Plenty to read in this month’s issue from the Washington State regulators….
Preparing for Significant Changes
Please remember that you cannot move your licensed cannabis business without prior approval from the Washington State Liquor and Cannabis Board (WSLCB).
No one likes to think about it, but a little estate planning will help ease your business’ transition during a difficult time. Although we can’t provide legal advice or help you prepare your will, we encourage you to be prepared. The WSLCB cannot transfer a license to another person until the estate is settled. We will request documents and information to demonstrate who has ownership rights. Most common documents we request include a will, letters of testamentary, and the death certificate. If you have additional questions regarding estates, please email email@example.com.
On October 3, 2020, changes to the marijuana true party of interest (TPI) rules went into effect. With these updates, the Licensing Division will no longer require background vetting of a marijuana licensee’s spouse, if the spouse does not exercise control over the licensed marijuana business. Please use the Change of Governing People application to make changes to the people on your license. If you have questions about making changes to your license, please contact firstname.lastname@example.org.
We have been receiving questions about how to submit intellectual property contracts for review. Washington’s cannabis licensees must disclose agreements and contracts related to intellectual property to the WSLCB as required by RCW 69.50.395. WSLCB staff review them for compliance with cannabis laws and regulations. WSLCB staff will not review drafts or provide legal advice/draft contract language for licensees. Please submit completed contracts to email@example.com.
Are Your Packages and Labels Compliant?
- False or misleading, consistent with guidance provided in 21 C.F.R. Sec. 101.18(a);
- Promotes over consumption;
- Represents that the use of marijuana has curative or therapeutic effects;
- Depicts a person under the age of twenty-one consuming cannabis: or;
- Especially appealing to persons under twenty-one years of age as defined in WAC 314-55-105.
- A completed application.
- Photo of the product, package, label, and retail/bar code label (if applicable). The photo(s) provided shall be of sufficient clarity and resolution to enlarge and illustrate all packaging and labeling requirements.
- Recipe/ingredient approval from Washington State Department of Agriculture (WSDA). Ingredients must be listed on the packaging/labeling verbatim as approved.
- A copy of the Marijuana Infused Edible Processor Endorsement from the Washington State Department of Agriculture.
Medical Cannabis Endorsed Retailers
- Having a certified medical marijuana consultant on staff in accordance with Department of Health (DOH) rules.
- Carrying cannabis concentrates and infused products that have been identified as medical grade by DOH and maintaining at all times, a representative assortment of marijuana products necessary to meet the needs of qualified patients and designated providers.
- Entering qualifying patients and designated providers into a medical cannabis database administered by the DOH.
- Issuance of medical cannabis patient cards developed by DOH.
- Ensuring that all employees are trained on medical cannabis including the ability to identify authorizations and recognition cards.
Social Equity: LCB Hosted Virtual Meetings
- Improve communication between the LCB and communities of color;
- Introduce LCB leadership, explain roles, and to establish how the LCB’s work might intersect with people of color who apply for licenses in the future or acquire existing licenses; and
- Inform attendees about the work of the Social Equity Task Force, established through legislation.