Business Licensing Law & Compliance Attorney for California Cannabis Regulations, 2020 Relevant News, Events, Information & Updates

California Cannabis Regulations

State Authority & Contact:

Bureau of Cannabis Control (CA Department of Consumer Affairs)
PO Box 419016, Rancho Cordova, CA 95741-9106
Phone: 1-833-768-5880

Manufactured Cannabis Safety Branch (CA Department of Public Health)
PO Box 997377, MS 7606, Sacramento CA 95899-7377
Phone: 855-421-7887

CalCannabis Cultivation Licensing (CA Department of Food & Agriculture)
Phone: 1-833-CALGROW (1-833-225-4769)

Scope of Licenses:

Medicinal (M-) and Adult-Use Recreational (A-):
  • Type 1 (Cultivation; Specialty outdoor; Small)
  • Type 1A (Cultivation; Specialty indoor; Small)
  • Type 1B (Cultivation; Specialty mixed-light; Small)
  • Type 1C (Cultivation; Specialty cottage; Small)
  • Type 2 (Cultivation; Outdoor; Small)
  • Type 2A (Cultivation; Indoor; Small)
  • Type 2B (Cultivation; Mixed-light; Small)
  • Type 3 (Cultivation; Outdoor; Medium)
  • Type 3A (Cultivation; Indoor; Medium)
  • Type 3B (Cultivation; Mixed-light; Medium)
  • Type 4 (Cultivation; Nursery)
  • Type 5 (Cultivation; Outdoor; Large)
  • Type 5A (Cultivation; Indoor; Large)
  • Type 5B (Cultivation; Mixed-light; Large)
  • Type 6 (Manufacturer 1) Extraction: Non-volatile Solvents, Mechanical Methods
  • Type 7 (Manufacturer 2) Extraction: Volatile Solvents
  • Type N Infusions (optional packaging and labeling)
  • Type P Packaging & Labeling Only
  • Type S (coming soon, shared-use manufacturing facilities)
  • Type 8 (Testing Laboratory)
  • Type 9 (Non-Storefront Retailer)
  • Type 10 (Retailer)
  • Type 11 (Distributor)
  • Type 12 (Microbusiness)
  • Type 13 (Distributor Transport Only)
  • Type 14 (Cannabis Event Organizer)

California Cannabis Regulation References:


Frequently Asked Questions

What is the process for creating the state cannabis cultivation regulations?

The California Administrative Procedure Act establishes the rulemaking procedures and standards for California’s state agencies. The act’s requirements are designed to provide the public with a meaningful opportunity to participate in the adoption of state regulations and help ensure the regulations are clear, necessary, and legally valid. The majority of adopted regulations that conform to the Administrative Procedure Act are submitted to the Office of Administrative Law as a “regular rulemaking.” Unless a proposed rulemaking action is submitted to the Office of Administrative Law as an “emergency rulemaking,” or is exempt from the Administrative Procedure Act, the regular rulemaking process must be followed when a state agency undergoes a rulemaking action.

What is the emergency rulemaking process?

Before California Governor Jerry Brown approved the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA) in June 2017, the California Department of Food and Agriculture (CDFA) had followed the regular rulemaking process and submitted proposed regulations for the Medical Cannabis Regulation and Safety Act to the Office of Administrative Law. However, once MAUCRSA became law, CDFA had to withdraw those regulations; instead, a new set of regulations consistent with changes in the new law was proposed in November 2017. CDFA followed the emergency rulemaking process for these regulations. This will be followed immediately by the regular rulemaking process to make the regulations permanent. To initiate the emergency rulemaking process, the state agency files emergency regulations with the Office of Administrative Law (OAL) at least 10 calendar days before the effective date. During the first five days of OAL’s review period, the public may submit comments to OAL, with a copy for the state agency. The state agency has until the eighth day of OAL’s 10-day review period to submit to OAL a rebuttal to any public comments; however, this step is optional. The OAL’s deadline for a decision is on the tenth day after the emergency regulations were filed, and, if approved, the emergency regulations are filed with the Secretary of State and will become effective immediately for 180 days. (MAUCRSA allows for one 180-day re-adoption if the agency is making progress toward adopting the permanent regulations.) For an illustrated step-by-step guide to this process, see the flowcharts on pages 5 and 7 for regular rulemaking and emergency rulemaking.

