Final Proposed Regulations

The BCC has released their final proposed regulations outlining how business will be conducted in the legal cannabis industry. While these changes have not yet taken effect, now is the time to start preparing. Let’s go over some of the major changes that permanent license holders should be aware of.

§ 5048. Track and Trace System(a) A licensee shall create and maintain an active and functional account within the track and trace system prior to engaging in any commercial cannabis activity, including the purchase, sale,test, packaging, transfer, transport, return, destruction, or disposal, of any cannabis goods.

According to the proposed regulations, track-and-trace systems will be mandatory for any license holder operating in the legal cannabis landscape. It is important to note that cultivators will have to track the material that they sell and ship, as well as the waste. This means that all licencees are going to have to get use to the idea of using tractability software.

§ 5307.2. Licensed Distributor to Licensed Distributor Transfers Cannabis goods, packaged as they will be sold at retail, that have undergone and passed regulatory compliance testing and have an accompanying certificate of analysis may be transferred to one or more licensed distributors. However, cannabis goods that have not been transported to retail within 12 months of the date on the certificate of analysis must be destroyed or retested by the licensed distributor in possession of the cannabis goods.

According to this statement, it sounds like it would mean that any material that is still floating around from the pre-2018 days will have to be tested before it can be transported to retail. If you are still processing product that has not been tested for over a year, it will require a new certificate of analysis if it has not been transferred to retail before the proposed regulations take effect.

Don’t get hit by the book, stay ahead of the game and make sure you’re not caught up with non-compliant material in your workflow. If you’re in need of some compliant product to keep your manufacturing pipeline going we are here to help. There are many options on the marketplace that could keep you going.

The Bureau of Cannabis Control’s existing Readopted Emergency Regulations will remain in effect until the Proposed Non-Emergency Regulations complete the formal rulemaking process. We would encourage you to read up on the proposed regulations that can be found here.

If you need help, or if you have questions about what this means for your operation feel free to reach out to us via email at or give us a call at 415-683-8601. 

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