CRA Warns of Specific Scam Targeted at Michigan Licensed Cannabis Businesses

The Cannabis Regulatory Agency (CRA) is issuing this bulletin to notify licensed marijuana businesses about recent fraudulent activity in the cannabis industry.

This week, the CRA was informed by a CRA-licensed business that they were contacted by an individual claiming to work for the CRA and asking for immediate payment of licensing fees under the threat of license revocation.

The CRA reminds licensees that all communications from the CRA will come through Accela or from a Michigan.gov email address and that the CRA will not call licensees to collect payment of fees. In addition, the CRA reminds licensees that the CRA does not accept alternative payment methods such as Bitcoin.

Licensees are encouraged to have their staff verify the validity of a call or text with a manager or owner before processing any payments to an individual claiming to be from the CRA. Licensees and applicants are reminded that the administrative rules require they notify the CRA and local law enforcement within 24 hours of becoming aware – or within 24 hours of when they should have been aware – of the theft or loss of any product or criminal activity at the marijuana business.

Incidents of fraudulent activity or attempted fraudulent activity that coincide with the above themes should be reported to the CRA using the online reporting form process and should be reported to local law enforcement. Questions can be sent to the Cannabis Regulatory Agency Field Operations Section at CRA-CSS@michigan.gov.

CRA releases breakdown of FY2023 municipal tax share payments from Adult Use cannabis sales

FY25 Budget Recommendation – elimination of monthly Metrc subscription fee

LANSING, MI – February 16, 2024: Cannabis Regulatory Agency (CRA) Executive Director Brian Hanna applauded Governor Gretchen Whitmer’s Fiscal Year (FY) 2025 Executive Budget Recommendation, which includes additional support for the agency’s initiatives.

This year’s budget is balanced, fiscally responsible, does not raise taxes on Michiganders, and contains support for key CRA initiatives, including:

  • Eliminating the monthly subscription fees that licensees currently pay to access the statewide monitoring system
  • Increased support to combat illicit activity in the cannabis market
  • Improved enforcement efforts and workload management within the Licensing Division
  • Reducing wait times for fire safety inspections

“We are excited to continue moving forward with support for our key initiatives, which stakeholders have indicated are important for a thriving and growing cannabis market,” said Hanna. “By removing the burden and cost of the monthly subscription to the statewide monitoring system, the CRA is investing in the stability and long-term success of the legal market. Increased support for combating illicit activity, improving enforcement efforts, and increasing safety with fire inspections will help us continue to support our state’s licensed businesses.”

“We applaud Governor Whitmer for putting forward a comprehensive budget for our program that will address a number of urgent requests from our members,” said Robin Schneider, executive director of the Michigan Cannabis Industry Association (MiCIA). “The budget contains several important allocations that will increase safety, reduce businesses’ regulatory costs, and increase profitability for law abiding operators by increasing enforcement against illicit activity in our market. As we work toward the continued improvement of our industry, we appreciate the Michigan Cannabis Regulatory Agency’s willingness to listen to our concerns and take action to address them.”

CRA Issues $212,000 Fine and 30-Day Suspension of Vassar Licensee

January 25, 2024 – Today, the Cannabis Regulatory Agency (CRA) issued a $212,000 fine and a 30-day suspension of 664 Vassar, LLC, dba Premier Provisioning Center #2, located at 664 State Rd., Vassar, Michigan 48768.

664 Vassar, LLC’s license shall be suspended from Saturday, February 3, 2024 through Sunday, March 3, 2024.

On April 21, 2022, the CRA visited 664 Vassar, LLC to conduct a compliance check and found the following at its facility:

  • Several clear totes containing expired marijuana products including distillate carts, medicated syrup, gummies, and chocolates stored in the “bathroom area” located upstairs in the northern most east backroom. This product was not under video surveillance.
  • 15 separate strains of individually bagged untagged flower in a large black garbage bag located in the upstairs central storage area. This product was not under video surveillance.
  • Untagged “House wax” in individual 1-gram jars and 1-ounce sheets. This product was not under video surveillance.
  • Approximately 38 jars of house wax on the sales floor and several sheets of house wax on the sales floor. Both products, although in different forms, contained the same statewide monitoring system (Metrc) tag number.
  • Chemicals – specifically, Round Up pesticide – stored on the landing area leading to the upstairs where marijuana product is stored.
  • Several hundred small, 1-gram jars of caregiver “house wax,” a marijuana product, stored in cardboard boxes.
  • Untagged medicated syrup called ‘Chill Medicated,” a marijuana product.

