What’s wrong with the private cannabis sector summed up by lack of response on OLCC request for comments on proposed rule changes

Oregon’s industry body doesn’t appear to be impressed by its members, and other statewide private sector non-members complete lack of interest in process.



They write the following and the tone seems one of exasperation.

In the end what happens is they don’t contribute and then the OLCC makes relevant changes and then  hey all complain and some of them who have enough money clog up the civil courts with pointless lawsuits .

Dear CIAO Members and Supporters,

Time To Make Yourself Heard! The OLCC has published it proposed rules and you all are now able to submit your comments about their proposed rules package

The OLCC has not received a single comment form the industry as of yesterday!  There are some big changes in these rules so please take a moment read through them and submit your comments to the OLCC ASAP!  Contact me – Jesse Bontecou – if you have any questions, ideas, or need help!

Download Proposed Rules – MJ Legislative and Technical Rules Package

Submit Written Comments Via Email (Deadline 5:00 PM Tues. 10/31) – Nicole Blosse OLCC Rules Coordinator

Provide Public Verbal Comments – OLCC Public Hearing Oct. 17th 9-10 AM


Join The Meeting

Meeting ID: 245 194 907 580

Passcode: E2ZzT9

Call in (audio only) +1 323-553-3576,185495682#



Quick & Dirty Summary of Proposed Changes:

1. Creation of Cannabis Reference Laboratory:

– House Bill 2931 directs the State Department of Agriculture (ODA) to establish a cannabis reference laboratory in consultation with the Oregon Liquor and Cannabis Commission (OLCC) and Oregon Health Authority (OHA).

– Collaboration among agencies to provide regulatory and technical support for enforcing cannabis regulations.

2. Technical Amendments and Corrections:

– OLCC proposes amendments to rules in OAR chapter 845, divisions 25 and 26.

– Changes include consolidating definitions, correcting errors, clarifying language, and updating references for improved readability and consistency.

– Specific amendments listed for rules in divisions 25 and 26.

3. Rule Violation Recategorization and Expansion:

– Recategorizing certain rule violations, expanding avenues of revocation for undisclosed interest, and extending suspension or revocation periods for worker permits under specific scenarios.

– Aimed at addressing serious rule violations and enhancing consistency in OAR chapter 845, divisions 25 and 26.

4. Location Restrictions and Prohibitions:

– Amendments to OAR 845-025-1015, 845-025-1115, and 845-025-1230.

– Defining “at the same location or address” for co-location restrictions.

– Adding prohibition on co-location with psilocybin manufacturing and service centers for clarity and consistency.

5. Water Access Documentation Requirement:

– Amendment to OAR 845-025-1030, requiring documentation from the Oregon Water Resources Department for producer initial license applications and changes of ownership.

– Aims to ensure compliance with water use laws.

6. Reporting Analyte Detections:

– Amendment to OAR 845-025-5045, requiring laboratory licensees to report analyte detections for all OHA-established compliance tests in the Cannabis Tracking System (CTS).

– Enhances data tracking for regulating contaminants within regulated products.

7. Transfer of Failed Products for Remediation:

– Clarification of OAR 845-025-5740 to allow licensees to transfer failed cannabis and hemp items to a wholesaler or processor for remediation.

– Provides flexibility to licensees with necessary safeguards against diversion.

8. Definition of “Different Potency”:

– Amendment to OAR 845-025-7520 to define “different potency” for combining products under one UID tag.

– Aims to create a clearer standard, ensuring consistency and reducing staff time.

9. Proof of Tax Compliance Requirement:

– Amendments to multiple rules, including OAR 845-025-1030, 845-025-1165, 845-025-1170, 845-025-1190.

– Requires proof of tax compliance from the Oregon Department of Revenue for marijuana retailer licensees at various stages.

– Introduced to ensure financial responsibility, compliance with tax obligations, and funding for public health and safety programs.

10. Increase in Daily Sales Limits:

– Amendment to OAR 845-025-2800 to increase daily sales limits for certain cannabinoid products from five grams to ten grams.

– Aims to allow larger consumer purchases, reduce packaging waste, and lower labor costs.

11. Adjustments to Container, Concentration, and Serving Size Limits:

– Amendments to OAR 845-026-0210 and 845-026-0220 for both medical and recreational markets.

– Introduction of a new definition for “mixed concentrate and extract” in OAR 845-026-0100.

– Aimed at harmonizing container and serving size limits for certain products.

12. Net Weight Definition Amendment:

– Amendment to OAR 845-025-7000 to remove the filter or tip from the net weight for infused pre-rolls.

– Aligns with OLCC laboratories’ testing practices for infused pre-rolls.

13. Changes to Package and Label Application Process:

– Amendment to OAR 845-025-7160 to disallow license applicants from submitting package and label applications prior to licensure.

– Introduction of a new section for inactivation of applications not acted upon after 365 days.

– Aims to reduce OLCC staff time and data storage burdens.

14. Technical Correction to Weight Classification:

– Amendment to OAR 845-025-7575 for scenarios where input and output weight are exactly equal.

– Clarifies tracking obligations without substantive modification.

15. Prohibition on Transfer Without Manifest:

– Amendment to OAR 845-025-7700 to add a prohibition on transferring or transporting marijuana without a manifest, to an unknown or undisclosed location, or to an unlicensed location.

– Aims to address marijuana being transferred outside the regulated system.

16. Expansion of Advertising Rules to Include Hemp Items:

– Amendments to OAR 845-025-8000 through 845-025-8040 to include hemp items in advertising rules.

– Modification of OAR 845-025-8040 for clearer standards on advertising claims about curative or therapeutic effects.

– Aims to ensure equal treatment of marijuana and hemp items and protect public health and safety.

17. Expansion of Hemp-Derived Vapor Item Rules:

– Amendments to OAR 845-025-7000 and 845-026-7010 to extend the applicability of packaging and labeling rules to any sale of an industrial hemp-derived vapor item to a consumer in Oregon.

– Aligns with 2021 SB 96.

18. Consolidation of Violations for Adulterating Marijuana:

– Amendments to OAR 845-025-1300, 845-025-2070, and 845-025-8540 to consolidate violations for adulterating marijuana under a single rule.

– Aims to increase clarity and reduce complexity.

19. Change in Terminology:

– Amendments to OAR 845-025-2025, 845-025-2090, 845-025-8540, and 845-025-8580 to refer to “marijuana” instead of “usable marijuana.”

– Aims to clarify provisions regardless of whether marijuana has been dried.

20. Repeal and Removal of Presumptive Test Definition:

– Repeal of OAR 845-026-4100 and removal of the definition of “presumptive test” from OAR 845-026-0100.

– Necessary due to the repeal of sections of 2021 HB 3000, effective January 1, 2024.

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