New Manufacturing Regulations are Hard to Swallow

By: Chris J. Hoo, Esq.
of Evergreen Law

Cannabis product manufacturers in California certainly have a lot to say about the regulations proposed by the state that will be overseeing their businesses.  While there’s still time to change them (and the Bureau itself seems to know it’ll take some time after January 1 for the dust to settle), most of the proposed medical regulations are likely here to stay and will also apply to adult-use manufacturing.  Here’s some of the more notable proposed regulations that will drastically change the cannabis products manufacturers roll out:

THC Limits:

Edibles are limited to 10 mg of THC/serving and 100 mg of THC/package (think a package of candy with ten 10-mg pieces). 


“Not attractive to individuals under 21”, meaning no cartoons or images popularly used in children’s advertising and no imitations of candy packaging or labeling.  Packaging cannot even resemble traditionally available food packages. 

Prohibited Products

Cannabis cannot be combined with alcoholic beverages, nicotine, caffeine, foods requiring refrigeration, canned products, juice, dairy, meat, or seafood.  You also cannot use commercially available candy or snack food items.

It’s worth pointing out that these proposed manufacturing regulations paint a different picture from the current cannabis products scene.  (Gummi bears, anyone?)  The market has a history and culture of illicitness, and that is not going to change overnight.  Indeed, the illicit market will remain a key player in the industry for some time while the “dust settles”.  However, for the serious manufacturers who plan on running a legitimate, licensed cannabis business, the time to get used to the new regulations and build their corporate culture of compliance is now.