State & Local Requirements (Beyond OCM)

The New York City Department of Sanitation (DSNY) regulates how businesses store trash, manage waste, and maintain clean sidewalks. These rules apply daily and are actively enforced against retail businesses across the city. Sanitation violations are among the most common tickets issued to NYC retailers and can result in repeat fines if not corrected.

The New York City Department of Buildings (DOB) regulates how your dispensary is built, altered, and approved for lawful use. If work is not permitted, inspected, and signed off by DOB, you cannot legally open and may be shut down at any time. These rules apply even if you have never dealt with construction, permits, architects, or Certificates of Occupancy before.

MRTA Article 2; Sections 7–20 explain who governs cannabis in New York and how regulatory power is structured. It defines which bodies set policy, write rules, issue licenses, enforce compliance, and oversee equity.

MRTA Article 3, Sections 30, 31, 32, 41, and 42 define how patients qualify, how certification and registry systems work, what lawful medical use includes, how home cultivation is regulated, and what legal protections apply.

New York’s medical cannabis program operates separately from the adult-use system. Only Registered Organizations (ROs) may cultivate, manufacture, and dispense medical cannabis, and only certified patients and caregivers may purchase it. If you are not operating as, or co-located with, an RO, these rules generally do not apply to your retail operations. Understanding the distinction prevents compliance errors and customer confusion.

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Federal law requires all advertising to be truthful, clear, and not misleading. Cannabis businesses are held to the same federal advertising standards as every other industry, even when operating legally under state law. These rules apply to everything customers see, read, or receive.

NYCRR Title 9, Part 124 sets the rules that govern how cannabis businesses may contract, sell, finance, and work with third parties. These rules exist to prevent hidden control, unfair leverage, exclusive dealing, and financial arrangements that undermine license integrity. This section explains what is allowed, what is prohibited, when agreements create a True Party of Interest (TPI), and how OCM enforces these boundaries.

Cannabis remains illegal under federal law and is classified as a Schedule I substance under the Controlled Substances Act (CSA). This federal status applies nationwide and affects cannabis businesses even in states like New York where adult-use retail is legal. State legalization protects you from state enforcement only. It does not override federal law.