Adult-Use License Types

What This Covers

• Adult-use license categories and authorizations
• Ownership limits and eligibility rules
• Operational permissions and prohibitions
• Vertical-integration restrictions
• OCM oversight and enforcement boundaries

Adult-Use Cultivator License (Section 68)

Authorizes the licensee to:

• Grow, harvest, dry, and trim cannabis
• Sell cannabis to licensed processors
• Conduct limited processing if authorized by OCM
• Apply for one processor license and one distributor license to distribute its own products

Restrictions include:

• No ownership interest in retail or other adult-use licenses
• One cultivator license per person unless OCM authorizes multiple sites

Registered Organization Adult-Use License — Full Vertical (Section 68-A)

Authorizes a Registered Organization to:

• Cultivate, process, distribute, and retail adult-use cannabis

Limits include:

• Maximum of three adult-use retail dispensaries at existing medical sites
• Distribution limited to its own products
• Medical operations must be maintained
• No ownership of other adult-use licenses

Registered Organization Adult-Use License — Vertical, No Retail (Section 68-B)

Authorizes a Registered Organization to:

• Cultivate, process, and distribute adult-use cannabis

Restrictions include:

• No adult-use retail activity
• Distribution limited to its own products
• No ownership of other adult-use licenses

Adult-Use Processor License (Section 69)

Authorizes the licensee to:

• Process, manufacture, package, label, and brand cannabis products
• Sell products to processors or distributors
• Apply for one distributor license to distribute its own products

Restrictions include:

• No cultivation
• No unrelated business activities unless approved by OCM
• One processor license per person
• No ownership interest in retail or Registered Organization licenses

Adult-Use Cooperative License (Section 70)

Authorizes the cooperative to:

• Cultivate, process, and distribute cannabis
• Sell to retailers, cooperatives, microbusinesses, on-site consumption licensees, and Registered Organizations

Restrictions include:

• No direct sales to consumers
• Ownership limited to New York residents
• One vote per member
• Members may belong to only one cooperative
• No ownership interest in other adult-use licenses

Adult-Use Distributor License (Section 71)

Authorizes the licensee to:

• Acquire and distribute cannabis products
• Sell to retailers, on-site consumption licensees, cooperatives, microbusinesses, and eligible Registered Organizations
• Charge an OCM-approved distribution fee

Restrictions include:

• No ownership interest in microbusiness, retail, on-site, or other Registered Organization licenses (except as allowed under §39)
• If affiliated with a cultivator or processor, distribution is limited to those products

Adult-Use Retail Dispensary License (Section 72)

Authorizes the licensee to:

• Acquire, possess, sell, and deliver cannabis products to consumers

Restrictions include:

• Maximum of three dispensaries per person
• No ownership interest in other adult-use licenses except as allowed under §§68-A and 68-B
• Public, street-level storefront required unless delivery-only or microbusiness
• Prohibited within 500 feet of a school or 200 feet of a house of worship

Microbusiness License (Section 73)

Authorizes limited:

• Cultivation
• Processing
• Distribution
• Delivery
• Retail of the licensee’s own products

Restrictions include:

• No ownership interest in other adult-use licenses
• OCM-set limits on canopy, production volume, and eligibility
• Mandatory support of social and economic equity goals

Delivery License (Section 74)

Authorizes the licensee to:

• Deliver cannabis products directly to consumers

Restrictions include:

• Maximum of 25 full-time-equivalent delivery workers
• No ownership interest in more than one delivery license
• OCM-set operating criteria and rules
• Mandatory support of social and economic equity goals

Nursery License (Section 75)

Authorizes the licensee to:

• Produce, sell, and distribute clones, immature plants, seeds, and starter materials

Restrictions include:

• Sales limited to cultivators, cooperatives, microbusinesses, and Registered Organizations
• License requirements set by OCM
• Cultivators may apply for only one nursery license

Adult-Use On-Site Consumption License (Section 77)

Applications are not yet open.

This license authorizes:

• On-site consumption of cannabis purchased on the premises

Restrictions include:

• Licensee must own or control the premises
• Maximum of three licenses per person
• No ownership interest in other adult-use licenses
• Prohibited within 500 feet of a school or 200 feet of a house of worship
• Access restricted to individuals 21 and over
• Full purchase and sales records required
• Subject to inspection at any time

What Operators Usually Miss

• You may not hold multiple license types unless explicitly allowed by statute
• Vertical integration is prohibited by default
• Ownership conflicts alone can trigger enforcement

When This Comes Up

• License application and eligibility review
• Business planning and structuring
• Ownership changes or investment discussions
• Enforcement actions and audits

What Happens If You Ignore This

• License denial or revocation
• Forced divestment of ownership interests
• Fines and enforcement penalties
• Denial of renewal or future licenses

Jump To MRTA Article 4 Section Pages

• Municipal Notification Requirements (Section 76)‍
• SOPs and Operations (Sections 78–86)‍
• Equity, Data, and Reporting (Sections 87–89)‍
• MRTA Article 4 Main Section Page

References

• MRTA Article 4, Sections 68–75, 77

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