Notice of CRA public hearing on proposed updated Rules
Department of Licensing and Regulatory Affairs
Cannabis Regulatory Agency
Administrative Rules for Marihuana Rules
Rule Set 2023-25 LR
NOTICE OF PUBLIC HEARING
Tuesday, May 6, 2025
09:00 AM
In person: Sun Conference Room, 2407 N. Grand River Ave., Lansing, MI 48906
The Department of Licensing and Regulatory Affairs will hold a public hearing to receive public
comments on proposed changes to the Marihuana Rules rule set.
All rules will be effective 180 days after filing, except R 420.218a will be effective immediately upon filing.
The purpose of the proposed rule promulgation is to make various updates and revisions to the existing
Marihuana Rules, including updating, revising, and clarifying requirements pertaining to applicants and
licensees, the social equity program, the operation of marijuana businesses, production of marijuana
products, transporting and delivering marijuana, advertising and labeling, sampling and testing, use of
the statewide monitoring system, and annual financial statements.
By authority conferred on the Executive Director of the Cannabis Regulatory Agency by section 206 of
the Medical Marihuana Facilities Licensing Act, 2016 PA 281, MCL 333.27206; sections 7 and 8 of the
Michigan Regulation and Taxation of Marihuana Act, 2018 IL 1, MCL 333.27957 and 333.27958; section
3 of the Marihuana Tracking Act, 2016 PA 282, MCL 333.27903; and Executive Reorganization Order
No. 2019-2, MCL 333.27001.
The proposed rules will take effect immediately after filing with the Secretary of State. The proposed
issue of the Michigan Register. Copies of these proposed rules may also be obtained by mail or
electronic mail at the following email address: CRA-AdminRules@michigan.gov.
Comments on these proposed rules may be made at the hearing, by mail, or by electronic mail at the
following addresses until 5/7/2025 at 05:00PM:
Attention: Rules
P.O. Box 30205, Lansing MI 48909
The public hearing will be conducted in compliance with the 1990 Americans with Disabilities Act. If the
hearing is held at a physical location, the building will be accessible with handicap parking available.
Anyone needing assistance to take part in the hearing due to disability may call 517-643-0757 to make
arrangements.
FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies
Immediate Release
WASHINGTON––Consistent with the U.S. Department of the Treasury’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) is issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act.
In that interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.
Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed below. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.
Upon the publication of the interim final rule, the following deadlines apply for foreign entities that are reporting companies:
- Reporting companies registered to do business in the United States before the date of publication of the IFR must file BOI reports no later than 30 days from that date.
- Reporting companies registered to do business in the United States on or after the date of publication of the IFR have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.
FinCEN is accepting comments on this interim final rule and intends to finalize the rule this year.
CRA Reminds Licensees of Impending FDA Ban of FD&C Red No. 3 Color Additive
February 18, 2025 – The CRA announced today that it is requiring licensee compliance by January 15, 2027 with the Food and Drug Administration’s recent January 15, 2025 announcement that authorization for the use of FD&C Red No. 3 in foods, supplements, and drugs has been revoked.
CRA licensed producers may be affected by the prohibition of Red No. 3, which is added to products to impart red coloring. Products such as candies, gummy base, powders, and capsules used by CRA licensed producers in edible marijuana products may currently contain Red No. 3.
Producers must work with their suppliers to source alternative color additives and ingredients to those containing Red No. 3. Producers currently incorporating Red No. 3, or an ingredient containing Red No. 3, into products should expect to change written product formulations and labeling to reflect the new ingredient(s) and color additive(s) utilized.
Food and supplement manufacturers must discontinue use of Red No. 3 in products by January 15, 2027, and drug manufacturers must discontinue their use by January 18, 2028.
As the CRA defines edible marijuana products as any product containing marijuana that is intended for human consumption in a manner other than inhalation, all edible marijuana products that currently contain Red No. 3 must be reformulated by the earliest compliance date of January 15, 2027. This includes items that may be offered in forms similar to traditional drugs, such as capsules or powders.
Licensees should note that producers may continue to find that their suppliers offer items containing Red No. 3, as the prohibition for traditional drugs containing the color additive is not in effect until 2028. Additionally, Red No. 3 may still be listed in the Food and Drug Administration’s Inactive Ingredient Search for Approved Drug Products until 2028.
Any questions for the CRA regarding the use of Red No. 3 color additive may be directed to CRA-Enforcement@michigan.gov.
Cannabis Regulatory Agency Announces Voluntary Vape Recall (BLOOM)
February 11, 2025 – In the interest of public health and safety, Exhale Systems Inc (AU-P-0000495) of Detroit, in conjunction with the Cannabis Regulatory Agency, is conducting a voluntary recall of vapes offered for sale in the Michigan market.