What is the California Department of Food and Agriculture’s regulatory authority for licensing cannabis cultivators and implementing a track-and-trace system?

When a state legislature passes—and the governor approves—a law (also known as a statute), this enacts a new program or changes the laws governing an existing program. After the law’s passage, one or more state agencies must adopt new regulations, amend existing regulations, and/or repeal existing regulations to ensure the program runs effectively. When the California State Legislature passed the Medical Cannabis Regulation and Safety Act in 2015, and California voters passed the Adult Use of Marijuana Act (Proposition 64) in 2016, both acts designated responsibilities for oversight of commercial cannabis to several state agencies. The California Department of Food and Agriculture (CDFA) was granted the authority to (a) establish a cannabis cultivation licensing process for the state, and (b) develop a track-and-trace system to record the movement of cannabis and cannabis products through the state’s supply chain. As a result, CDFA created a new division called CalCannabis Cultivation Licensing, which is tasked with overseeing these projects. On June 27, 2017, California Governor Jerry Brown signed the cannabis trailer bill (also known as California Senate Bill 94). A trailer bill is legislation that implements specific changes to the law to enact the state budget. Generally a separate trailer bill is needed for each major area of budget appropriation, such as transportation, human services, education, revenue, or, in this case, cannabis. These bills typically are negotiated as part of the entire budget package each fiscal year. In this instance, the cannabis trailer bill effectively merged the two existing cannabis bills—the Medical Cannabis Regulation and Safety Act and the Adult Use of Marijuana Act—into one streamlined bill: the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA). Having one comprehensive state law will provide for a more unified and efficient regulatory process governing both medicinal and adult-use (recreational) cannabis. For a link to the most recent version of MAUCRSA, please visit the CalCannabis website at

What is the regular rulemaking process?

