Sixth months have almost passed under the transition regime and the July 1st deadline for the Emergency Regulations approaches soon. Many dispensaries are in a state of crisis because there has not been enough time for businesses to come into compliance given the very few licensed testing facilities – only 19 active of the 30 licenses granted as of May. Compare that number with the over 3,800 cultivation licenses and the 800 manufacturing licenses. The United Cannabis Business Association has done the math, and the math does not add up: a testing facility can handle 100-120 samples per day, which works out to only about 4 cultivation batches per day on average. With problematic and confusing rule changes on packaging requirements, including labels and child-resistant rules, the supply of compliant packaging is too low. And, as a result of these issues as well as various other regulatory delays and obstacles, there’s an enormous backstock of product that is out of compliance with Section 5029(b)(5).
Many small business owners and working Californians stand to lose if the deadline does not get extended past July 1st. Margolin & Lawrence joins the United Cannabis Business Association in asking the BCC to extend the deadline. Remind them that the BCC has the authority under the statute’s reasonable business owner standard to extend the deadline another three months given the current, wholly inadequate state of the testing infrastructure. We support the transition to a fully regulated market, but business owners cannot come into compliance unless there are enough facilities licensed for testing to meet the current industry demand. Please consider joining us in sending a letter to the BCC and letting them know your thoughts!