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New York Cannabis: Distribution Licenses

As we previously broadly summarized on December 27, 2022 (here), in late December 2022, the Office of Cannabis Management (“OCM”) released its first proposed adult-use cannabis rules and regulation for New York (the “Proposed Regulations”). The official document is 282 pages, so we won’t cover every detail. But we will highlight the big-ticket items, significant issues that all applicants should be aware of, and the license application process as a whole. Also, keep in mind that the Proposed Regulations are still pending as OCM receives the final public comments to the Proposed Regulations.

One of the more nuanced portions of the Proposed Regulations relates to those applying for a distribution (or distributor) license and the do’s and don’ts once awarded a distribution license. First and foremost, a cultivator that has a processor license may apply for and obtain one distributor license. Additionally, those holding a conditional cultivation license shall be given priority by the OCM in review of its application for a distributor license.

New York cannabis distribution license – the do’s

Let’s start with some of the do’s for those holding a distributor license. The most obvious is that a distributor may acquire cannabis products from any duly licensed processor, possess

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