On April 22, 2022, the CRA requested video surveillance footage from all camera views for the past 30 days. 664 Vassar, LLC provided the requested footage on May 10, 2022 but the video footage would not play completely and did not show how the abovementioned products entered the facility. 664 Vassar, LLC was unable to provide a working copy of 30 days of video surveillance footage as requested by the CRA.

Further details can be found in the related formal complaints and consent orders:

Adult-Use Consent Order and Stipulation

Adult-Use Amended First Superseding Formal Complaint

Medical Consent Order and Stipulation

Medical First Superseding Formal Complaint

664 Vassar, LLC must comply with the following within 40 days:

  • Provide updated standard operating procedures (SOPs) for the following: the statewide monitoring system (Metrc), sales and transfers of marijuana and marijuana product, video surveillance system, storage of marijuana and marijuana products, and storage of chemicals and solvents. 664 Vassar, LLC must correct any deficiencies identified by the CRA within 30 days of receipt of the deficiency notice unless agreed upon by the CRA in writing.
  • 664 Vassar, LLC must train all managers and employees on the updated SOPs, and provide a document, signed by a manager, with the names and positions of all managers and employees trained, dates of completion for each; and provide a written training agenda, and copies of all training materials.

664 Vassar, LLC must comply with the following terms within 160 days:

  • 664 Vassar, LLC must schedule a date to destroy all of the untagged marijuana and marijuana product at issue in paragraph 6.b. in the amended first superseding formal complaint in the presence of a CRA staff member and provide video surveillance proof demonstrating compliant destruction.
  • 664 Vassar, LLC must conduct an inventory audit and provide a report to the CRA demonstrating that its physical inventory matches inventory in Metrc and explaining any discrepancies.

CRA Administrative Rules Correction: National Poison Control Hotline phone number UPDATE

An error in the Cannabis Regulatory Agency’s administrative rules has been corrected.

Old/incorrect:

• 504(4) “National Poison Control Center Hotline 1-800-222-1212,”

New/correct:

• 504(4) “National Poison Control Center Hotline 1-800-222-1222,”

A Proclamation on Granting Pardon for the Offense of Simple Possession of Marijuana, Attempted Simple Possession of Marijuana, or Use of Marijuana

In Proclamation 10467 of October 6, 2022 (Granting Pardon for the Offense of Simple Possession of Marijuana), I exercised my authority under the Constitution to pardon individuals who committed or were convicted of the offense of simple possession of marijuana in violation of the Controlled Substances Act and section 48–904.01(d)(1) of the Code of the District of Columbia (D.C. Code).  As I have said before, convictions for simple possession of marijuana have imposed needless barriers to employment, housing, and educational opportunities.  Through this proclamation, consistent with the grant of Proclamation 10467, I am pardoning additional individuals who may continue to experience the unnecessary collateral consequences of a conviction for simple possession of marijuana, attempted simple possession of marijuana, or use of marijuana.  Therefore, acting pursuant to the grant of authority in Article II, Section 2, of the Constitution of the United States, I, Joseph R. Biden Jr., do hereby grant a full, complete, and unconditional pardon to all current United States citizens and lawful permanent residents who, on or before the date of this proclamation, committed or were convicted of the offense of simple possession of marijuana, attempted simple possession of marijuana, or use of marijuana, regardless of whether they have been charged with or prosecuted for these offenses on or before the date of this proclamation, in violation of:

(1)  section 844 of title 21, United States Code, section 846 of title 21, United States Code, and previous provisions in the United States Code that prohibited simple possession of marijuana or attempted simple possession of marijuana;

