California to Add a New Type of Cannabis License, the Combined Activities License

by Omar Figueroa & Lauren Mendelsohn

November 22, 2024

 

Senate Bill 1064 has been signed into law and, effective January 1, 2025, will amend the cannabis regulatory framework in California by adding a new type of statutory license, the Combined Activities License (CAL).

The Combined Activities License (CAL) is defined as “a state license that authorizes two or more commercial cannabis activities at the same premises, with the exception of laboratory testing.”  See, amended Business and Professions Code Section 26001(m).  This new type of license will be designated as a Type 15 license. See, amended Business and Professions Code Section 26050(a)(23).

Starting in 2025, the license types will be:

Type 1—Cultivation; Specialty outdoor; Small.

Type 1A—Cultivation; Specialty indoor; Small.

Type 1B—Cultivation; Specialty mixed-light; Small.

Type 1C—Cultivation; Specialty cottage; Small.

Type 2—Cultivation; Outdoor; Small.

Type 2A—Cultivation; Indoor; Small.

Type 2B—Cultivation; Mixed-light; Small.

Type 3—Cultivation; Outdoor; Medium.

Type 3A—Cultivation; Indoor; Medium.

Type 3B—Cultivation; Mixed-light; Medium.

Type 4—Cultivation; Nursery.

Type 5—Cultivation; Outdoor; Large.

Type 5A—Cultivation; Indoor; Large.

Type 5B—Cultivation; Mixed-light; Large.

Type 6—Manufacturer 1.

Type 7—Manufacturer 2.

Type 8—Testing laboratory.

Type 10—Retailer.

Type 11—Distributor.

Type 12—Microbusiness.

Type 13—Cannabis event organizer.

Type 14—Processor.

Type 15—Combined activities.

The language of Senate Bill 1064 can be read below and downloaded here.

SB1064

 

The analysis by the California Senate dated August 27, 2024 can also be read below and downloaded here.

202320240SB1064_Senate Floor Analyses

 

Similarly, the analysis by the California Assembly dated August 22, 2024 can also be read below and downloaded here.

202320240SB1064_Assembly Floor Analysis

 

Notably, the California Assembly analysis points out an advantage that this new license category will have for operators holding multiple licenses:

Under this new license category, the DCC would be authorized to issue a single license to unique businesses conducting several activities at one location, similarly to how earlier iterations of the bill intended for the premises licensing process to function. While under existing law, each of these businesses is required to apply for multiple licenses from the DCC, each of which must be separately obtained and maintained, this bill would allow for the DCC to instead issue a single license.

It is anticipated that operators will be able to consolidate operations and increase efficiency and profitability once they unlock the potential of the Combined Activities License.