US (MI): "The cannabis regulatory agency significantly expands the scope of allowed transfers between equivalent licenses"

The Michigan Cannabis Regulatory Agency (CRA) recently issued an advisory bulletin that may create significant licensing cost savings for grower and/or processor licensees holding both medical and adult-use licenses.

Pursuant to Administrative Rule 420.214, the CRA may authorize licensees who hold “equivalent licenses” to transfer marijuana products between the inventory of their medical and adult-use operations. This rule requires the CRA to establish a start date, end date, and other requirements for such transfers. Since at least 2019, the CRA has used advisory bulletins to regulate the equivalent license transfer process.

On February 8, 2023, the CRA issued its latest Advisory Bulletin on transfers of marijuana products between equivalent licenses (“Revised Equivalent Transfer Bulletin”). By its terms, the Revised Equivalent Transfer Bulletin superseded the prior bulletin on this topic issued on March 21, 2022 (the “Prior Bulletin”).

The Prior Bulletin contained detailed limits on product transfers, including CRA preapproval, testing criteria on marijuana products intended to be transferred, and limits on the quantity of marijuana products or plants which could be transferred during specific 30 or 60-day time periods. For growers and processors who held co-located medical and adult-use licenses, the equivalent transfer process under the Prior Bulletin provided a mechanism to somewhat manage inventories of marijuana produced by their medical and adult-use operations.


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