The state agency must prepare the following documents and submit them to the Office of Administrative Law to initiate the regular rulemaking process: Economic Impact Assessment (for nonmajor regulations with less than $50 million in economic impacts) or Standardized Regulatory Impact Assessment (also known as a SRIA, pronounced sir-RHEE-uh, for major regulations with more than $50 million in economic impacts) – A SRIA is required with the California Department of Food and Agriculture’s (CDFA) regulatory package because the cannabis cultivation regulations are considered a major regulation. It includes information on how the regulations will impact businesses and jobs and the potential impacts on competition and investment in California. The SRIA is posted on the California Department of Finance website at Economic and Fiscal Impact Statement (Form STD.399) – This is a California Department of Finance form that includes information on the estimated economic and fiscal monetary impacts of the proposed regulations. Notice of Proposed Action – This notice provides critical information about the regulations, including a summary of existing laws that pertain to cannabis, the specific statutory authority that requires CDFA to create regulations, and details about the process for receiving the public’s comments. Initial Statement of Reasons (ISR) – The Initial Statement of Reasons provides the rationale behind CDFA’s decisions for including each section of the regulations and describes the purpose, need, and benefits of the regulations. It also identifies the supporting materials used to make regulatory decisions. Proposed Text of Regulations (Express Terms) – This text identifies any proposed changes to the California Code of Regulations. The state agency must publish the Notice of Proposed Action in the California Regulatory Notice Register and mail a copy to those who have requested it. The agency also must post on its website the Notice of Proposed Action, Initial Statement of Reasons, and the Proposed Text of Regulations. Once a Notice of Proposed Action has been issued by the state agency and published by the Office of Administrative Law, a regular rulemaking record will officially be opened and the minimum 45-day public comment period commences. The state agency may hold a public hearing; if the agency does not schedule a public hearing, anyone interested in having one may submit a written request for a hearing at least 15 days prior to the close of the written comment period, and that request must be granted. The state agency then receives and reviews the comments received during the official public comment period—and must summarize and respond to all of the comments. Some comments might ask for clarification of the proposed regulations, other comments might propose regulatory changes. If the state agency makes changes to the regulations, the changes are categorized as follows: Nonsubstantial Changes—Or No Changes Nonsubstantial changes do not alter the regulatory effect of the proposed provisions, and therefore the rulemaking process continues. The state agency updates the Informative Digest and prepares a Final Statement of Reasons (with a summary and a response to the public comments) and a Final Text of Regulations. Substantial and Sufficiently Related Changes These are changes considered reasonably foreseeable based on the Notice of Proposed Action and must be made available for public comment for at least 15 days. The state agency mails a notice of opportunity for commenting on the proposed changes (along with a copy of the proposed changes) to each person who has submitted written comments about the proposal, testified at an official public hearing (and provided contact information), or asked to receive any notices of modification. The agency also must post this notice on its website. When no further substantial changes are made to the proposed regulations, the agency updates the Informative Digest and prepares the Final Statement of Reasons (with a summary and a response to the public comments) and the Final Text of Regulations. Substantial Changes Not Sufficiently Related—Or Major Changes These are changes to the original proposal that are not reasonably foreseeable based on the Notice of Proposed Action. The state agency is obligated to publish another Notice of Proposed Action in the California Regulatory Notice Register, and hold another 45-day or longer public comment period. When no further substantial changes are made to the proposed regulations, the agency updates the Informative Digest and prepares the Final Statement of Reasons (with a summary and a response to the public comments) and the Final Text of Regulations. The state agency must transmit a rulemaking action to the Office of Administrative Law for review within one year from the date the notice was published in the California Regulatory Notice Register. Once submitted, the Office of Administrative Law has 30 working days to conduct a review of the rulemaking record. Generally, regulations go into effect on one of four quarterly dates, which are based on the dates the final regulations are filed with California’s Secretary of State: January 1, April 1, July 1, and October 1. However, an effective date may vary if a specific effective date is stated in statute or other law, the adopting agency requests a later effective date, or the agency demonstrates good cause for an earlier effective date. For an illustrated step-by-step guide to this process, see the flowcharts on pages 5 and 7 for regular rulemaking and emergency rulemaking.

Where can I read more about California’s cannabis licensing process?

For information about state licenses for cannabis farmers, please visit the CalCannabis Cultivation Licensing website at For details on other types of cannabis licensing in California, including manufacturing (such as edibles), testing, distribution, and retail, go to the California Cannabis Portal at

