December 8, 2017


Office of Administrative Law
Via Email
State of California
Department of Public Health
State of California


RE: Public Comments on Licensing of Commercial Cannabis Cultivators


Dear Office of Administrative Law:

The Cannabis Corporate Law Firm represents a variety of commercial cannabis stakeholders in furtherance of California’s goal in legalizing and regulating commercial cannabis activity in the state of California.  We are delighted to have had the opportunity to participate in many of the workshops and conferences sponsored by the Bureau of Cannabis Control, Department of Food and Agriculture and the Department of Public Health.

To that end, please know that the goal of The Cannabis Corporate Law Firm in submitting these comments is to further the legitimate business interests of industry stakeholders, in this case commercial cannabis manufacturers, and to aid in establishing a practical and fair system of regulation for the industry.

To that end, please find our comments regarding specific sections within the California Code of Regulations below.

  1. 40102 (a)(4)(B) – “for” should be “of”
  2. 40102 (c)(3)- use of “only”
  3. 40102 (b)- need to add the word “or” in last sentence.
  4. 40300 overregulates the edible industry. Many of the products that are sold are attractive to consumers because they are readily identifiable.   Prohibiting candy, cookies, drinks, teas and other edibles that can be construed as either attractive to children or mistaken for commercially available foods without cannabis unduly restricts the market.  Moreover, the edible industry is well established in California.  This regulation could inadvertently put a number of small businesses out of business.  More narrowly tailored regulations are recommended.

We thank you in advance for careful consideration of our comments.  Please feel free to contact our office if you would like to discuss any of these issues further.


Dana Leigh Cisneros, Esq.