• Team Highroad

Newly proposed CA permanent cannabis rules are up for comment by November 5, 2018

Updated: Nov 1, 2018

In late October 2018, the state of California proposed a new set of permanent cannabis regulations. Please see below for highlights listed by state department. We advise you to review the full proposals here.


The regulations are up for public comment through November 5, 2018.


This is our opportunity as an industry in California to work together with lawmakers to help shape regulations that make profitable compliance possible.


Details about the proposed rules:


All Licenses

  • One supervisor and one employee must successfully complete a Cal-OSHA 30-hour general course by an authorized OSHA provider within 1 year of obtaining a cannabis license.

  • Tickets reflecting the date and time of when your cannabis waste is collected are no longer required, but a receipt showing payment to a waste collection service is needed.


Bureau of Cannabis Control – Retail, Distribution, Testing Laboratory and Micro business Licensees

  • Samples that fail compliance testing before a COA is issued may be re-tested with certain requirements.

  • Business owners must disclose all parties involved in the business including all parties with a financial interest.

  • Commercial cannabis activity of any kind by non-licensed parties is strictly prohibited. This includes the use of IP, direction to make orders, etc.

  • Distributors must now comply with new packaging requirements, including ensuring packages containing multiple products are resealable and protecting cannabis and pre-rolls from contamination from other substances within the package (i.e. matches).

  • Beginning 01/01/2020, distributors are responsible for ensuring that all packages containing cannabis goods are child-resistant and includes a label stating, “This package is not child-resistant after opening.” A plastic packaging that is at least 4 mils thick and heat-sealed without an easy-to-open tab, dimple, corner, or flap is considered “child-resistant.”

California Department of Food and Agriculture – Cultivation Licensees

  • Beginning 1/1/2020, cultivators are responsible for ensuring that all cannabis packaged for retail sale must be child-resistant.

  • Cultivators with multiple cultivation licenses are prohibited from sharing the following spaces: Areas outside the canopy that contain immature plant, designated processing areas, designated packaging areas, designated areas for physically segregating cannabis subject to an administrative hold.

California Department of Public Health – Manufacturing Licensees

  • Waste Management: Vape cartridges do not need to be emptied before disposal if the cartridge is no longer usable.

  • Waste Management: Waste can be collected by specific local agencies.

  • Waste Management: Self-hauled cannabis waste must be done by employees only and taken to a solid waste landfill or composting facility, and the employee must obtain a receipt or weight ticket from the facility.

  • Edible cannabis products that fail compliance testing due to exceeding the limit of THC may be repackaged if certain requirements are met.

  • Cannabinoid content must be added to the label at the distribution location.

Highroad plans to submit comment to the agencies on behalf of our clients and the industry. Give us a call to contribute.

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