Cultivation

LICENSING

Cannabis Advising Partners helps cultivators and growers with the detailed and time-consuming submission process for the Annual License Application for Cultivation. Besides detailed profile questions about your business and the owners, there are at least fifteen other components of the application, including California Tax and Fee Administration requirements, water quality protection provisions, hazardous materials requirements, California Environmental Quality Act (CEQA) involvement, Property Diagram requirements and many more.

Depending on the type of license (Type 1, 2, 3, 4, & 5), there are other specific requirements for the application process, as well as limitations concerning which license types and sizes can be held by the same entity and/or for the same premises. Cannabis Advising Partners can help you navigate these matters to enable you to stay focused on your number-one priority: your business.

SITE REQUIREMENTS

Cultivation Site requirements vary depending on the size of license (Specialty, Small or Medium) and the type (Indoor, Outdoor, or Mixed Light). There are also separate permits for Nurseries or Processors. Environmental protection measures, energy and generator requirements, pesticide usage, weights and measures, Track and Trace Program and sales invoice requirements are some examples of the many issues involved in the licensing process.

COMPLIANCE

The California Department of Food and Agriculture (CDFA) can conduct inspections, investigations and audits to review books, records, accounts, inventory or onsite operations.

The regulations do allow enforcement with minor, moderate and serious violation classes within the Administrative Action category, as well as Licensing Actions and Formal Administrative Hearings. Violations result in fines adjusted depending on the degree of violation.

Manufacturing

LICENSING

Manufacturers apply for an Annual Manufacturer License (Type 7, 6, N or P), which is issued by the California Department if Public Health. This license process is similar to that required by the California Bureau of Cannabis Control (BCC) and California Department of Food and Agriculture (CDFA) for their respective licenses within the cannabis industry.

Due to the nature of manufacturing, you will be asked to provide more information regarding your business activities and anticipated gross revenue. The application also will require a description of inventory control procedures, quality control procedures, transportation processes, security procedures, and waste disposal procedures. Lastly, a waiver of Sovereign Immunity is required.

To operate, manufacturers must secure a Commercial Cannabis License from the California Bureau of Cannabis Control (BCC). Cannabis Advisors oversees all of the license application requirements, including a detailed description of operating procedures in the areas of transportation, inventory, quality control and security.

A premises diagram and landowner approval are also required, and the BCC reserves the right to prohibit certain people from holding a license.

COMPLIANCE

Cannabis product manufacturing deals with areas of compliance, which includes disease control, cleanliness, personnel, proper storage, cleaning of equipment, sanitary operations, batch production, Track-and-Trace Program requirements, waste management, and facility construction and design.

Care must be taken in dealing with raw materials and ingredients. Manufacturing operations also include hazard analysis, preventive controls, inventory control, weights and measures, and machinery qualification.

As part of its operational plans, manufacturers must adequately train employees, handle product complaints, and manage recalls. Manufacturers must also address significant regulatory concerns in the areas of product standards, safety and security, labeling and packaging, Track-and-Trace and many others.

Distribution

LICENSING

Cannabis Advisors will handle the licensing(Type 11 and Type 13) and compliance for distributors transporting cannabis goods, arranging for laboratory testing, conducting quality assurance review of cannabis goods to ensure they comply with all packaging and labeling requirements, or storing cannabis goods.

Our knowledgeable cannabis consultants will guide your business through the ever-changing distribution licensing requirements. Let our team help you navigate through the strict regulations concerning storage, insurance, transportation and other areas of concern for Distributors.

COMPLIANCE

Key requirements for distributors include getting a CDTFA seller’s permit, vehicle and alarm requirements, clearly identifying medicinal and adult-use cannabis goods, and much more. Ongoing compliance needs will be extremely important for distributors, especially in the areas of vehicle transport and appropriate storage.

Retail

LICENSING

Cannabis retailers must adhere to all of the requirements for Commercial Cannabis Licensees that involve storage of inventory, record keeping, security, surveillance requirements, and compliance with the Track and Trace program.