(2)  section 48-904.01(d)(1) of the D.C. Code and previous provisions in the D.C. Code that prohibited simple possession of marijuana;

(3)  section 48-904.09 of the D.C. Code and previous provisions in the D.C. Code that prohibited attempted simple possession of marijuana; and

(4)  provisions in the Code of Federal Regulations, including as enforced under the United States Code, that prohibit only the simple possession or use of marijuana on Federal properties or installations, or in other locales, as currently or previously codified, including but not limited to 25 C.F.R. 11.452(a); 32 C.F.R. 1903.12(b)(2); 36 C.F.R. 2.35(b)(2); 36 C.F.R. 1002.35(b)(2); 36 C.F.R. 1280.16(a)(1); 36 C.F.R. 702.6(b); 41 C.F.R. 102-74.400(a); 43 C.F.R. 8365.1-4(b)(2); and 50 C.F.R. 27.82(b)(2).
My intent by this proclamation is to pardon only the offenses of simple possession of marijuana, attempted simple possession of marijuana, or use of marijuana in violation of the Federal and D.C. laws set forth in paragraphs (1) through (3) of this proclamation, as well as the provisions in the Code of Federal Regulations consistent with paragraph (4) of this proclamation, and not any other offenses involving other controlled substances or activity beyond simple possession of marijuana, attempted simple possession of marijuana, or use of marijuana, such as possession of marijuana with intent to distribute or driving offenses committed while under the influence of marijuana.  This pardon does not apply to individuals who were non-citizens not lawfully present in the United States at the time of their offense.

Pursuant to the procedures in Proclamation 10467, the Attorney General, acting through the Pardon Attorney, shall review all properly submitted applications for certificates of pardon and shall issue such certificates of pardon to eligible applicants in due course.

IN WITNESS WHEREOF, I have hereunto set my hand this twenty-second day of December, in the year of our Lord two thousand twenty-three, and of the Independence of the United States of America the two hundred and forty-eighth.

JOSEPH R. BIDEN JR.

CRA Adds Former Licensee to Michigan’s Marijuana Industry Exclusion List

December 14, 2023 – On November 14, 2023, the Cannabis Regulatory Agency issued a consent order and stipulation, resolving the formal complaint that had been issued on March 31, 2023, against the medical marijuana provisioning center license PC-000254 of Clark Street Investment Group Inc. dba The Reef, located at 6640 E. 8 Mile Road, Detroit, Michigan 48234.

Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra are permanently prohibited from applying for or otherwise seeking any new marijuana business license in the State of Michigan; exercising managerial control over a such a business; or otherwise meeting the criteria to be deemed an applicant, supplemental applicant, or otherwise subject to a background investigation of any such business.

In addition, Clark Street Investment Group Inc. dba The Reef and Mr. Czuchra are permanently prohibited from obtaining any new ownership interest in a licensed marijuana business in the State of Michigan. Mr. Czuchra is permanently prohibited from being employed or working in any capacity at a licensed marijuana business in the State of Michigan, including but not limited to, performing the functions of a regular or managerial employee, rendering any services as an independent contractor, or rendering any services via another party.

The following lapsed or closed licenses held by Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra, will not be renewed, reinstated, reissued, or reactivated, limited or otherwise, at any future date: PC-000254, GR-C-0001040, GR-C-0001041, GR-C-0001021.

On October 13, 2022, the CRA received a complaint alleging Clark Street Investment Group Inc. dba The Reef was selling marijuana product to individuals without a medical marijuana card. On November 29th, CRA investigators made an unannounced site visit to the provisioning center.

