California Large Licensing Gets Really Small

California law required the state Department of Cannabis Control to begin accepting large license applications on January 1, 2023. Earlier this year, DCC published proposed large licensing regulations (which I described here). As usually happens, on December 5, 2022, DCC dropped its second set of modifications to the proposed regulations. When DCC’s rules take effect, they will make it very difficult for people to get large licenses.

The new DCC rules and large licensing

To summarize my earlier post, the state will allow cultivators to apply for larger licenses than were previously available. Up until now, larger farms had to aggregate small licenses, which they can now convert into large ones. One of the key issues here though – which state law mandated years ago – was that large license holders couldn’t own testing labs, microbusinesses, and distributors. More on that below.

The big change though concerns prohibitions on license ownership. When I wrote my original post, the original proposed regulations said that “holders” of large licenses were ineligible to hold the other license types referred to above. This was an incredibly vague term. Did it mean that a business that holds a large license couldn’t hold the other types?

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