Various flavors of BLOOM Classic and BLOOM Live brand vape cartridges contained Medium Chain Triglyceride Chain (MCT) oil and should not be consumed.
Exhale Systems Inc has identified sales locations that have this product in their inventory and are working with stores to retrieve and dispose of any recalled product in stock.
Sales locations have posted signs advising consumers to return this product to the sales location from which it was purchased or dispose of it.
The impacted products include the following strains: Alien Jack, Blue Dream, Cereal Milk, Champagne Kush, Durban Gelato, Face Off OG, Forbidden Fruit, Green Crack, Jack Herer, Maui Wowie, Pineapple Express, Pineapple Sherbert, Rainbow Runtz, Skywalker, White Widow.
Consumers who purchased these flavors of BLOOM vape cartridges any time after September 1, 2024 should check the recall bulletin. Consumers with a recalled vape should return it to the sales location from where it was purchased or dispose of it safely.
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 via the Adverse Reaction Form or by phone at 517-284-8599. A licensee who becomes aware of any adverse reactions to a marijuana product must notify the CRA and enter the information into METRC within one business day.
Update for Michigan Hemp Growers – Regulatory Transition
Since the inception of Michigan’s Agricultural Hemp Pilot Program in 2019, the Michigan Department of Agriculture and Rural Development (MDARD) has overseen the regulation of hemp production in Michigan. However, over the past few years, the number of licensed hemp growers has significantly declined, from 631 in 2020 to just 34 in 2024. As a result, the program is no longer financially sustainable. In addition, MDARD’s continued investigation and enforcement efforts against farms intentionally growing marijuana under the guise of hemp adds to the time and expense of managing the program.
Legislation has been introduced to rescind Public Act 220 and shift the regulation of hemp cultivation from MDARD to U.S. Department of Agriculture (USDA). This is only a proposed change, and adjustments may be made as the process moves forward.
If the legislation passes, MDARD will work closely with USDA to ensure hemp growers have a smooth transition to the federal program.
Currently, some key differences in the USDA program include:
- No license fee.
- Licenses are valid for three years.
- Growers must contract with USDA-certified sampling agents and private labs for THC testing.
For more details on the USDA hemp program and available resources, visit USDA Hemp Program and see the “For USDA Licensed Producers Only” section.
Depending on the status of the legislation, MDARD may delay mailing out renewal applications later than mid-December, which is when renewal applications are typically mailed. MDARD will continue to provide updated information as the legislative process unfolds.
Covert Law Firm
Stacy Adams
02:52 29 Jan 21
Ashley was very professional and delivered highly favorable results. I felt peace of mind knowing I was in the very best hands during one of the most challenging times in my personal life. Highly recommend .
Erick Roberts
20:19 05 Jan 21
Josh really cares about his clients. He has personally helped me multiple times on (2) separate cases. Criminal law & cps are two expertise areas i have personally witnessed. Josh has also worked wonders for a close friend of mine in the MJ field. If you are reading reviews or trying to decide if josh is the guy you need, you are looking in the right spot.
Colorado Ski Chairs
04:37 01 Jan 21
One of the smartest and most dedicated guys you’ll ever meet. Joshua has helped innovate and push the boundaries of modern justice in not only the medical marijuana field but in social justice and protecting and supporting families. He’s one of a kind. Fair, dedicated, intelligent and tireless. You’ll be pressed to find a better ally for any case you need help on.
Patrick Giddis
21:02 26 Dec 20
Joshua Covert has been extremely helpful and personable. Rare to find lawyers that will try to help no matter whether you retain them or not. I've dealt with a lot of lawyers but he's one of the most honorable.
Gee Rod
20:35 26 Dec 20
I first hired Josh last year for a criminal assault case in Clinton county. I decided to take that case to trial. I had a NOT GUILTY verdict in less then five minutes after deliberation. Since then I've continue to use Josh for numerous things. I am highly involved in the cannabis industry and Josh had my five year state wide noncompete agreement thrown out just last month. Josh and James have also helped me get my medical and recreational licensing for both grow and processing in the city of Lansing. They did all the trademarking for all my brands and logos. I am also using Josh for some other legal things that he doesn't specialize in like estate and will. I have utmost confidence in his abilities and I trust him. Josh and his team are really the best when it comes to law. I've put them up against big money a few times and came out on top. Josh and his firm are honest and hard working. If he doesn't know the answer to something he is sure to find it for you. You can't get much better then the Covert law firm. Highly recommended!