Additional requirements that are specific to retailers include highly regulated areas such as retail location, hours of operation, goods display, selling of live plants, daily limits on sale, packaging, labeling, returns, inventory documentation and more.

Cannabis Advising Partners offers a full suite of services to help retailers comply with all regulations set forth by the Bureau of Cannabis Control, which oversees the licensing (Type 9 and Type 10) of retail cannabis businesses.

COMPLIANCE

Retailers must meet compliance requirements for their operations concerning hours of operation, packaging, and strict delivery regulations. Retailers cannot accept, possess, or sell cannabis goods if they are not packaged as they will be sold at final sale.

Micro-businesses

LICENSING

Micro-businesses are specialized permits(Type 12) that allow a business to engage in three out of the four major permit areas (cultivating, manufacturing, distributing, and retailing), but with some limitations. For example, under the micro-business permit, there is a limit of 10,000 square feet for cultivation.

COMPLIANCE

Additional ongoing compliance considerations for Microbusiness Licensees, depending on what areas you are engaged in (cultivation, manufacture, distribution, or retail) include storage of inventory, record keeping, security, employee badge and surveillance requirements, and compliance with the Track-and-Trace program.

Other Cannabis Activities

TESTING LABS

Testing laboratories require a specific license, and Cannabis Advisors can aid in acquisition of an initial Temporary, Provisional Laboratory License.

There are specific guidelines from the California Food and Drug Administration (CFDA) that must be followed. The primary considerations for testing laboratories involve their standard operating procedures for harvest batch sampling and product batch sampling, including field logs, rules about the number of increments per sample depending on batch size, Chain of Custody (COC) protocols, and distributor sampling.

In addition, testing laboratories must demonstrate their standard operating procedures for laboratory analysis, including test methods, validation criteria, and reporting.

We will assist in the wide range of tests that must be performed and reported, including microbial impurity, mycotoxin, heavy metals, cannabinoid, terpenoid and foreign matter testing, as well as both Category 1 and 2 testing for residual solvents, processing chemicals and pesticides.

In addition, we ensure that testing laboratories follow all regulations concerning employee qualifications for supervisors, management, analysts and samplers.

compliance requirements:

• ISO/IEC 17025 accreditation

• Must develop and implement a chain of custody protocol to document the transportation, handling, storage, and destruction of samples

• Must generate a certificate of analysis for each primary sample the lab analyzes

• Any cannabis or cannabis product sold to, or purchased by, a customer, must meet testing requirements

PROCESSORS

Specific requirements. Please call us for a free consultation.

NURSERIES

Specific requirements. Please call us for a free consultation.

Type 1-5

for cultivators

jurisdiction:CalCannabis Cultivation Licensing, CA Department of Food & Agriculture

A-Type 1

A-Type 1A

A-Type 1B

A-Type 1C

A-Type 2

A-Type 2A

A-Type 2B

A-Type 3

A-Type 3A

A-Type 3B

A-Type 4

A-Type 5

A-Type 5A

A-Type 5B

M-Type 1

M-Type 1A

M-Type 1B

M-Type 1C

M-Type 2

M-Type 2A

M-Type 2B

M-Type 3

M-Type 3A

M-Type 3B

M-Type 4

M-Type 5

M-Type 5A

M-Type 5B

6, 7, N, P, S

for manufacturers

jurisdiction: Manufactured Cannabis Safety Branch, CA Department of Public Health

A-Type 6

A-Type 7

A-Type N

A-Type P

M-Type 6

M-Type 7

M-Type N

M-Type P

Type 9-14

for other cannabis business actors

jurisdiction: Bureau of Cannabis Control, CA Department of Consumer Affairs

A-Type 9

A-Type 10

A-Type 11

A-Type 13

M-Type 9

M-Type 10

M-Type 11

M-Type 13

Type S

Type 8

Type 12

Type 14