The factual allegations are detailed in the formal complaint and resulted in 14 counts of violated administrative rules in the following categories:

  • Licensees may sell or transfer marijuana to a registered qualifying patient or registered primary caregiver only after it has been tested and bears the label required for retail sale.
  • Licensees must accurately identify, enter, and track all transactions, current inventory, and other information into the statewide monitoring system as required.
  • Licensees must not have marijuana products that are not identified and recorded in the statewide monitoring system, nor without a batch number or identification tag or label.
  • Marijuana product that is to be destroyed or is considered waste must be rendered into an unusable and unrecognizable form.
  • Licensees must securely lock the marijuana business.
  • Licensees must ensure the video surveillance system records any areas where marijuana products are weighed, packed, stored, loaded, and unloaded for transportation, prepared, or moved within the marijuana business.
  • Marijuana products sold or transferred must be clearly labeled with the tracking identification numbers assigned by the statewide monitoring system affixed, tagged, or labeled and recorded, and any other information required. Before a marijuana product is sold or transferred, the container, bag, or product holding the marijuana product must be sealed and labeled with all of the required information.
  • Licensees may not advertise a marijuana product in a way that is deceptive, false, or misleading, or make any deceptive, false, or misleading assertions or statements on any marijuana product, sign, or document provided.
  • Licensees must ensure that employees handle marijuana product in compliance with Current Good Manufacturing Practice, Hazard Analysis, and Risk Based Preventative Controls for Human Food, 21 CFR part 1107.
  • Consumption of food and beverages by employees or visitors is prohibited where marijuana product is stored, processed, or packaged or where hazardous materials are used, handled, or stored.

Clark Street Investment Group Inc. dba The Reef and Anthony Czuchra have been added to Michigan’s marijuana industry exclusion lists, which are available online and include individuals excluded from participating in the licensed marijuana industry in Michigan.

Licensees must screen prospective employees, supplemental applicants, and owners against the exclusion list as they are prohibited from employing excluded individuals or allowing them to be supplemental applicants on a license.

Metrc: Accurate Tracking Tips from CRA

December 1, 2023:  To further assist licensees achieve compliance through accurate tracking, the Cannabis Regulatory Agency is providing guidance for a couple of issues found during compliance audits.

Notice to Cultivators, Producers and Sales Locations Re: Packaging Pre-rolls as Count-Based Products

If an item is pre-weighed and sold by the unit, the Metrc item category should be a count-based item. If an item is weighed just prior to sale, a weight-based category should be used.

Packages of raw pre-rolls should be created as Shake/Trim (prepackaged).

If the weight of a single pre-roll is 1 gram and the package is sold individually, then the unit weight should be 1 gram.

If the 1 gram pre-roll is sold in 5 packs, then the unit weight should be 5 grams.

It is important to check the unit weight of all items created before distribution to ensure it is accurate. Inaccurate unit weights can appear as oversales. For example: if the unit weight for a 1 gram pre-roll is inaccurately entered as 1oz, every time a sales location sells the 1 gram pre-roll the transaction amount will show 1oz. If a customer buys three 1 gram pre-rolls, the transaction will exceed the allowable limit of 2.5oz.

Notice to Sales Locations Re: Transaction Limit for Concentrate Products

Adult-use consumers may not purchase more than 15 grams of concentrate in a single transaction, which includes any combination of the following: inhalable compound concentrates (infused pre-rolls, moonrocks), concentrates (shatter, live resin) and vape carts.

The CRA will be auditing sales transactions in Metrc. Any retailers found to sell more than 15 grams of concentrate in a single transaction to adult-use consumers are in violation of R 420.506(3) and are at risk for disciplinary action.

Questions regarding the categorization and packaging of products in Metrc can be sent to CRA-Compliance@michigan.gov.

Questions regarding purchasing and transaction limits can be sent to CRA-Enforcement@michigan.gov.

CRA Announces New Social Equity Grant Program

November 30, 2023 – In order to further the development of the Cannabis Regulatory Agency’s Social Equity Program, following months of discussions with industry stakeholders and Social Equity Program participants, the Cannabis Regulatory Agency (CRA) announced today the formation of the Social Equity Grant Program.

“Many of our social equity licensees have invested everything they have in their cannabis business, and they truly deserve this shot in the arm,” said CRA Executive Director Brian Hanna. “I’m excited to see how our licensees use these funds and the positive impact they can have on their employees and their communities.”