California Universal Symbol for Cannabis

California Universal Symbol for Cannabis

Download PNG file or Download JPG file

This site focuses or refers to information and services regarding licensed cannabis cultivators potentially-hazardous foods tinctures The California Department of Public Health's disposal mandated warning statements no added caffeine California Department of Public Health (CDPH) Category II Residual Pesticides Testing transportation public health and safety at least 20% ownership interest Retailer (Type 10) workshops hosted by the Bureau of Cannabis Control health claims Business Organizational secured area contaminant free Department of Food and Agriculture’s CalCannabis Cultivation Licensing division Physical address 2020 new laws manned motor vehicle Business and Professions Code section 26050.1 hydrocarbon-based solvents state cannabis licensing medicinal and adult-use markets Conducting quality assurance review of cannabis goods cannabis products in container or wrapper for sale inventory 2020 resolutions transportation and security manufacturing cannabis products Premises Information ownership premises is not within a Government Premises Diagram amount of sodium investment into a commercial cannabis business entry into the legal, regulated market separate applications activity for a period of 120 days highly-concentrated THC/CBD such as oil, wax and resin Local Authorization sales of cannabis goods manufacturing CO2 and ethanol extractions Carbon Dioxide (CO2) Local Authorization Attachment 100 mg of THC per package opaque exit package California Public Records Act inventory and quality control 2020 proposed changes three cannabis licensing authorities edible products public Licensee Lookup Tool licensing cannabis distributors 2020 fines Proposition 64: The Adult Use of Cannabis Act of 2016 medicinal commercial cannabis activity commercial cannabis activity identity of the product CDTFA seller’s permit Medical Cannabis Regulation and Safety Act of 2015 Personnel Requirements packaging and labeling requirements compliance with regulations Water/Food-grade Dry Ice Distributor transport sugar vape cartridges transport cannabis goods to retailer Microbial Impurities Testing (A. fumigatus, A. flavus, A. niger, A. terreus) period of 120 days shipping manifest paper inserted into the packaging comply with all packaging and labeling requirements hang tag or a peel-back label online licensing system 2020 issues must enter certain events Cannabinoids Testing Transition Period cannabis sales and/or consumption allergen information Operating Procedures Arranging for laboratory testing Retailer (nonstorefront) evidence of rehabilitation Temporary License Application premises diagram temporary license Live Scans for each owner aggregate interest of 20% or more CDPH-issued universal symbol 2020 regulations licensing and regulating commercial cannabis manufacturers regulations for medical and adult-use cannabis in California security and cannabis waste disposal unique ID/batch number final form nonlaboratory quality control annual license application commercial cannabis manufacturing infusion A-licensees Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA) cultivation (on an area less than 10,000 square feet) child-resistant packaging licensing cannabis microbusinesses A-license and an M-license minimum standards for extraction processes waste management laws financial interest holder waste disposal extracts cannabis event organizer license retailers 120 days Labor peace agreement Category I Residual Pesticides Testing contaminants Licensees periods of 90 days extensions conditional license ANTICIPATED ANNUAL (NONTEMPORARY) LICENSE APPLICATION REQUIREMENTS manufacturers who package for other producers Department of Consumer Affairs’ Bureau of Cannabis Control cultivation Mycotoxins Testing labeling manufacturer's name managing member equity interest in a commercial cannabis business Standard Operating Procedures (SOPs) track and trace system Mechanical inhalable cannabis packaging property for the commercial cannabis activity meat and seafood, and other products written procedures for inventory control manufacturing (Level 1 manufacturing, Type 6) transportation of cannabis goods sampling standards California Department of Public Health Seller’s permit number recordkeeping Licensee Lookup Tool manufacturing activities commercial cannabis manufacturing in California licensed premises medicinal and adult-use cannabis manufacturing CalCannabis Cultivation Licensing list of artificial food colorings Industrial Hemp Advisory Board licenses for both medicinal and adult-use cannabis manufacturing at the same premises exit packaging designated structure security diagram of the business’s layout ingredient list product guidelines exception for testing laboratories disclosure of all criminal convictions MCSB chain of custody Form # CDPH-9041 Proposition 65 Temporary event up to 4 days commercial cannabis manufacturing activity Manufactured Cannabis Safety Branch (MCSB) government warning statement label 600 foot radius of a school local jurisdiction’s ordinances and regulations Track and Trace member manager an officer or director of a cannabis business CALIFORNIA BUREAU OF CANNABIS CONTROL 2020 recent news sanitary and hazard-free environment onsite consumption of cannabis goods procedures for inventory control medicinal