The CCC’s new rules create two types of delivery licenses. A “marijuana delivery operator” can purchase marijuana and finished marijuana products at wholesale from cultivators, craft marijuana cooperatives, and marijuana product manufacturers and microbusinesses and sell and deliver from their own warehouses to consumers, but cannot repackage marijuana products or operate a retail store location. A “marijuana courier” can charge a fee to deliver marijuana products from retailers but cannot make retail sales to consumers or purchase finished marijuana products at wholesale.
Holders of either type of license can make contractual arrangements with online platforms that have been approved by the CCC. However, the technology platforms may not own or directly control, or share profits with, a delivery licensee.
The marijuana delivery operator licenses and the marijuana courier licenses will be exclusively available to social equity and economic empowerment applicants for at least three years. The CCC also established limits on the number of delivery and retail licenses that a person or entity may hold, in order to avoid monopolies.
The CCC has been accepting applications for marijuana courier licenses for several months. According to published reports, the CCC will open applications for marijuana delivery operator licenses later in January.
Partridge Snow & Hahn’s Cannabis Advisory Practice Blog provides updates on marijuana law and policy, covering some of the risks and opportunities in the industry, and makes recommendations regarding best practices. If you are interested in receiving these updates via email, please submit the form below: