Processor Guidance Only & FAQs
The following guidance is provided by the Maryland Cannabis Administration (MCA) to assist cannabis licensees comply with State laws and regulations governing the cannabis industry. This document is not legal advice. It is meant to highlight operational changes for licensed processors. Please consult an attorney if you have any questions regarding the legal requirements that apply.
Highlighted updates
Recent updates to regulations make certain changes for processor licensees, with an anticipated effective date of April 14, 2025, including but not limited to the following:
- If a licensee finds evidence of theft or diversion, they must report the finding to MCA within 1 business day but are no longer required to notify local law enforcement.
- Establishes a new process by which processors may request MCA’s approval of new/novel cannabis product types not currently authorized in Maryland but lawfully produced in another jurisdiction. MCA intends to fully implement this process beginning June 1, 2025. Further guidance is forthcoming.
- Specifies labeling language requirements for edible cannabis products meant for R&D use. Each product must now be labeled with the statement: “CAUTION: THIS PRODUCT IS FOR APPROVED R&D USAGE ONLY.” MCA is advising that industry implement this change on or before June 1, 2025.
Products
Liquid edibles
For the purposes of producing a liquid edible product, one single container is a single serving of product, and it may not contain more than 10 milligrams (mg) of tetrahydrocannabinol (THC). Liquid edibles must also comply with the requirements for other edible products in terms of production, packaging, and labeling. This includes limiting the manufacture of these products to facilities with a valid edibles permit.
Product reservations
The following products may only be sold to qualifying patients and registered caregivers:
- Concentrated cannabis products with a total product weight greater than 1 gram
- Edible cannabis products, capsules, and tinctures containing more than 10 mg THC per serving or 100 mg THC per package
Adult use consumers may purchase:
- Cannabis vaporizing devices (e.g., vapes)
- Concentrated cannabis products with a total weight of 1 gram or less
- Infused flower and pre-rolls of any product weight
- Infused non-edible cannabis products
- Home cultivation products
- Usable cannabis products (e.g., flower, pre-rolls)
- Edible cannabis products, capsules, and tinctures containing up to 10 mg THC per serving or 100 mg of THC per package
Hemp
Hemp-derived products containing more than 0.5 mg THC per serving or 2.5 mg THC per package may only be sold by licensed dispensaries if they have been manufactured, processed, and tested in accordance with MCA regulations. (Note: THC includes any THC isomers or derivatives, including delta-8 and delta-10). These products may only be displayed or offered for sale in the restricted area of a dispensary. Licensed processors may obtain hemp and hemp-derived products from registered hemp growers.
UPDATED! Discrepancy, theft, and diversion reporting
If a licensee identifies a discrepancy between the inventory of stock and the seed-to-sale tracking system outside or normal weight loss, they must begin an investigation of the discrepancy within 1 business day. If a discrepancy is not resolved within 30 business days, the licensee must submit a report of their investigation to MCA. Failure to report an unresolved discrepancy may be used as evidence of diversion.
If a licensee finds evidence of theft or diversion, the licensee must report the theft or diversion to the Administration within 1 business day.
Within 30 business days of discovering the theft, diversion, or unresolved discrepancy, the licensee must:
- Complete an investigation;
- Amend its standard operating procedures, if necessary; and
- Send a report of the investigation to the MCA.
Other operational considerations
- For packaging and labeling guidance, please refer to COMAR 14.17.18 Finished Product Packaging, as well as the General Information and Packaging and Labeling Guidance documents on the Laws and Regulations page.
- Visitors to any operational areas of the premises must be continuously, physically supervised at all times while on the premises. Video surveillance does not suffice for meeting supervision requirements. For growers and processors, individuals who are on the premises for the narrow purposes of package delivery, or other services that do not involve areas of the premises used for cannabis cultivation or processing are exempted from this requirement.
