LARA-MMFLA – ADVISORY BULLETIN
July 17, 2018
This advisory bulletin does not constitute legal advice and is subject to change. Licensees are encouraged to seek legal counsel to ensure their operations comply with the Medical Marihuana Facilities Licensing Act and associated
Emergency Rules.
30-Day Transition Period (Emergency Rule #20)
Emergency Rule 20 allows for a transition period of 30 calendar days during which marihuana product can be entered into the statewide monitoring system to ensure statewide tracking. These 30 days begin on the day a state operating license is issued to a licensee for the first time (the only exception is for additional licenses issued to the same license holder for a stacked license after a first license has already been issued).
Within those 30 days, a licensee shall:
- Comply with ALL testing requirements as prescribed by the act and rules, including moisture content, potency analysis, foreign matter inspection, microbial and mycotoxin screening, chemical residue, metals screening, residual solvents levels and water activity.
- Record all marihuana product in the statewide monitoring system and tag or package all inventory that has been identified in the statewide monitoring system.
The above requirements pertain to all marihuana and marihuana-infused products remaining in inventory at the time of licensure.
After the 30-calendar-day period, any marihuana product that has not been identified in the statewide system under these rules and the Medical Marihuana Facilities Licensing Act (MMFLA) is prohibited from being onsite at a marihuana facility.
A violation of this rule may result in sanctions and/or fines. At any time during this 30-calendar-day period, and thereafter, a marihuana facility is subject to inspection.
Additional information relating to the statewide monitoring system can be found in the This advisory bulletin does not constitute legal advice and is subject to change. Licensees are encouraged to seek legal counsel to ensure their operations comply with the Medical Marihuana Facilities Licensing Act and associated
Emergency Rules.
MMFLA Sections 501 and 502 provide that growers and processors must use a secure transporter to transport marihuana unless the facilities are within the same location and public roadways are not used.
Additionally, the MMFLA specifies that – prior to Dec. 31, 2018 – growers and processors have 30 days once their license is issued to transfer marihuana plants, seeds, and seedlings if they are lawfully possessed by an individual formerly registered as a primary caregiver who is an active employee of the grower or processor.
This 30-day period coincides with the 30-calendar-days given for licensees to enter items into the statewide monitoring system.
Komorn Law has represented numerous clients through the legal chaos of starting up a business in the Michigan Medical Marihuana Industry.
Contact Us For More Information.
800-656-3557