Joe Dunn
16:28 23 Dec 20
About two years ago, I was interested in the smaller commercial marijuana cultivation licenses in Michigan. I had many questions regarding the application process and understanding/clarification on the laws surrounding the commercial grows. I called Josh after getting his number from google. He answered my questions, but I had many more and I also needed help with the application process. He told me to move forward, I would need to deposit $2,000 and open an account with him. This would allow me to call or text him for quick questions and responses. I didn't think I would have $2,000 worth of questions, but he assured me, over the phone, that if I didn't have any more questions I could get money back that I didn't use. Fast forward to present day, I no longer need his services. I have $1,555 in my account. $445 was deducted for text and phone call questions that I have had over the past years. I reached out to him 4 weeks ago, to get my $1,555 back. First he tells me its non-refundable. I reminded him that he told me I would get any money back that I didn't use. After going back and forth, he agreed to give me my money back. 2 more weeks pass and nothing. I reach out to him again, he tells me he doesn't write checks, his assistant has to do it, blah blah blah. He tells me I will have it in a few days. That was 3 weeks ago. I still haven't got any money back. Not a word from Josh. DO NOT USE THIS LAW FIRM. DO NOT TRUST THIS GUY. If you do, make sure to audio record all conversations with him!!!! He will lie to you to get you to pay large deposit for services you dont need.
Kate Seward
16:57 29 Sep 20
In the beginning of my case, Ashley talked to Josh. Josh and Ashley told me I have nothing to worry about in the child custody case. Total took a lot off of my shoulders hearing that. Thank you to you both for traveling to Roscommon County for this case! You both rock and ready to be a bull in court in Nov. Thank you again!!
James McGillie
01:23 16 Sep 20
Best in the business. Client focused, responsive, and effective team of attorneys with practical advice and solutions to most any legal issue you face. HIGHly recommended 👊
Nicole Abbey
13:33 14 Sep 20
Covert Law is a law office that cares about the individuals they represent and are affordable. Josh will get it done!
Sara Eleanor Yarbrough
02:25 21 Aug 20
Although I was facing some serious things, Josh happily took my case and was there every step of the way. The retainer was very reasonable, communication was great, and his negotiations were very clear and to the point. He really made an intense, sometimes scary and emotional, situation a lot easier to go through. I never felt like he was trying to get money out of me. I can honestly say my outcome, and life going forward, is much easier from choosing to call him for legal aid.
Sam Postalot
17:20 07 Aug 20
Very knowledgeable always a pleasure to work with highly recommended been in the industry for years
Tony Nowak
15:57 07 Aug 20
Very professional, knowledgeable and willing to help point me in the right direction.
Randi Bagley
17:12 19 Feb 20
Excellent concise and knowledgeable, especially about medical marijuana. Call them if you need advice! They are very fair and generally want to help the cannabis community.
Chris C
17:27 15 Feb 19
Nickolas Calkins was recommended to me, and ever since the first time I to him I was in good hands. He was able to handle the case and help relieve the stress from it off of and communicate in a way that kept me at ease and well informed. He, and the entire staff at Covert Law really went above and beyond. I am grateful that I was introduced to them.
Roy Schmidt
00:50 26 Nov 18
Josh Covert is the best cannabis attorney in Michigan. Josh defended me on an OWI charge, operating while impaired on cannabis. Josh was outstanding in my defense. Josh is a good listener, kept me updated, asked my opinion, and really cares about his clients. Josh filed every motion (several) in my defense before my trail. During the trail Josh was professional but a bulldog in defending me against lies and lack of evidence by the arresting officers. When Josh was finished cross examining the arresting officers it took a jury less than an hour to find me NOT GUILTY! You will never go wrong with Josh Covert.
Vessel of Christ
22:19 17 Nov 18
Hands down the best Attorney in Michigan, cares for his clients, knows the laws, doesnt back down, and doesnt get pushed over like most attorneys by the corrupt system and corrupt prosecutors. This Job is meant for truly intelligent people that have a heart for truly helping the individual, and out of 15 different attorneys that I've had in my life. There is no comparison. When you truly know you have someone on your side, it takes away the fear the corrupt system wants you to feel
brian coon
16:50 16 Nov 18
I hired josh on my open case but he's been a good attorney, very , very knowledgeable on cannabis and cannabis laws.he's also will work with you. I feel if ur in need of a tip notch cannabis attorney I wouldn't look no mores and give his office a call.very good ppl in office also..thanks Josh !!!
Jennifer Dummer
16:23 16 Nov 18
Josh Covert is an amazing lawyer. He fought for us and got our case thrown out. I would highly recommend him. He's always there for us when ever we need advice or help.
