Jarrell Cook

Final regulations for cannabis manufacturing approved

By Jarrell Cook, Legislative Manager, Government Relations

Capitol Update, Jan. 22, 2019

On January 16, California's Office of Administrative Law announced that it approved state regulations governing cannabis cultivation, manufacturing, distribution, and sale issued by California's Department of Public Health, the Bureau of Cannabis Control, and the Department of Food and Agriculture. The regulations will take effect immediately.

Portions of the regulation that may be of interest to manufacturers include:

  • Master Manufacturing Protocol – Manufacturers must develop a written ‘master manufacturing protocol’ for each unique formulation of product manufactured and for each batch size produced. The regulation details the required elements of the document.
  • Product Quality Plan – Clarifies that the required ‘Product Quality Plan’ for each type of product manufactured at a facility is subject to trade secret protection.
  • Narrowing ‘Manufacturing Activity’ – Neither adding cannabinoid content to the label on the package of cannabis or cannabis products by the distributor nor the preparation of pre-rolls is considered a manufacturing activity and may be done without a manufacturing license.
  • Disclosure of Financial Interest – A new section, 40130 (a)(9), requires an owner to disclose ownership or financial interest in any other cannabis business licensed under the Medicinal and Adult Use Cannabis Regulation and Safety Act.
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