At Manzuri Law, our California cannabis attorneys have helped local businesses procure and maintain over 300 licenses over the past decade — including Type 11 licenses, also known as cannabis distribution licenses.
According to the Department of Cannabis Control, cannabis distribution licenses (both Type 11 and Type 13) allow California business operators to transport cannabis products between cultivation, manufacturing, or distribution premises and move finished cannabis goods to retail premises. While Type 13 licensees may only transport products, Type 11 licensees are authorized to store, test, and package cannabis goods.
While distribution itself may seem like a simple concept, intricate compliance requirements must be followed to ensure the license remains in good standing, so there are no delays or potential issues in its annual renewal.
What Operations are California Cannabis Distributors Authorized to Participate In?
Type 11 and Type 13 distributors are authorized to distribute cannabis products, accessories, and branded merchandise or promotional materials belonging to other licensees in the industry.
In addition to transporting cannabis products, Type 11 distributors may provide:
- Cannabis Storage
When storing cannabis under a Type 11 licensee, all cannabis products must be stored separately and distinctly from the other products/batches located in the distribution center. Likewise, each product must be properly tracked in the state’s track-and-trace system, Metrc. Within ten calendar days of the initial credentialing into the track-and-trace system, Metrc package and/or plant tags must be ordered for all plants and products. Within three calendar days, the distributor must confirm that the Metrc tags were received (or not received).
- Cannabis Packaging
Licensed distributors may package, re-package, label, and re-label cannabis for pre-rolls before regulatory compliance testing occurs. Importantly, a distribution license does not allow for the actual processing of cannabis products, such as curing or trimming.
- Cannabis Transportation and Sales
Cannabis transportation may only be conducted by licensed distributors, or employees of the licensee. All vehicles and trailers used for transportation must be owned or leased by the licensee, and must meet the transportation requirements of the DCC.
- Trade Sample Provision and Transportation
Cannabis goods that have been classified as trade samples may be provided to a licensed distributor in limited quantities each month. Such transfers must be recorded in Metrc, the track-and-trace system.
Importantly, all the authorized activities described above have additional regulations not discussed here. To renew a Type 11 license annually, you must have a clear understanding of the requirements applicable to your operations and have a system that ensures you remain compliant in practice.
Before applying for a distribution license, it is important to determine whether a Type 11 or Type 13 license best serves your specific business goals. Manzuri Law excels at helping distributors win, maintain and renew their distribution licenses so they can continue their operations without interruption.
Contact us at Manzuri Law and We can Help You
Contact us today by phone at (310) 912-2960 or online to learn more about how we can help protect your operation from its formation and licensing stages through ongoing compliance and security measures.
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