With the new cannabis law, comes a new licensing regime. Borrowing from the New York State Liquor Authority’s three-tier system under which alcohol beverage licensing has operated for nearly a century, cannabis licensing is generally divided into five types of activities: cultivation, processing, distribution, retail dispensing, and on-site consumption. Unlike the early days of alcohol beverage licensing, cannabis licensing will allow limited cross-over between different activities.
The following chart provides a brief overview of the various licenses available and the activities they permit.
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Adult-Use |
Adult-Use/Medical |
Medical |
Cannabinoid Hemp and Hemp Extract |
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Cultivation |
Adult-Use Cultivator License |
Adult-Use Cooperative License Microbusiness License |
Registered Organization Adult-Use Cultivator Processor Distributor Retail Dispensary License |
Registered Organization Adult-Use Cultivator Processor and Distributor License |
Hemp Grower’s Authorization |
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Processing |
Adult-Use Processor License |
Cannabinoid Hemp Processor License |
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Distribution |
Adult-Use Distributor |
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Retail Dispensing |
Adult-Use Retail Dispensary License |
Registered Organization |
Cannabinoid Hemp Retailer License |
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On-Site Consumption |
Adult-Use On-Site Consumption License |
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In addition to those listed above, there are several licenses for specific transactions like nursery and delivery licenses.
Each license comes with certain rights and limitations. Because of the limitations on each license, it is imperative that a prospective cannabis business obtains the right license for the operations it intends to conduct.
In the coming weeks, we’ll take a deeper dive on the various activities and the individual licenses. We’ll specifically cover what each license permits and any limitations that are placed on certain licenses. In the meantime, if you would like more information on the licenses summarized above, please contact a member of our Cannabis practice group at 585.232.6500 or 716.853.1616.