Cannabis Law Introduces New Licensing Regime

Michael Roche


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.





Cannabinoid Hemp and Hemp Extract


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


Adult-Use Processor License


Cannabinoid Hemp Processor License


Adult-Use Distributor


Retail Dispensing

Adult-Use Retail Dispensary License


Registered Organization

Cannabinoid Hemp Retailer License

On-Site Consumption

Adult-Use On-Site Consumption License


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.

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