2018 Regulations for Manufacturers & Cultivators

Important New Regulations for Manufacturers & Cultivators 

Hello. My name is Tim Morland. I am the Compliance and Policy Director for RVR Distributing. RVR knows the transition into the regulated market can be a daunting process that can be down-right nerve wracking. The RVR team and myself are here to help.

Below you’ll find some brief guidelines to help you through this process. The first section is for manufacturers. The second section is for cultivators. While the language is similar, there are important differences, so make sure you are looking at the correct section for your business.

If you have any questions, please feel free to contact me anytime at tmorland@rvrdc.com.

Manufacturer Section

Manufacturing Licensing 

All licensees will be required to have local permission or a local license to obtain a temporary license granted by the California Department of Public Health. Licensing applications from the California Department of Public Health are currently available. All licensees with a temporary license will be required to apply for an annual license in the near future.

The California Department of Public Health will notify applicants when the application for the annual license is available. For six months manufactures can conduct business with other licensees whether they have an "A" or "M" license. RVR will have both licenses.

NOTE: RVR will only be able to distribute cannabis products for manufactures with a temporary license from the State of California on January 1, 2018.

Manufacturer Track and Trace

Temporary licensees will not be required to participate in the state-wide track and trace program. Once you receive your annual license from the California Department of Public Health you will be required to use the state track and trace system. The vendor for the track and trace program will be Metrc. Metric is the track and trace vendor for Alaska, Colorado, Maryland, Michigan, Nevada, Ohio and Oregon.

Manufacturer Taxes

Beginning January 1, 2018, all cultivators will be required to remit a tax of $9.25 per flower ounce (dry weight); $2.75 per ounce of trim. Cannabis cultivators who sell their product to a manufacture will remit the cultivation tax to the manufacture to whom they sell their product.

Manufactures are required to provide cultivators with valid proof of payment of the cultivation tax. Manufactures will in return remit cultivation taxes collected to the licensed distributor to whom they sell their manufactured products.  

RVR will provide the proper documentation to manufacturers of taxes paid. This documentation will be important for you to keep.

NOTE:  Please keep these records for a minimum of 4 years.

Manufacturer Testing

All manufactured cannabis products sold to a distributor January 1, 2018, and after will have to pass state testing standards. Distributors will be required to facilitate such tests with licensed testing labs. This test will be considered the official test by State of California.

Manufactured products held in a distributors inventory currently, and sold January 1, 2018, or after will not be required to meet the state testing standards; however, distributors will have to place a sticker stating that the product does not comply with state testing requirements.

We encourage you to pretest your products before you send it our facility to help ensure your product will pass testing requirements prescribed by the State of California.

Manufacturer Packaging and Labeling

Beginning January 1, 2018, all cannabis products will have to be placed in tamper proof packaging. There will be a six-month grace period where cannabis products can be sold to retailers that isn't placed in childproof packaging. Dispensaries will be responsible to place cannabis products in child-proof packaging at the time of sale to a consumer. However, RVR recommends that you acquire such packaging as soon as possible.

Beginning January 1, 2018, all edible products shall be placed in opaque packaging. Non-edible products will have to be placed in opaque bag or packaging when sold by a dispensary.

Manufactured cannabis products sold by a licensed distributor beginning January 1, 2018, and before July 1, 2018, will not have to meet the labeling requirements prescribed by California Department of Public Health and California state law.

A licensed distributor will have to place a sticker on the package that states that the product does not meet state labeling requirements. Once again, we encourage you to package your product in packaging that meets the labeling requirements prescribed by state law as soon as feasibly possible.

Manufacturer Dosage

Edibles sold for adult use shall contain 10mg of THC per serving. Edible products sold for adult use shall not contain more than 100mg of THC per package. Edible cannabis sold for medicinal use shall contain 10mg of THC per serving. However, each package does not have a THC limit.

Beginning January 1, 2018, and before July 1, 2018, non-edible cannabis products that don't meet THC levels prescribed by the California Department of Public Health and the State of California can be sold and transported.

Beginning July 1, 2018, all non-edible cannabis products sold for adult use shall contain no more than 1,000mg of THC per package, and non-edible cannabis sold for medicinal use shall contain no more than 2,000mg of THC per package.


Cultivator Section

Cultivator Licensing

All licensees will be required to have local permission or a local license to obtain a temporary license granted by the California Department of Food and Agriculture. Licensing applications from the California State Department of Agriculture are now available.

All licensees with a temporary license will be required to apply for an annual license in the near future. The California Department of Food and Agriculture will notify applicants when the application for the annual license is available. For six months cultivators can conduct business with other licensees whether they have an "A" or "M" license. RVR will have both licenses.

NOTE: RVR will only be able to distribute cannabis products for cultivators with a temporary license from the State of California on January 1, 2018.

Cultivator Track and Trace

Temporary licensees will not be required to participate in the state-wide track and trace program. Once you receive your annual license from the California Department of Food and Agriculture you will be required to use the state track and trace system. The vendor for the track and trace program will be Metric. Metric is the track and trace vendor for Alaska, Colorado, Maryland, Michigan, Nevada, Ohio and Oregon.

Cultivator Taxes

Beginning January 1, 2018, all cultivators will be required to remit a tax of $9.25 per flower ounce (dry weight); $2.75 per ounce of trim to a licensed distributor who distributes their product. RVR will provide the proper tax documentation to our vendors to prove taxes have been paid. This documentation will be important for you to keep.

NOTE: Please keep these records for a minimum of 4 years.

Cultivator Testing

All flower product distributed by January 1, 2018, will have to pass state testing standards. Distributors will be required to facilitate such tests with licensed testing labs. This test will be considered the official test by State of California.

Flower held in a distributors inventory now and sold after January 1, 2018, will not be required to meet the state testing standards; however, distributors will have to place a sticker stating that the product does not comply with state testing requirements. We encourage you to pretest your flower before you send it our facility to help ensure product will pass testing requirements prescribed by the State of California.

Cultivator Packaging and Labeling

Beginning January 1, 2018, all cannabis flower will have to be placed in tamper proof packaging. There will be a six-month grace period where cannabis products can be sold to retailers that isn't in childproof packaging.

Dispensaries will be responsible to place cannabis products in child-proof packaging before final sale to a consumer. However, RVR recommends to acquire such packaging for your product as soon as possible.

Flower sold by a licensed distributor from January 1, 2018, and before July 1, 2018, does not have to meet the labeling requirements prescribed by California Department of Public Health cannabis regulations and state law.

A licensed distributor will have to place a sticker on the package that states that the product doesn't meet state labeling requirements. Once again, we encourage you to package your product in packaging that meets the labeling requirements prescribed by state law as soon as feasibly possible.

NOTE: Beginning January 1, 2018, RVR will only be allowed to purchase cannabis flower that is in retail ready packaging.

We hope you find this information helpful. The RVR Team is here to assist you in any way we can. Reach out if you have any questions.

 


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