
Daniel T. McKillop
Partner
201-896-7115 dmckillop@sh-law.comFirm Insights
Author: Daniel T. McKillop
Date: November 12, 2021
Partner
201-896-7115 dmckillop@sh-law.comThe New Jersey Cannabis Regulatory Commission (CRC) plans to issue and begin accepting applications for adult-use cannabis license applications for Class 1 cultivator licenses, Class 2 manufacturer licenses, and testing laboratory licenses on December 15, 2021. The CRC will issue and begin accepting applications for Class 5 Retailer licenses on March 15, 2022.
On November 10, 2021, the CRC published a Notice of Application, which outlines eligibility requirements, prioritization processes, application requirements (including a list of necessary forms and supporting documents), scoring methodology, and approval criteria regarding cultivator, manufacturer, and testing laboratory licenses. While potential applicants should review the Notice of Application in its entirety, below are a few key takeaways:
The CRC has not yet announced when it will begin applications from entities interested in a Class 3 Wholesaler, Class 4 Distributor, or Class 6 Delivery license. In addition, the CRC has yet to provide a date for medical marijuana dispensaries looking to transition to adult-use sales.
The Notice also provides no information about the process by which existing medical cannabis ATCs are to certify their inventory to the CRC in order to operate in the adult-use industry. It does, however, state that “speed of implementation” is a factor in awarding cultivator licenses. This favors the existing ATCs who are already operating, as they will be able to convert to adult-use operation after certifying their inventory to the CRC. These facts, together with the statutory deadline to start adult-use sales by February 2022 and the fact that adult-use retailer applications will not be accepted until March 15, 2022 seems to confirm that the existing medical ATCs will sell the first adult-use cannabis in New Jersey.
After a slow start, the New Jersey adult-use cannabis market is poised to evolve quickly. For businesses interested in applying for any class of cannabis license, it is important to have a knowledgeable team assembled to navigate the application process and complex regulatory regime. 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 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 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.
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