Cannabis Stakeholders Weigh in on Proposed Rule Changes


Since it first released a list of issues it was considering addressing through new administrative rules in May, the Michigan Cannabis Regulatory Agency (“CRA”) has already received hundreds of pages of responses, comments, and recommendations from cannabis stakeholders. Honigman’s Cannabis Industry Group has reviewed the extensive feedback received thus far, and some of the frequently cited comments include:

  • Many stakeholders have expressed concern that listing specific banned chemicals and testing requirements in the rules rather than by bulletin will cause delays in a rapidly changing industry, because the rules will have to be amended each time the lists or requirements are updated. 
  • Stakeholders also expressed concern regarding requirements for licensed growers to have at least one employee obtain MDARD pesticide applicator certification and “Master Grower” certification within one year of licensure, particularly since the definition of “Master Grower” is unclear.
  • Multiple stakeholders have expressed support for allowing the CRA to deny initial license or renewal applications for entities that have been subject to civil judgments or court orders related to owing money to other licensees or service providers for cannabis-related goods and services. 
  • Multiple stakeholders have also expressed that they do not support testing pre-roll products in final form, citing the additional expenses and undue burdens related to this testing. 

Several of our attorneys and lobbyists are already actively involved and communicating regularly with the CRA about our clients’ priorities.  We will continue to closely monitor the process and provide updates throughout the rulemaking process. If you are curious to know what other commenters have already submitted and/or need support providing input to the CRA, advocating for specific issues, or have any questions related to the rulemaking process, please reach out to us for assistance.  

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