and adult-use or both markets shares of stock that are less than 5% of the total shares in a publicly traded company amount of THC content basic nutritional information licensed cannabis distributors Proposed Section 40133 MCSB’s temporary license application BUREAU OF CANNABIS CONTROL convicted of a substantially related crime cannabis plants licensing cannabis third-party testing laboratories manufacturing practices edibles packaging opaque primary panel requirements laboratory quality assurance supplemental label re-sealable remove THC/CBD compliance with local jurisdiction Completed Temporary License Application Form ISO/IEC 17025 accreditation cannabis market Foreign Material Testing product formulation Edibles– Products supply chain licensed cannabis manufacturers extraction motor carrier permit Manufacturing (non-volatile) capsules THC levels testing lab Transport vehicles alarm system protocol cannabis cultivation licensing microbusinesses Temporary License Application Information Moisture Content Testing Butane/Hexane/Propane the commercial medicinal and adult-use (recreational) consumption of alcohol or tobacco purchasing cannabis products on tribal lands storage of cannabis goods LICENSE APPLICATION REQUIREMENTS labels not be attractive small product packaging Medicinal and Adult-Use Cannabis Regulation and Safety Act license review process payable to the state of California finished product Percentage of ownership stickers Financial Interest 2020 compliance Category II Residual Solvents and Processing Chemicals Testing Cultivation less than 10,000 testing laboratories Individual Owner tamper-evident certified by a California-licensed engineer Local Issuing Authority local jurisdiction authorization Type S share facility space limited to a maximum of 1,000 mg per package medicinal and adult-use commercial cannabis activity no infusion of alcohol shaped like a human, animal, insect, or fruit product as a candy prohibited Criminal History onsite sale and consumption of cannabis goods A-license and an M-license for the same commercial cannabis activity commercial cannabis manufacturers destruction of cannabis goods emergency regulations Homogeneity Testing of Edible Cannabis Products concentrate three state cannabis-licensing authorities The Manufactured Cannabis Safety Branch (MCSB) some nutritional facts Business Information 600-foot radius of a school 2020 laws access to the area(s) regulatory framework licensing cannabis retailers evidence of the legal right to occupy the premises scaled to the gross annual revenue of the licensed premises valid waiver quality control informational panel Non-Storefront Retailer (Type 9) shared-use manufacturing facilities licensed physical location (premises) good manufacturing practices A-license alcoholic beverages Heavy Metals Testing health impacts of cannabis Microbial Impurities Testing (Escherichia coli and Salmonella spp.) carbohydrates and fat per serving Department of Public Health’s Manufactured Cannabis Safety Branch Bond in the amount of $5,000 Office of Environmental Health Hazard Assessment (OEHHA) cannabis training limited to a maximum of 10 mg of THC per serving cannabis adult-use products Poison Prevention Packaging Act of 1970 (PPPA) Extractions using CO2 commercial cannabis products highly-concentrated oils or waxes Licensee Information operating premises Identifying information licensing scheme local jurisdiction cannabis waste Temporary Cannabis Event Fingerprints Cannabis Manufacturing 2020 problems Owner child-resistant outer package packaging and labeling Distributor Transport Only operating procedures Water Activity Testing of Solid or Semi-Solid Edibles sanitary workplaces packaging and labeling requirements for pre-rolls 2020 important information testing methods secondary packaging CDPH-9041 Ethanol regulations for medicinal and adult-use cannabis medicinal and adult use cannabis goods transported together persons 21 years of age or older dried flower topicals 2020 revisions conducting quality assurance review Manufactured Cannabis Licensing System (MCLS) 2020 updates Premises diagram Bond and Insurance Information at least 99% purity structure and formation documents surety bond disposal and destruction methods The Bureau of Cannabis Control (BCC) requiring refrigeration required limits Financial information Vehicle Requirements distributors M-license 2,000 mg of THC per package for the medicinal-use market tobacco products definition of owner Food-grade Butter/Oil transporting cannabis goods secondary package local jurisdiction’s requirements Category I Residual Solvents and Processing Chemicals Testing Local Jurisdictions commercial kitchens Application Checklist delivery vehicle $3,000 of cannabis goods loop system supply chains for medicinal and adult-use cannabis products MANUFACTURED CANNABIS SAFETY BRANCH testing of cannabis goods M-licensees adult-use commercial cannabis activity cannabis cartoons persons with a financial interest in the cannabis business loan provided to a commercial cannabis business amount of THC/CBD per serving and per package Incorporating THC/CBD concentrates immature live plants and seeds being transported from a licensed nursery no infusion of nicotine cannabis industries manufacture cannabis products volatile solvent pre-made or purchased Terpenoids Testing Manufactured Cannabis Safety Branch Microbusiness and more.

