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Regulatory Comments on Craft Marijuana Cooperatives

It is September, 2023, and the CCC is currently revising the cannabis regulations. There are a number of critical issues in legislation passed last year that must be implemented with new regs, including Host Community Agreements, social consumption, equity programs, and agent eligibility. There are lots of smart people talking about these issues (and I’ll share my thoughts soon), but what I’m talking about today is Cooperatives. The regulations regarding the Craft Marijuana Cooperative license are in dire need of an update. This license has so much potential to achieve numerous goals of all stakeholders (i.e., entrepreneurs, investors, municipalities, consumers, the CCC, etc.), but it is being woefully under-utilized partly due to poorly drafted regulations.


As a public comment to the CCC, I submitted a short list of regulatory changes I recommend to improve the Coop license. You can check it out below. My comments address:


1) Fixing the flawed residency requirement;

2) Explicitly permitting certain types of investors in coops;

3) Fixing the erroneous definition of “Member”;

4) Permitting Coops to deliver to consumers;

5) Providing additional exclusive benefits to incentivize Coop applicants;

6) Encouraging other license types to structure their business in a cooperative fashion;

7) Loosen the ownership limitations if the additional license also a Coop;

8) Expand canopy limits for Coops; and

9) Reduce administrative burden related to Change of Control Requests for Coops;


If you have questions about cannabis cooperatives, send me a message!












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