accurate reflection of your current layout and operations?
Where are you with CEQA compliance?
(Cultivators only) Do you intend to change your Waste Management Plan?
(Cultivators only) Do you intend to change your Pest Management Plan?
(Cultivators only) Will you be using a different water source?
(Cultivators only) Are you enrolled in the North Coast or Central Valley Regional Orders?
(Cultivators only) Have you obtained a final Lake and Streambed Alteration Agreement or written verification that you don’t need one?
Do you know your renewal fee amount?
More information will be forthcoming in the coming months. Consider this a great opportunity to get your compliance ducks in a row and start off the new year with a solid pathway to license renewal.
California law says that cannabis and cannabis products must be sold in child-resistant packaging (CRP). The January 2019 final regulations included an option – available until the end of 2019 – to fulfill the CRP requirement with exit packaging. Starting on January 1, 2020, the CRP requirement cannot be satisfied at retail with exit packaging. Cannabis and cannabis goods (except plants and seeds) in finished form must be placed in child-resistant packaging at the cultivation or manufacturing premises before a licensed distributor picks them up.
This email is provided as informational only and does not constitute legal advice.
If you have any questions about compassionate use donations, please contact your attorney directly or call our main line at 877-257-2442.