As of January 1, 2018, all cannabis and cannabis products sold in California must be tested rigorously under state law. The regulations, according to California’s Bureau of Cannabis Control (BCC), require that all batches of cannabis products undergo testing by third-party laboratories that interrogate the samples for safety and dosing accuracy.
Type 11 distributors, microbusinesses or type 13 transport-only distributors are the only licensees that may engage in transportation between licensees, with the exception of transport only distributors who cannot transport cannabis goods to the premises of a retailer, except for when the licensee is transporting only immature plants and seeds from a licensed nursery to a licensed retailer or microbusiness.
One of the key functions of distributors is providing storage. Type 11 distributors and Type 12 microbusinesses (who choose to operate as distributors), are allowed to store goods on their premises as long as they remain compliant. Distributors can store products they own, or have title to, and/or store products belonging to others, in which case they only take custody of the products. Regardless, they are responsible for the inventory while it is in their possession and must report any discrepancy to the bureau and authorities should significant loss or theft occur. An update to the regulations also now allows distributors to transfer products to other distributors' facilities for storage post-compliance testing. This is great for many looking to store their products in different geographies of the state without the transferee having to re-test the cannabis goods for compliance.
Labeling and packaging requirements impact all the players as cannabis products travel up the supply chain. Cannabis operators in California have to comply with a number of packaging and labeling laws that the government has established to protect consumers.