Micro Dispensary Guidance

About

The following guidance is provided by the Maryland Cannabis Administration (MCA) to assist cannabis licensees in complying with State laws and regulations governing the cannabis industry. This document is not legal advice. It is intended to outline operational guidelines for micro dispensaries. Please consult an attorney if you have any questions regarding the applicable legal requirements. 

Micro dispensary license overview 

A micro dispensary license is authorized to deliver cannabis to residences and medical facilities within an authorized service area. A micro dispensary licensee is not authorized to operate a physical storefront. A micro dispensary may employ no more than 10 registered agents, including owners. 

See COMAR 14.17.07.07 and 14.17.12.03; Alcoholic Beverages and Cannabis § 36401(c)(2)(iii)

A micro dispensary may choose one or more of the following models to operate their business: 

1. Own storage model: The business possesses up to three of its own storage facilities for cannabis inventory storage;
2. Grower/processor storage sharing: The business stores its cannabis inventory in a physically separate unit with a grower or processor premises; 
3. Standard dispensary storage: The business stores its cannabis inventory in a physically separate unit within a standard dispensary’s secure room; and 
4. Delivery partnership with standard dispensary: The business does not have its own inventory; delivers on behalf of one or more standard dispensaries. 

A micro dispensary may choose a combination of these models, provided its cannabis inventory is not stored in more than three places. 

Authorized service area 

An authorized service area is the region in Maryland where the micro dispensary license was awarded, i.e., Central, Eastern, Southern, or Western, and where it may deliver cannabis or cannabis products. A micro dispensary may store its inventory outside of the authorized service area. COMAR 14.17.12.03C(1).  It may also transit outside the service area to stock or restock inventory, or when it is most efficient, as part of a planned delivery route. COMAR 14.17.07.07D(5), 14.17.12.03D(2). Transit outside of Maryland is never permitted. COMAR 14.17.12.03C(1) & D(2). 

Beginning July 1, 2026, a micro dispensary may petition to expand its authorized service area in the manner prescribed by the MCA. See COMAR 14.17.07.07D. 

Storage facility options 

A micro dispensary licensee may store inventory at a facility it controls and operates or a facility operated by another licensee. Depending on where a micro dispensary stores its inventory, different requirements apply (see table below). 

A micro dispensary may use up to three storage facilities to store their inventory. They may choose to store their inventory in multiple of their own storage facilities or a mixture of their own and other licensees’ storage areas. Storage facilities do not need to be located within the micro dispensary’s authorized service areas, see COMAR 14.17.07.07D(5), but must meet all requirements in COMAR 14.17.12.03C or COMAR 14.17.12.02G, whichever applies. 

Note: An arrangement between a micro dispensary and a standard dispensary does not count toward a micro dispensary’s three permitted cannabis storage facilities. 

Can a micro dispensary’s delivery vehicle serve as storage? 

No. A micro dispensary's storage facility may not be a delivery vehicle. COMAR 14.17.12.03G prohibits dispensing cannabis or cannabis products from the storage facility premises or transporting cannabis not associated with an active invoice, order, or product manifest. Additionally, a micro dispensary licensee may not carry cannabis or cannabis products in the delivery vehicle with a value in excess of $5,000 at any time. The value of cannabis goods shall be determined using the current retail price of all cannabis or cannabis products carried by or within the delivery vehicle. See COMAR 14.17.12.03H. 

Adding a new location or delivery partnership 

To add a new inventory storage location, whether it is controlled by the micro dispensary or another licensee, the micro dispensary must obtain approval from the MCA prior to using it for cannabis operations. To notify MCA about the new location, a micro dispensary must complete the Request for Modification. 

Requirements for micro dispensaries sharing storage with other licensees 

See the list above for comprehensive storage area regulations. If the micro dispensary stores inventory in a facility controlled by a grower, processor, or standard dispensary, each licensee’s inventory must be physically separated. For example, a micro dispensary could store its inventory in a vault within a standard dispensary operations zone. If the licensees were sharing inventory in the same vault, they would need to arrange the vault so that the micro and standard dispensaries can only access their respective inventories, e.g. two locked cages in one room that contain each licensee’s inventory. The micro dispensary may only have access to the micro dispensary’s inventory, and the host licensee may only have access to the host licensee’s inventory. Each licensee must use security alarm systems to prohibit access to storage areas by anyone other than their own agents. Each licensee must have independent and unique access to its own video surveillance and security alarm systems.  

A host licensee may use one alarm system for its entire premises provided it has unique zones for each area required to be protected by the alarm system. For example, a grower licensee that hosts a micro dispensary for inventory storage may use one overall security alarm system with unique zones for different areas, including a unique zone for the micro dispensary’s designated storage area.  

Agent badging considerations  

MCA strongly recommends that a micro dispensary’s agents be dually badged if they will be entering any area of another licensee’s premises that is used for cannabis operations. A guest at a licensed premises who is not a registered agent employed by that licensee would need to be treated as a visitor in accordance with COMAR 14.17.10.07, 14.17.11.17, and 14.17.12.04N, whichever applies, to be admitted to an area of the premises used for cannabis operations.  