In addition, Track-and-trace systems Proposition 65 warning statement Type N Infusions (optional packaging and labeling) Canopy Specialty Outdoor Type 1C (Cultivation; Specialty cottage; Small) Contact surface Component Holding Mature plant Raw material Type 5A (Cultivation; Indoor; Large) DPH-17-010E Type 1A (Cultivation; Specialty indoor; Small) Bureau Indoor cultivation Adequate Product Identity Type P Packaging & Labeling Only Quality control operation Universal symbol Cultivation site Preventive controls Extraction Primary panel Type 5 (Cultivation; Outdoor; Large) Specialty Cottage Mixed-Light Tier 2 In-process material Specialty Indoor track and trace system Premises Department Type 1 (Cultivation; Specialty outdoor; Small) Nursery MCSB 90-day extension periods Cannabis product Watts per square foot Type 2B (Cultivation; Mixed-light; Small) Type 3 (Cultivation; Outdoor; Medium) Quarantine gross annual revenue for first year in operation under MAUCRSA Cultivation Type 7 – for extraction using a volatile solvent (ex: butane, propane and hexane) Mixed-light Tier 2 list of cannabis manufacturers Type 14 (Cannabis Event Organizer) Wet weight Nonmanufactured cannabis product Licensee Small Indoor Medium Mixed-Light Tier 2 Adult-use Market Pre-roll Actual yield Flowering Serving Pathogen Medium Outdoor UID Microorganisms Processing aid Request for Live Scan Immature plant Processor Specialty Cottage Indoor Type 10 (Retailer) Allergen cross-contact Applicant Edible cannabis product alternate use of a manufacturing premises Type 11 (Distributor) Medium Mixed-Light Tier 1 Mixed-light cultivation Nonvolatile solvent Ingredient Type 7 (Manufacturer 2) Extraction: Volatile Solvents Finished product Small Outdoor Limited-access area Type 3B (Cultivation; Mixed-light; Medium) Personnel Qualified individual Track and trace system Specialty Cottage Outdoor Net weight Processing Quality Type 12 (Microbusiness) CBD Small Mixed-Light Tier 1 Informational panel Type 9 (Non-Storefront Retailer) Commercial cannabis activity Manufacturer licensee products similar to traditional food products prohibited Outdoor cultivation Hazard Infusion package flower or pre-rolls Batch Type 13 (Distributor Transport Only) Specialty Cottage Mixed-Light Tier 1 Commercial-grade, non-residential door lock cakes, cookies, beverages and juices, tea and coffee, chocolates, gummies, gum, and mints Quality control personnel Dried flower Type 3A (Cultivation; Indoor; Medium) cannabis concentrates Specialty Mixed-Light Tier 1 Pest Lot Adulterated Theoretical yield Environmental pathogen Package Validation Topical cannabis product Volatile solvent M-license Type N – for infusions Verification Type 6 (Manufacturer 1) Extraction: Non-volatile Solvents, Mechanical Methods Distribution Sanitize Type 2 (Cultivation; Outdoor; Small) Kief Small Mixed-Light Tier 2 Type 5B (Cultivation; Mixed-light; Large) Labeling CBD from industrial hemp Type 1B (Cultivation; Specialty mixed-light; Small) adulteration Specialty Mixed-Light Tier 2 Allergen Process Type S (coming soon, shared-use manufacturing facilities) Mixed-light Tier 1 infused butters and oils as concentrates infused pre-rolls Type 2A (Cultivation; Indoor; Small) Harvest Batch Medium Indoor THC limit of 10 milligrams per serving and 100 milligrams per package Type 4 (Cultivation; Nursery) Type 8 (Testing Laboratory) 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) Type P – for packaging and labeling only Manufacture Monitor THC Unique identifier and more.

Disclaimer: Informational and educational purposes. Self-help services (not legal advice). Site is not affiliated with any state agency. Note that site might not contain the most updated information. Your receipt of any information from this site does not create a relationship. Prior results do not guarantee or suggest a similar result in other matters. No promise is made with regard to services or content's reliability, availabilty, or ability to meet any needs. Information and services provided "AS IS."

Green Trusted
All Rights Reserved