The “Cannabis Regulation and Taxation Act” should take effect on the first of April,
2020. There are plenty of new business opportunities in the New York cannabusiness
space and our legal team is gearing up for these exciting new ventures. These
businesses will need to be regulated by the Division of Alcoholic Beverage Control’s
new State Office of Cannabis Management. Our legal team is experienced representing
businesses in front of the State Alcoholic Beverage Control’s State Liquor Authority and
is well-positioned to hit the ground running for licensing and other regulatory issues. The
law anticipates that the same qualifications for on-premises consumption of alcoholic
beverages (restaurants and bars) will apply to retail establishments for on-premises
cannabis consumption. The list of available permits simulates the permit structure for
Available permits will include:
1. Industrial cannabis permit to purchase non-consumable cannabis for (a) apparel,
energy, paper, and tools; (b) scientific, chemical, mechanical and industrial products; or
(c) any other industrial use as determined by the State Office of Cannabis Management.
2. Nursery permit to produce clones, immature plants, seeds, and other agricultural
products used specifically for the planting, propagation, and cultivation of cannabis, and
to sell such to licensed adult-use cultivators, registered cooperatives, and certified
patients or their designated caregivers.
3. Solicitor’s permit to offer for sale or to solicit orders for the sale of any cannabis
products, medical cannabis and/or hemp cannabis, as a representative of a registered
cooperative or licensee governed by the State Office of Cannabis Management.
4. Broker’s permit to act as a broker in the purchase and sale of cannabis products,
medical cannabis and/or hemp cannabis for a fee or commission, for or on behalf of a
person authorized to cultivate, process, distribute or dispense cannabis products,
medical cannabis or hemp cannabis within New York.
5. Trucking permit to allow for the trucking or transportation of cannabis products,
medical cannabis or hemp cannabis by a person other than a registered cooperative or
licensee governed by the State Office of Cannabis Management.
6. Warehouse permit to allow for the storage of cannabis, cannabis products, medical
cannabis or hemp cannabis at a location not otherwise registered or licensed by the
State Office of Cannabis Management.
7. Delivery permit to authorize licensed adult-use cannabis dispensaries to deliver adult-
use cannabis and cannabis products directly to cannabis consumers.
8. Cannabinoid permit to sell cannabinoid products derived from hemp cannabis for off-
9. Temporary retail cannabis permit to authorize the retail sale of adult-use cannabis to
cannabis consumers, for a limited purpose or duration.
10. Caterer’s permit to authorize the service of cannabis products at a function, occasion
or event in a hotel, restaurant, club, ballroom or other premises, which shall authorize
within the hours fixed by the State Office of Cannabis Management, during which
cannabis may lawfully be sold or served on the premises in which such function,
occasion or event is held.
11. Packaging permit to authorize a licensed cannabis distributor to sort, package, label
and bundle cannabis products from one or more registered cooperative or licensed
processors, on the premises of the licensed cannabis distributor or at a warehouse for
which a permit has been issued by the State Office of Cannabis Management.
12. Miscellaneous permits to purchase, receive or sell cannabis, cannabis products or
medical cannabis, or receipts, certificates, contracts or other documents pertaining to
cannabis, cannabis products, or medical cannabis, in cases not expressly provided for
by the law, when in the judgment of the State Office of Cannabis Management it would
be appropriate and consistent with the policy and purpose of the law.
Please feel free to contact our team if you are a cannapreneur and want to discuss a
new business opportunity in the cannabusiness space.