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California Bureau of Cannabis Control Proposes Extension of Emergency Cannabis Regulations

The California Bureau of Cannabis Control has proposed the state readopt and extend the current, emergency cannabis industry regulations. Previous regulations called for the merging of the medical cannabis industry (MCRSA) and adult-use industry (AUMA) into what’s now known as MAUCRSA, governed by the Bureau of Cannabis Control.

As part of the current regulations, applicants have had to apply for both adult and medical use licenses, Type A and Type M, respectively.

A licensee can hold both an M- and A- license of the same type at one location as long as the following criteria are met:

(1) The licensee holds both an A-license and an M-license for the identical type of commercial cannabis activity;
(2) The licensee who holds both licenses is identical in name, business formation, and ownership;
(3) The licensee only conducts one type of commercial cannabis activity on the premises;
(4) All cannabis and cannabis products are clearly marked with an “A” or “M”; and
(5)Records are kept separately for each license and clearly indicate that the records are related to the A-license or the M-license.

Section 5029 of the emergency regulations states:

(b) Notwithstanding any other law, or regulation in this division, beginning January 1, 2018 and before July 1, 2018 licensees may do all of the following:
(1) Licensees may conduct business with other licensees irrespective of the M or A designation on their licenses.

What’s changed?

The BCC has issued an extension of the expiring emergency regulations it issued before for another 180 days, with the following changes affecting adult-use and medicinal licenses:

  • Applicants may complete one license application and request an A-designation, an M-designation, or both for the license.
  • Regardless of designation requested, applicants will pay one license fee.
  • Licensees may engage in commercial cannabis activities with any licensee regardless of designation.


  • The first draft of emergency regs released in late 2017 is still in effect for the next 180 days.
  • During these 180 days all licensees can keep on conducting business like they are (ie. temporary medical licensees and temporary recreational licensees) which was supposed to cease July 1.
  • They are proposing amendments now to the first draft of regs for clarification purposes. There is a 5-day comment period. Per bulletin: “The public comment period will begin when the California Office of Administrative Law (OAL) posts the proposed emergency regulations on its website and will last 5 calendar days. The posting may not occur before May 25, 2018, to allow for the 5 working day notice to the public that the licensing authorities provided today. “

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