The New Jersey Cannabis Regulatory Commission began accepting applications for wholesale, distribution, and delivery of recreational cannabis business licenses…
The New Jersey Cannabis Regulatory Commission (CRC or Commission) began accepting applications for wholesale, distribution, and delivery of recreational cannabis business licenses on September 27, 2023. The new licensing opportunities represent just one of several key changes impacting New Jersey’s growing cannabis industry.
On September 8, 2023, the CRC voted to relax restrictions on edibles, clearing the way for additional ingestible products, including cannabis infused food and beverages, to be offered by both adult-use and medical dispensaries. Under the new guidance, cannabis businesses must satisfy a number of requirements, which include ensuring products are made uniformly, providing food safety training to employees involved in manufacturing, and complying with strict packaging and labeling requirements.
New Jersey Cannabis License Application Schedule
New applicants or existing operators looking to integrate their cannabis business vertically will be able to apply for business licenses in the three additional classes over the coming months. These new licensing opportunities include:
A Class 3 Cannabis Wholesale: This license allows the holder to store, buy, and sell bulk cannabis and cannabis products.
A Class 4 Cannabis Distribution: This license allows the holder to transport bulk cannabis and cannabis products between cannabis cultivators, manufacturers, or retailers within New Jersey.
A Class 6 Cannabis Delivery: This license allows the holder to transport retail-purchased cannabis and cannabis products to consumers.
Depending on your entity status, you may be able to submit your application now. On September 27, 2023, the CRC began accepting applications for Class 3 Wholesaler, Class 4 Distributor, and Class 6 Delivery Service licenses from Social Equity Businessesonly. These businesses will have an exclusive 90-day application period.
Beginning on December 27, 2023, at 9 a.m. ET, the CRC will also begin accepting applications for Class 3 Wholesaler, Class 4 Distributor, and Class 6 Delivery Service licenses from Diversely Owned Businesses. Beginning on March 27, 2024, at 9 a.m. ET, the Commission will begin accepting applications for Class 3 Wholesaler, Class 4 Distributor, and Class 6 Delivery Service licenses from all other applicants.
Importance of Understanding the Application Requirements
For entities interested in pursuing a New Jersey cannabis license, it is imperative to understand all of the requirements and work with experienced counsel when preparing your application. According to data from the CRC, as of August 2023, almost 1,800 of the 2,014 applications received by the CRC resulted in cure letters notifying applicants of application deficiencies. The CRC says that the most common reasons for cure letters are:
Entity Disclosure Form (EDF) Issues: Entities must provide disclosure forms for license applicants and any related entities providing financial or management support.
Persons of Interest (POI) issues: Applicants must be sure to sign the necessary documents, including the statement of truth and waiver of liability, and have them notarized. Additionally, you must correctly identify the people involved and provide their Personal History Disclosure (PHD). It is also imperative to provide all the requested data and complete the PHDs.
Tax Return issues: Applicants must provide their latest state and federal tax return. If submitting returns from a previous year, you must also provide proof of any extensions obtained.
Government Identification Issues: Applicants must provide valid government IDs that is current at the time of submission.
Business Certification Issues: Diversely-owned businesses’ certification must be up-to-date on New Jersey Selective Assistance Vendor Information (NJSAVI) and in the name of the correct applicant.
Key Takeaways
There are many new opportunities on the horizon in New Jersey’s cannabis industry. However, to fully take advantage of them, you must be able to navigate the licensing process. To avoid unnecessary delays, it is always advisable to work with an experienced cannabis attorney.
Scarinci Hollenbeck has helped clients successfully obtain cannabis licenses in New Jersey for several years. We encourage you to contact Scarinci Hollenbeck’s Cannabis Law Group for more information regarding applications, CRC regulations, and other legal compliance issues.
If you have questions, please contact us
If you have any questions or if you would like to discuss the matter further, please contact Dan McKillop, or the Scarinci Hollenbeck attorney with whom you work, at 201-896-4100.
This article is a part of a series pertaining to cannabis legalization in New York, New Jersey and the United States at large. Prior articles in this series are below:
Disclaimer: Possession, use, distribution, and/or sale of cannabis is a Federal crime and is subject to related Federal policy. Legal advice provided by Scarinci Hollenbeck, LLC is designed to counsel clients regarding the validity, scope, meaning, and application of existing and/or proposed cannabis law. Scarinci Hollenbeck, LLC will not provide assistance in circumventing Federal or state cannabis law or policy, and advice provided by our office should not be construed as such.
Are Stay Interviews the Key to Retaining Top Talent?
Retaining top talent continues to be one of the greatest challenges facing employers today. Even in an employer’s market, the loss of a key employee can disrupt operations and result in significant costs. While compensation plays a role, long-term retention often depends on workplace culture, communication, and employee engagement. One increasingly popular strategy for improving […]
Secured transactions form the backbone of a wide range of business dealings, including business loans, mortgages, and inventory financing. Because the stakes are often high and relatively minor oversights can have drastic consequences, lenders and borrowers should thoroughly understand how to form an enforceable security agreement that protects their legal rights. What Is a Secured […]
Don’t Cash a “Paid in Full” Check Without Understanding the Legal Implications
Cashing a check marked “paid in full” can be a risky endeavor, particularly if you don’t fully understanding the legal implications. If you are owed more than the amount of the check you accept and deposit, you may waive your right to collect the full disputed amount. That is why you should consider either rejecting […]
Changes to Qualified Small Business Stock Will Benefit Startup Founders and Investors
The One Big Beautiful Bill Act of 2025 (OBBBA) significantly impacts federal taxes, credits, and deductions. A key change relating to Qualified Small Business Stock (QSBS) allows greater tax-free gains for investments in startups and other qualifying small businesses. Company founders and other investors should understand how the enhanced tax strategy works or risk missing […]
Corporate Consolidation and Antitrust Issues in Mergers
Corporate consolidation involves two or more businesses merging to become a single larger entity. The result is often a stronger and more competitive company that can better navigate today’s competitive marketplace. What Is Corporate Consolidation? Corporate consolidation closely resembles a basic merger transaction. The primary difference is that a consolidation creates an entirely new business […]
Business law plays a critical role in nearly every aspect of running a successful enterprise, from negotiating a commercial lease to drafting employee policies to fulfilling corporate disclosure obligations. Understanding what is business law and your legal obligations can help your business run smoothly and build productive relationships with clients, business partners, regulators, and others. […]
No Aspect of the advertisement has been approved by the Supreme Court. Results may vary depending on your particular facts and legal circumstances.
Sign up to get the latest from our attorneys!
Explore What Matters Most to You.
Consider subscribing to our Firm Insights mailing list by clicking the button below so you can keep up to date with the firm`s latest articles covering various legal topics.
Stay informed and inspired with the latest updates, insights, and events from Scarinci Hollenbeck. Our resource library provides valuable content across a range of categories to keep you connected and ahead of the curve.
Let`s get in touch!
Sign up to get the latest from the Scarinci Hollenbeck, LLC attorneys!
