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 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 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 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.

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

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

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

All Rights Reserved