On September 27, 2021, a substantive amendment was approved by the Department of Cannabis Control (DCC) in an emergency rulemaking action. In addition to clarifying ambiguities in the preexisting regulations and other non-substantive changes, the amendments contain substantive changes that will significantly impact the licensing and operation of California’s cannabis businesses.
Earlier this summer, the California Department of Public Health, Bureau of Cannabis Control, and Department of Food and Agriculture (the three state agencies that were previously tasked with administering the California Medicinal and Adult Use Cannabis Regulation and Safety Act and corresponding regulations) consolidated into the Department of Cannabis Control (DCC).
The DCC’s amended rules and forms approved on September 27, 2021 are available here. Please contact Arent Fox's Cannabis group if you would like assistance navigating these changes.
Since the consolidation, industry practitioners have anticipated an update of the regulations that each agency had previously adopted to govern cannabis cultivators, manufacturers, distributors, retailers, microbusinesses, testing laboratories, cannabis event organizers, and temporary cannabis events. In addition, the DCC has updated corresponding application and notification forms. Because an emergency rulemaking procedure was used, the amended rules took effect immediately upon approval. Therefore, all cannabis industry practitioners would be well served to review the updated rules and forms as soon as possible.