Below is our letter of public comment submitted to California’s Bureau of Cannabis Control the proposed text of regulations Section 5032(b) regarding commercial cannabis activity. If you share our viewpoint we urge you to repurpose this language and/or submit your own personalized position to the BCC before November 5, 2018. Instructions for submission of public comment by email or mail are found here: https://www.bcc.ca.gov/law_regs/17-065_public_comment.pdf
California’s three state cannabis licensing authorities, the Bureau of Cannabis Control, the California Department of Public Health and the California Department of Food and Agriculture, proposed new regulations in the California Regulatory Notice Register on July 13, 2018. This was the first step toward adopting non-emergency regulations and opened the 45-day public comment period required in the formal rulemaking process.
New label requirements mandated by California’s Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA), as well as the proposed emergency regulations issued by the state’s three cannabis licensing authorities on November 16, 2017, are a departure from current practice, and could subject cultivators, wholesalers, manufacturers and retailers to liability if not addressed.