California License Types

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Medical Cannabis Licenses Under the MCRSA & AUMA


License Types

The AUMA provides for 19 different types of licenses – most of which mirror the 17 licenses already created by the MCRSA.  

Here's a brief breakdown:

MCRSA LICENSE TYPES

Type 1 = Cultivation; Specialty outdoor; Small.  (Up to 5,000 sf. of canopy, or up to 50 non-contiguous plants)

Type 1A = Cultivation; Specialty indoor; Small  (Up to 5,000 sf.)

Type 1B = Cultivation; Specialty mixed-light; Small (Up to 5,000 sf. using exclusively artificial lighting)

Type 1C** = Cultivation; Specialty Cottage; Mixed-Light (Up to 2,500 sf. using a combo of natural and artificial lighting); Outdoor (Up to 25 plants); Indoor (Up to 500 sf.)

Type 2 = Cultivation; Outdoor; Small (Up to 5,000 sf. using a combination of artificial and natural lighting)

Type 2A = Cultivation; Indoor; Small. (5,001 -10,000 sf.)

Type 2B = Cultivation; Mixed-light; Small (5,001 -10,000 sf.)

Type 3 = Cultivation; Outdoor; Medium (10,001 sf. - 1 Acre)

Type 3A = Cultivation; Indoor; Medium (10,001 - 22,000 sf.)

Type 3B = Cultivation; Mixed-light. Medium (10,001 - 22,000 sf.)

Type 4 = Cultivation; Nursery

Type 6 = Manufacturer 1 (Using non-volatile solvents)

Type 7 = Manufacturer 2 (Using volatile solvents)

Type 8 = Testing

Type 10 = Dispensary; General

Type 10A = Dispensary; No more than three retail sites

Type 11 = Distribution 

Type 12 = Transporter

AUMA LICENSE TYPES**

Type 1 = Cultivation; Specialty outdoor; Small (Same as MCRSA)

Type 1A = Cultivation; Specialty indoor; Small (Same as MCRSA)

Type 1B = Cultivation; Specialty mixed-light; Small (Same as MCRSA)

Type 2 = Cultivation; Outdoor; Small (Same as MCRSA)

Type 2A = Cultivation; Indoor; Small (Same as MCRSA)

Type 2B = Cultivation; Mixed-light; Small (Same as MCRSA)

Type 3 = Cultivation; Outdoor; Medium (Same as MCRSA)

Type 3A = Cultivation; Indoor; Medium (Same as MCRSA)

Type 3B = Cultivation; Mixed-light; Medium (Same as MCRSA)

Type 4 = Cultivation; Nursery (Same as MCRSA)

Type 5 = Cultivation; Outdoor; Large (No artificial lighting greater than 1 Acre)

Type 5A =Cultivation; Indoor; Large (Over 22,000 sf. using exclusively artificial lighting)

Type 5B = Cultivation; Mixed-light; Large (Over 22,000 sf. using a combination of artificial and natural lighting)

Type 6 = Manufacturer 1 (Same as MCRSA)

Type 7 = Manufacturer 2 (Same as MCRSA)

Type 8 = Testing (Same as MCRSA)

Type 10 = Retailer (Includes retail sale and delivery)

Type 11 = Distributor (Same as MCRSA but not mandatory)

Type 12 =Microbusiness (Can cultivate up to 10,000 sf. and also act as a licensed distributor, Level I manufacturer and retailer)

**All licenses issued for adult use would be distinct from those issued for medical use, and would be designated as such.   E.g., an outdoor cultivator for medical cannabis would receive a “Type 1” license, whereas a non-medical outdoor cultivator would receive a “Type 1 – Nonmedical” or “Type 1NM” license.


The MCRSA and AUMA are very similar, at least with respect to license types. The key differences are:

  • The AUMA's addition of Type 5 licenses for large-scale growers, which will not be issued for five (5) years and will not allow for vertical integration;
  • Unlike the MCRSA, the AUMA does not prohibit vertical integration for other licensees, except for Type 8 testers and Type 5 large growers; and
  • The AUMA provides for a versatile “microbusiness” license which allows for vertically integrated small farm operations – much like the collective model we've already been using here in California.

MCRSA vs. AUMA Licensing

Though the AUMA provides for 19 different types of licenses – most of which mirror the 17 licenses already created by the MCRSA – there are several key differences with respect to licensing:

  • Vertical Integration: Unlike the MCRSA, the AUMA doesn't prohibit vertical integration of licenses.   Instead of being limited to only having up two different license types under the MCRSA, the AUMA instead allows a licensee to hold any number or combination of licenses: cultivator, manufacturer, retailer, distributor and tester. There is one exception, however, for Type 5 cultivators (see below), who cannot hold certain other licenses.  
  • (Type 5) New Category of “Large” Cultivation Licenses: AUMA creates an additional category of Type 5 cultivation licenses, which are the largest cultivation licenses available. This license is created for farms that exceed the MCRSA's current limit of 22,000 sq. ft. indoors or 1-acre outdoors.   No Type 5 licenses will be issued before January 1, 2023.[i] Unlike other licensees, the vertical integration for Type 5 cultivators will be limited: they will not be allowed to hold Type 8 (laboratory tester), Type 11 (distributor) or Type 12 (microbusiness) licenses.
  • (Type 12) New Category of “Microbusiness” Licenses: Not to be confused with the type 12 transporter license und MCRSA, the AUMA replaces Type 12 licenses with a new category of “microbusiness” licenses. This license will allow for vertically integrated small farm operations not exceeding 10,000 sq. ft. – much like the collective model we've already been using here in California.
  • Diminishes Business Potential for (Type 11) Distributors: Unlike the MCRSA, the AUMA doesn't require that cultivators send their products to Type 11 distributors. It appears that only the new, Type 5 large-scale cultivators will be required to use Type 11 distributors. The remaining licensees will be eligibly to distribute for themselves.
  • Cannabis Cafés: The AUMA will allow local governments to permit on-site consumption for Type 10 dispensaries and Type 12 microbusinesses in their jurisdiction provided that the sale or consumption of alcohol or tobacco is not allowed on the premises.

[i] AUMA, § 26062(d).

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