California commercial cannabis licensees currently operating with a state provisional license have until December 31, 2025 to submit a provisional license renewal. All provisional licenses will expire on January 1, 2026.[1] Thereafter, licensees must obtain an annual license to continue operating.
Over the next few months, provisional licensees will likely receive urgent email notifications from the Department of Cannabis Control (“DCC”) for any outstanding annual license requirements in order to successfully transition their provisional license to an annual license.
Depending on the license type, outstanding requirements may include such requests as an updated lease agreement, an updated list of currently manufactured products, revisions and clarifications to the business premises diagram, and/or site specific quality control programs.
Most significantly, licensees must obtain written compliance from their local jurisdiction or the DCC with the California Environmental Quality Act (CEQA) to obtain an annual license. Each local licensing jurisdiction is handling CEQA in a different manner,[2] which has resulted in different compliance requirements and timelines based on locality.
However, what is similar is that all project sites, no matter the locality, will be required to produce either a Notice of Exemption (NOE) or an Initial Study/Mitigated Negative Declaration (ISMND) to the DCC as part of their state annual application package.
For many cities, the NOE has been achieved without issue. In the City of Los Angeles, the DCR is behind and applicants may be in danger of missing crucial deadlines for renewals. However, the City of Los Angeles states they remain actively working with licensees to remedy this CEQA NOE deficiency.
Once the locality completes their specific CEQA review, the licensee’s NOE package will be filed online by their respective local jurisdiction with the State Clearinghouse. Once a licensee receives the package from their city (or pulls it directly from CEQAnet), the NOE records must be submitted via electronic mail to the DCC Environmental Review team for review.
Once submitted, the Environmental Review team may require further documentation or may recommend the provisional license be transitioned to an annual license.
[1] Certain exceptions apply for eligible locally verified equity retailers (excluding microbusinesses with retail activity.
[2] Read more on local handling of CEQA compliance in our article here.
“This information is provided as a public educational service and is not intended as legal advice. For specific questions regarding DCC annual licenses, CEQA compliance for cannabis licensees and updating local ordinances, please contact Manzuri Law at (310) 912-2960 or info@manzurilaw.com to schedule a confidential legal consultation.”