“I was honored to spearhead social equity funding in the state budget this year,” said Sen. Sarah Anthony (Lansing). “I know how important funding is for individuals who are participating in the cannabis industry but may not have the same resources as others. It is vital that we begin the process to help those who have been disproportionately impacted by cannabis prohibition. These funds will go a long way in helping those in the social equity space grow their businesses and give back to their communities.”

Social Equity Grant Program funds must be spent in one or more of the following categories:

  • Funds spent on employee education may be used for an employee of the entity to take one or more classes or courses that are relevant to the entity’s business from an accredited institution.
  • Funds spent on business needs may be used towards compliance with licensing and regulatory statutes and rules.
  • Funds spent on community investment may be used on or donated to organizations, non-profits, and/or charities that positively impact the community in which the entity is located.

To be eligible to participate in the Social Equity Grant Program, entities must have a valid CRA-issued adult-use license, must currently have eligible Social Equity Program participants who have majority ownership of the entity, and must be a certified participant in the CRA’s Social Equity All-Star Program.

The application window for the 2024 Social Equity Grant Program runs from December 1, 2023 through January 26, 2024. The completed grant application must be received by the CRA via email no later than 5:00 pm on January 26, 2024. The application and instructions can be found on the CRA website.

Only one grant will be awarded per qualifying entity, regardless of how many licenses the entity has. Once it is determined how many applicants meet the criteria for approval, then each approved grantee will receive an equal share of the available one million grant dollars. [Example: 100 grantees = $10,000 per grantee.]

The CRA has scheduled an education session regarding the Social Equity Grant Program for Thursday, December 7th at 10:00 AM. The education session information is available on the CRA’s website and will also be available for replay as needed.

Social Equity Program licensees who are not yet participants in the CRA’s Social Equity All-Star Program should email CRA-SEGrants@michigan.gov for more information on how to participant in the program. This requirement must be met before a complete application will be considered for the Social Equity Grant Program.

Any questions regarding the Social Equity Grant Program should be sent to the CRA’s Social Equity Team via email: CRA-SEGrants@michigan.gov.

CRA Notifies Consumers of Voluntary Marijuana Product Recall for Sales Locations in Adrian and Gould City

November 20, 2023 – In the interest of public health and safety, Bloomfield Development Group Grow, LLC (AU-P-000308) – in coordination with the Cannabis Regulatory Agency (CRA) – is voluntarily recalling a limited number of marijuana-infused edibles. The recall bulletin can be located here.

The marijuana-infused edibles are being recalled because the producer could not provide evidence the product is homogeneous, and the product exceeds the maximum dose of 10mg of THC per serving. In the statewide monitoring system (Metrc), the product is spelled “Sweet Cheeks White Chocolate 10 pc” and as “Sweet Cheeks” on the product packaging.

The product was sold between the dates of 6/16/2023-10/17/2023 and has an expiration date of 5/5/2024.

Sweet Cheeks

The recall applies to the marijuana product sold at the following locations:

METRC TAG: 1A4050300032C81000002408
Endo (AU-R-000653)
307 E Beecher St, Adrian, MI 49221

METRC TAG: 1A4050300032C81000001360
Bloomfield Development Group Grow LLC (AU-R-001011)
17812 US HWY 2, Gould City, MI 49838

The above sales locations must display this recall notice on the sales floor, visible to all consumers, for 30 days from the date of this notice.

Consumers who have these products in their possession should return them to the marijuana sales location for proper disposal. Consumers who have experienced adverse reactions after using these products should report their symptoms and product use to their healthcare providers.

Consumers are encouraged to also report any adverse reactions to marijuana product to the CRA by completing this Adverse Reaction Form and submitting it according to the instructions included or by phone at 517-284-8599.

A licensee that becomes aware of any adverse reactions to a marijuana product must notify the CRA and enter the information into METRC within one business day.

Questions about this recall should be emailed to the CRA’s Operations Support Section at CRA-Compliance@michigan.gov. For more information about the CRA, please visit www.michigan.gov/CRA.