Allison Margolin, founder and partner of Margolin & Lawrence, spoke on Wednesday about dosing regulations at the State of Cannabis conference in Queen Mary, Long Beach. The maximum dosage is 100 mg of THC for packaged edible products, and each serving can contain no more than 10 mg. This was established in the final re-adoption of the emergency regulations (CCR, Title 17, Division 1, Chapter 13, §40305), and while these limits may frustrate consumers with a higher tolerance, larger doses of concentrated cannabis products are allowed in non-edible forms. Under §40306 of the regulations, topical products, concentrates and other non-edible products (including tinctures and capsules) may be sold in amounts up to 1,000mg per package. a special recommendation to get a larger dose (up to 1,000mg) without medical prescription. Up to 2,000mg per package is also permitted under this provision, but only for medicinal-use customers and with appropriate labelling.
Other panelists at the conference also discussed an issue regarding testing laboratories that has previously been flagged as an increasing problem. Since there are not enough testing laboratories for the amount of product being funneled through the current cannabis market, retailers have experienced severe delays as new products accumulate. All cannabis products must go through testing prior to being sold through a licensed retailer, but the average lab can only test around 100-120 samples per day, according to CSO of Cannalysis Labs. This does not match the rate of cannabis production and has caused considerable delays in the cannabis market flow in California. Unless more testing labs receive licensing, retailers will continue to struggle due to this testing bottleneck.
Several legislative changes were passed this week, including the Cannabis Equity Act and Assembly Bill 2020, both approved by Governor Brown several days ago. The California Cannabis Equity Act is a bill designed to provide assistance to small cannabis businesses impacted by the War on Drugs. As California’s larger municipalities already have social programs structured to relieve those most affected, this legislation provides past marijuana offenders with a greater opportunity to attain retail licenses for commercial cannabis. In the coming year, state regulatory agencies will provide grants in coordination with the Bureau of Cannabis Control in order to develop programs similar to those in the Bay Area, Los Angeles and Sacramento. Currently $10 million have been allocated in initial funding for the bill, though this may increase depending on the success of the social equity programs.
Assembly Bill 2020, which also passed this week, authorizes state temporary event licenses. This allows for an event to be held at any venue expressly approved for events by local jurisdictions. The bill requires all participants engaged in the onsite retail sale of cannabis or cannabis products to be appropriately licensed. Furthermore, an event applicant must provide the Bureau with a list of all licensees that will be providing onsite sales of cannabis or cannabis products at the event 60 days beforehand. Any person who violates the requirements governing state temporary event licenses will be charged with a civil penalty for each violation in an amount up to 3 times the license fee.
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