CRA Guidance for Tinctures

Tinctures are not defined in either the Medical Marihuana Facility Facilities Licensing Act (MMFLA) or the Michigan Regulation and Taxation of Marihuana Act (MRTMA). When a term is not specifically defined in statute, the Cannabis Regulatory Agency (CRA) uses the plain meaning of the term as defined in the dictionary. As a result, CRA policy has been that a product labeled as being a tincture must contain alcohol.

The CRA recently reviewed products produced and sold by several licensees that are labeled and sold as tinctures. The products appeared to be non-compliant because they were labeled as a tincture but contained no alcohol and exceeded the allowable THC limit of 100 mg per container in the adult-use market.

The CRA has been notifying licensees that the sale of these products is a violation. In response, many licensees have expressed concern about the lack of a clarifying statutory definition, common industry practice in other states, and residual solvent compliance testing for tinctures.

To address these concerns until a long-term solution can be implemented, the CRA will allow licensees to make the necessary changes to packaging, labeling, formulations, and recipes, and take no disciplinary action against licensees regarding product that is currently available for sale or transfer for 60 days from the date of this bulletin (August 30, 2022).

For more help navigating Michigan’s cannabis laws and rules, be sure to reach out to Michigan Cannabis Lawyers at (517) 512-8364.

The Attorney for PEOPLE v. LATZ comments on the case four years later

PEOPLE v. LATZ

Our friend and client Callen Latz was charged with improper transport of medical marijuana back in 2014. Joshua Covert defended his rights in 2016 and won the case PEOPLE OF MI V CALLEN TRENT LATZ

PEOPLE v. LATZ Joshua Covert Quote

Now in 2020, this is what Josh has to say about his landmark case:

 

Sources

https://www.washingtontimes.com/news/2016/dec/21/court-medical-marijuana-law-trumps-law-on-transpor/

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MRA emergency rules expired IDS www.michigancannabislawyer.com

 

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If not, scroll down and watch it.

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More states across the Country are leaning toward this type of approach in determining the reasonableness of similar searches.

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Long ago, Michigan started protesting how ridiculous it is for cannabis to be stigmatized and be criminalized. So every first Saturday in April people gather at the U of M campus and openly consume. But this year will be different. A disease is sweeping the nation and events and even schools all across Michigan are being canceled.

On the best year and month possible for this event (04/2020), the virus is COVID-19 is scaring the nation. In preventive measures to keep the virus from spreading, everyone is staying at home to prevent the spread of the disease.

The Ann Arbor Hash Bash 2020 is postponed this year.

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Hey Everybody its Josh Covert from the Michigan Cannabis Lawyers. I’m in at the office today had a little time to shoot a video so I thought I talked about Michigan Marijuana Microbusiness. I get a lot of questions about micro businesses!

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