On April 8, 2020, The Michigan Marijuana Regulatory Agency (“MRA”) issued updated guidance relating to transfers of marijuana between equivalent medical and recreational marijuana license holders. As of that date, the MRA will no longer permit any equivalent license transfers that would result in caregiver-derived marijuana entering the adult-use recreational marijuana market. In addition, this new bulletin clarifies that adult-use marijuana establishments may not transfer products to medical marijuana facilities.
This updated guidance eliminates the possibility that caregiver product will continue to enter the adult-use market. Medical marijuana facilities can continue to receive marijuana flower from caregivers, although this remains subject to change at any time.
Although transfers between caregivers and facilities are still permitted, this latest guidance could be viewed as a first step by the MRA to create a clear divide between caregiver product and licensed product. As such, both medical marijuana facilities and caregivers would be wise to begin the planning necessary to ensure a steady supply of product derived from non-caregiver sources.
If you are a licensed marijuana facility that needs assistance in complying with MRA guidance, or in defending your license against an MRA violation, please contact our experienced cannabis law team as soon as possible. At Grewal Law PLLC, we have an extensive practice relating to cannabis licensure and transfer, and we can help businesses remain complaint under the new guidance.
Contact us today at (888) 211-5798 to schedule a consultation. For more information on transfers of product from caregivers to facilities, visit here.