The proposed regulation would prohibit common industry practices such as white labeling and IP licensing
Our firm has prepared a public comment in opposition to the following Proposed California Regulation issued by the Bureau of Cannabis Control:
§ 5032. Commercial Cannabis Activity
(b) Licensees shall not conduct commercial cannabis activities on behalf of, at the request of, or pursuant to a contract with any person that is not licensed under the Act. Such prohibited commercial cannabis activities include, but are not limited to, the following:
(1) Procuring or purchasing cannabis goods from a licensed cultivator or licensed manufacturer.
(2) Manufacturing cannabis goods according to the specifications of a non-licensee.
(3) Packaging and labeling cannabis goods under a non-licensee’s brand or according to the specifications of a non-licensee.
(4) Distributing cannabis goods for a non-licensee.
You can read the full text of our public comment by clicking here.