Reminder: Colorado Medical Marijuana Vertical Integration Requirements will be Eliminated July 1, 2019
Jun 17, 2019
Have you notified the MED of which OPC license you are keeping?
The passage of HB18-1381 left Colorado medical marijuana businesses in a transitional period between the previous sourcing model and full elimination of the vertical integration requirements.
Currently, medical marijuana centers (MMCs) may only sell medical marijuana grown in their associated medical marijuana optional premises cultivation (OPC) facilities and can accept transfers of no more than 50% of their total on-hand medical marijuana inventory, excluding trim, from another licensed MMC, OPC or medical MIP. MMCs may only transfer up to 50% of their total on-hand medical marijuana inventory, excluding trim, to another MMC, OPC or medical MIP.
Effective July 1, 2019, these vertical integration requirements will be eliminated.
Colorado Marijuana Enforcement Division Rule M 507 sets out the production management rules for OPCs, effective July 1, 2019:
- OPC licenses with identical ownership and located at one licensed premise are subject to mandatory collapse.
- OPC licenses with common, but not identical, ownership may continue operating all OPC licenses that existed at that licensed premises prior to July 1, 2019. Both license types will be assigned a production management class for their OPC licenses.
- Production management classes are as follows:
- Class 1: 1-500 plants
- Class 2: 501-1500 plants
- Class 3: 1501-3000 plants
- The maximum authorized plant count above 3000 plants shall increase in one or two increments of 3000 plants
Prior to June 30, 2019, licensees subject to mandatory collapse are required to notify the MED which OPC license they desire to keep. The surviving OPC license will remain active after July 1, 2019, and all other OPC licenses will be surrendered effective July 1, 2019.
If you have questions regarding the MED's instructions, we can help point you in the right direction. Send an email to firstname.lastname@example.org or call 303-860-4501.