Delivery operations 

COMAR 14.17.12.03D establishes delivery requirements for a micro dispensary. Deliveries must be made: 

• By registered agents with MCA-issued badges.
• Between 8:00 AM and 11:00 PM 
  • No deliveries may occur after 11:00 PM; delivery of the product is an element of a sale. 
  • Any order received that cannot be fulfilled before 11:00 pm may not be fulfilled until the following day 
• Only to qualifying patients, caregivers, or adults 21+ with a valid ID. 
• Using secure, unmarked vehicles equipped with GPS, lockboxes, and cameras with no more than $5,000 in cannabis products per vehicle, per trip.
• Using a body camera during transport and delivery of cannabis to the consumer.  
  • Licensees can use any type of camera that can capture, record, and produce shareable video records that can be inspected by the MCA upon request 
  • Licensees should obtain consent for a delivery recipient to be captured on video during delivery 
  • If a customer, registered patient, or caregiver does not want to be recorded during the delivery then the licensee should decline the sale.  

See COMAR 14.17.12.03D, .08, .09

Inspections 

MCA’s general inspection procedures are outlined in [inspections doc] on the MCA website. The MCA may inspect all of a cannabis licensees’ premises and operations to ensure conformity with its application, State law, and regulations. An MCA inspection may include, but is not limited to: 

• Vehicles; 
• Standard operating procedures as required in COMAR 14.17.12.11A; 
• All rooms and containers in which cannabis will be stored; 
• Video surveillance and security alarm system; 
• Delivery platforms for online, phone, or other remote orders; 
• Records and anywhere records are stored;and  
• Cannabis.  

See COMAR 14.17.14.03E and F.  

Note: The MCA will not issue a cannabis license to a micro dispensary until the Administration has inspected and deemed compliant at least one delivery vehicle that will be used by the micro dispensary. 

Micro dispensary inspections will vary based on the selected business model and number of storage facilities. If a micro dispensary stores its inventory in its own or another licensee’s storage facility, the MCA inspection will include but not be limited to delivery vehicles, storage areas, all aspects of the shared space arrangement, security and surveillance systems, and anywhere records are stored. For a micro dispensary that does not have its own inventory, an MCA inspection will include all delivery vehicles, surveillance systems, any contracts between licensees, and anywhere records are stored.  

Vehicle inspections 

MCA will inspect all vehicles a micro dispensary intends to use for delivery to ensure compliance with COMAR 14.17.12.03D(10). Cannabis must be delivered in enclosed vehicles that: 

• Have and display a current vehicle registration; 
  • There is no requirement that a vehicle be owned by or registered to a micro dispensary licensee. 
• Are insured as required by law; 
• Are equipped with: 
  • A global positioning system (GPS) that enables the micro dispensary to monitor the vehicle’s location for the entirety of its delivery routes;
  • Locked and secure storage containers anchored to the inside of the vehicle; 
  • A motion-activated video-surveillance system that captures activity around all storage containers that contain cannabis or cannabis products; 
• Conceal storage containers so they are not visible or identifiable from outside of the vehicle; and 
• Do not display any sign or illustration related to cannabis, cannabis products, or a cannabis licensee. 

MCA will conduct vehicle inspections at the storage location or another mutually agreeable location where and when all vehicles can be inspected at the same time. All delivery vehicles must be inspected and deemed compliant by the MCA prior to use.   

Requirements for cannabis storage containers in vehicles 

Cannabis storage containers must be locked shut in a manner which will prevent the contents from falling out of the containers if they are dropped or shift in a collision. Micro dispensaries may choose between two methods for securing the container inside the vehicle. The containers must be hidden from view from outside the vehicle and inaccessible to vehicle occupants while the vehicle is in transit: 

1. A secure lockbox (key or combination needed) bolted from within to the body of the vehicle; or 
2. Plastic containers zip-tied closed, secured in a locked area, i.e. partitioned, caged, or in a trunk with a supplemental drum-style padlock. Examples: In a sedan, this could be the locked trunk with a supplemental drum style lock. In a cargo van, this could be the vehicle door locks and a locked cage within the cargo area, OR just the factory vehicle door locks and a supplemental drum-style lock installed on each door that accesses the cargo area. 

Adding new vehicles and storage locations 

A micro dispensary must submit the Request for Modification form and obtain approval prior to initiating any of the following business changes: 

• Adding a new vehicle;
• Establishing a new storage facility for cannabis inventory, whether its own or shared with another licensee.  

All vehicles and storage locations must be inspected and approved by MCA prior to use. 

Standard operating procedures (SOPs)

Micro dispensaries must establish and implement SOPs for all aspects of operations, including but not limited to inventory control, packaging, labeling, receiving, delivery, green waste, and security. The security SOP should include the micro dispensary’s plan for video surveillance review. Licensees must train agents on all SOPs and make SOPs available for inspection by the MCA upon request. See COMAR 14.17.12.11A. 

Inventory compliance 

Micro dispensaries must use MCA’s seed-to-sale tracking system, METRC (Marijuana Enforcement Tracking Regulation and Compliance), to track its stock of cannabis from the time it is received by the micro dispensary to the time it is delivered or dispensed to another licensee, qualifying patient, registered caregiver, or adult-use consumer. Daily logs of all inventory, transfers, manifests, and sales must be maintained in METRC. See COMAR 14.17.09.03. 

Frequently asked questions

MCA encourages early and continuous communication regarding inspection readiness, operational challenges, and compliance solutions.