Cannabis and the Law Foley Hoag LLP New Jersey Adult Use Regulations – Ahead of Time and Full Steam Ahead


The New Jersey Cannabis Regulatory Commission (“CRC”) – ahead of schedule – just released its adult-use regulations, thereby taking the first step towards opening up its adult-use marketplace. While there is a tremendous amount of information to digest in the 160 pages of regulations, and the myriad implications and questions flowing from it, our cannabis team wanted to provide a brief overview of the relevant implications. In short, there are no substantial deviations from the expectations of the statute, i.e., the same license limitations and anticipated scope remain the same. What was fleshed out in painstaking detail, however, are certain details related to the application process, scoring, priority and the likely roll-out of the industry. We are anxiously awaiting the critical details that will be supplied by the Notice of Application, but at the moment the regulations establish a structure where to win, an applicant may have to both qualify under one of the ‘social equity priority’ criteria and submit the application as quick as possible under the CRC’s rolling review. So let’s dive in! Number of Licenses No surprise – the statutory cap of 37 cultivators for the first two years of the program is in the regulations, with no corresponding cap on other classes other than the generic requirement of meeting patient demand. However, the regulations do concede that the notice of applications will ultimately identify how many licenses and what classes are solicited. Application Process Timeline The application process starts with notice of the initial acceptance of license applications (the “Notice”). The statute identifies that the CRC must begin accepting applications within thirty (30) days of rule adoption (August 19). Applications may be accepted on a rolling basis. Timeline Not more than 90 days after the submission of the application, the CRC must make a determination on…

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Source : Cannabis and the Law Foley Hoag LLP New Jersey Adult Use Regulations – Ahead of Time and Full Steam Ahead

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