Cannabis Compliance: Top 5 Regulatory Changes Effective on January 1st

Happy New Year! Several important regulatory changes become effective on January 1, 2019. Below is a list of the most challenging regulatory changes that cannabis businesses will face on New Year’s Day.

  • Washington: The amended cannabis packaging and labeling regulations become effective on January 1, 2019. The Washington State Liquor and Cannabis Board (WSLCB) released a proposed interim policy that provides cannabis businesses with the details and requirements for phasing in the new packaging and labeling requirements. Although firms must comply on January 1, they will have until June 1, 2019 to submit the compliant packaging and labels to the Board for approval. The Board provided the phased in approach so that firms could deplete existing inventory that is often purchased in bulk in order to reduce costs. The phased in approach will allow firms to incorporate the new compliance packaging and labels as the inventory depletes.

  • Colorado: The permanent rules for recreational and medical cannabis are effective as of January 1, 2019. The Marijuana Enforcement Division adopted the final regulations on November 9, 2018.

  • California: California regulators may no longer issue temporary licenses after December 31, 2018. California also submitted final permanent rules to the Office of Administrative Law on December 3, 2018 for final approval. We expect the final rules to be published and effective in the first quarter of 2019.

  • California: California’s phase III testing requirements go into effect. Cannabis harvested or cannabis products manufactured on or after  December 31, 2018 must go through phase three testing. Phase III testing includes testing for terpenoids, mycotoxins, heavy metals and water activity testing of solid or semi-solid edibles. Cannabis products that are harvested or produced prior to December 31st may still be sold so long as they have been tested in compliance with phase I and phase II requirements.

  • Oregon: The Oregon Liquor Control Commission will stop issuing licenses to processors as alternating proprietors after January 1, 2019, but current processors in alternating proprietorships are grandfathered.

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