Processor FAQs
The MCA has announced the names of 15 Pre-approved Processors, however, no actual final licenses to process medical cannabis have been issued. The pre-approved entities are current working through Stage Two of the licensing process, which includes extensive background investigations and regulatory requirements. The MCA will vote for licensure in a public meeting once compliance with the regulatory requirements is complete.
A processor will process usable medical cannabis into medical cannabis concentrates, or medical cannabis-infused products.
A cannabis-infused product means an oil, wax, ointment, salve, tincture, capsule, suppository, dermal patch, cartridge or other product containing medical cannabis concentrate, or usable cannabis that has been processed so that the dried leaves and flowers are integrated into other material.
Yes, as of April 2021, MCA licensed processors can process cannabis into edible products.
Yes. All products will be subject to independent laboratory testing to assure that the medicine is pure and meets the processor's specifications.
Yes; all processors in Maryland will be subject to inspection.
Processors will contract with one or more licensed growers to obtain medical cannabis to process. They will need to follow inventory controls specified in the regulations, and in the standard operating procedures of the processors and growers.
No.
No.
Processors will contract with dispensaries to distribute their products. They will need to follow inventory controls specified in the draft regulations, and in the standard operating procedures of the processors and dispensaries.
Yes. The MCA has the authority to inspect processors on an ongoing basis. In the case of a major deficiency or a failed inspection, the MCA may discipline the licensee, including by revoking the processor's license.
Yes. The regulations list the requirements for packaging and labeling of medical cannabis finished products.
Evidence that the licensed premises comply with all zoning planning requirements is required in Stage Two of the application process.
Yes. In so far as the premises comply with local zoning and planning codes, and are constructed and organized to maintain security, cleanliness, safety and the required inventory controls, a grower facility and a processor facility may be located on the same property.
Yes, so long as the building is constructed so that the processor and dispensary are two completely different units, each with an address which is independent of the other, they may share one common roof. However, the two premises must each have a separate means of ingress and egress, and under no circumstances may the two premises have any means of internal ingress or egress between the dispensary or processor.
Yes, parties or entities who wish to operate a growing and processing facility, as well as a dispensary, must submit separate license applications for each facility. The MCA may award separate licenses for each operation.
No; the licensee must provide required agent ID cards to anyone transporting cannabis.
A transportation agent is not required to hold a Maryland driver's license.
Yes; however, the agent would need to register multiple registrations at a charge $200 per registration.
Yes. A person can be an owner in an entity that obtains a license for each class of activity, and therefore would be an agent for each licensee.
A resident is one who lives in Maryland. A person may demonstrate Maryland residency by providing one or more of the following: 1) Most recent Maryland tax return; 2) Most recent Maryland property tax bill; 3) Local gas and electric bill that is no more than 4 months old; 4) Valid Maryland Driver’s license; or 5) Another record that corroborates the Maryland residency.
A business may be registered to conduct business in the State of Maryland. They may be either an out-of-state company which is establishing its Maryland existence, and its principal place of business may or may not be Maryland.
Alternatively, the business entity could be a “grass roots” company, meaning a business that was founded in Maryland and maintains its principal place of business in Maryland. In either eventuality, a business entity may demonstrate its ability to conduct business in the State of Maryland by providing the following: 1) Articles of Incorporation or Articles of Organization; 2) Certificate of Status (also referred to as a Certificate of Good Standing); and 3) Identification of the Resident Agent.
While any subcontractor may be registered with the MCA, the subcontractor is not required to register with the MCA. However, should the subcontractor not be registered with the MCA, then, they are considered a visitor to a non-public area, and the Grower, Processor, or Dispensary will be required to
- log the visitor in and out of the premises;
- retain a photocopy of the visitor’s government-issued identification;
- continually visually supervise the visitor while on the premises; 4) ensure that the visitor does not touch any plant or medical cannabis; and
- maintain a log of all visitors to non-public areas for two years.
Be Informed. Be Responsible. BeCannabisSmart.
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