Marijuana Licensing

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Notice of CRA public hearing on proposed updated Rules

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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  
Virtual: https://bit.ly/4bLt2x1 Passcode: 276834  
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  
rules are published on the State of Michigan’s website at www.michigan.gov/ARD and in the 5/1/2025  
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  
CRA-AdminRules@michigan.gov  
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.

2024 Adult-Use Marijuana Payments Being Distributed to Michigan Municipalities, Counties and Tribes

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CRA Reminds Licensees of Impending FDA Ban of FD&C Red No. 3 Color Additive

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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)

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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.

COA (unpublished opinion) – Municipal clerk may not remove MRTMA ballot initiative after approving language

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CRA Announces New Testing Requirement for MCT Oil

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June 27, 2024 – Today, Michigan’s Cannabis Regulatory Agency (CRA) issued a technical bulletin announcing that MCT (medium-chain triglyceride) oil will be added as a target analyte for marijuana vape cartridges as part of the Sampling and Testing Technical Guidance for Marijuana Products, effective October 1, 2024.

MCT oil, commonly derived from coconut or palm oil, is primarily used in oral supplements and food products. However, when aerosolized and inhaled, MCT oil may pose dangers to respiratory health. Inhalable marijuana products that fail testing for MCT oil cannot be remediated.

“From a public health and safety standpoint, the potential for adverse effects with MCT oil underscores the importance of safety guidelines for product development,” said CRA Executive Director Brian Hanna. “Michigan’s licensed marijuana businesses must prioritize respiratory safety when formulating or using inhalable products, opting for ingredients that have been thoroughly evaluated for their compatibility with lung health. I look forward to when our new state reference laboratory is up and running, advancing the health and safety of Michigan cannabis consumers with advanced testing for diluents.”

“Several of our retail members have been proactively pulling and testing their inventory to ensure the brands they showcase on their shelves do not contain MCT oil,” said Robin Schneider, executive director of the Michigan Cannabis Industry Association. “Moving forward, this testing will take place before the retailers purchase inventory from producers, easing the burden on retailers and ensuring that the products they sell are safe. Required testing for MCT oil will further protect cannabis customers from vape-related lung illnesses and is a win for both the industry and consumers.”

“I fully support the state’s decision to restrict the use of MCT oil in vape cartridges,” said MiNORML Executive Director Anqunette Sarfoh. “The health and safety of cannabis consumers must always be our top priority. Emerging evidence suggests that inhaling MCT oil can pose serious respiratory risks, and it’s imperative that we take proactive measures to prevent potential harm. By enforcing stricter regulations on vape product ingredients, Michigan is taking a significant step towards ensuring a safer cannabis industry for everyone and we commend the state’s commitment to protecting consumers.”

“I applaud the CRA’s decision to ban the use of MCT oil in all regulated vape cartridges,” said Anton Harb Jr., an Iraq combat veteran and founder of the Veteran Access Program in Michigan. “As the cannabis industry matures, so will the scientific and regulatory safety measures protecting it. This regulatory decision helps ensure the continued safety and well-being of all Michigan cannabis consumers.”

The CRA is committed to evidence-based decision-making when implementing technical guidance for licensed laboratories. As research into marijuana use, safety, and testing advances, the Sampling and Testing Technical Guidance for Marijuana Products may be revised and updated to reflect these changes.

Michigan CRA Issues Recall Bulletin and Product Advisory Bulletin

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May 15, 2024 – In the interest of public health and safety, the Cannabis Regulatory Agency (CRA) issued a recall bulletin for 1,098 units of infused pre-rolls produced by Flavor Galaxy LLC (license no. AU-P-000373), located at 21015 John R Road, Hazel Park, MI 48030.

In its investigation, the CRA discovered that Flavor Galaxy LLC did not submit certain infused pre-rolls for testing in their final form. The statewide monitoring system (Metrc) indicated that the infused pre-rolls only had safety compliance testing for raw marijuana flower and potency and were not tested after Flavor Galaxy LLC added cannabis distillate and/or terpenes to the product. Consumers who purchased a Flavor Galaxy LLC produced infused pre-roll (with AU-P-000373 on the package label) between November 25, 2023, and May 6, 2024, should check the recall bulletin to determine if the product is subject to recall.

In addition, the CRA issued a product advisory bulletin alerting marijuana consumers to marijuana products that were not properly tracked in the statewide monitoring system (Metrc) by Flavor Galaxy LLC. In its investigation, the CRA reviewed Metrc and discovered that Flavor Galaxy LLC added marijuana product to numerous packages of pre-rolls after the packages had been sampled by a licensed laboratory for compliance testing. Metrc information also showed that Flavor Galaxy LLC added marijuana product to numerous packages of vape cartridges after the packages had been sampled by a licensed laboratory for compliance testing. A link to the Metrc tag numbers for affected products can be found in the product advisory bulletin.

Marijuana consumers who have experienced adverse reactions after using these products should report their symptoms and product use to their health care provider. 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. For more information about the CRA, please visit www.michigan.gov/CRA.

Cannabis Regulatory Agency Issues Reminder Regarding Illegal Sales of Marijuana in Michigan

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April 23, 2024 – Today, Michigan’s Cannabis Regulatory Agency (CRA) reminded licensees and businesses of their roles and responsibilities regarding the selling of cannabis in Michigan.

Under state law, THC is defined to include THCA and marijuana, generally, is defined as cannabis in any form with a THC concentration greater than 0.3%. Therefore, cannabis in any form with a concentration of THC (including THCA) greater than 0.3% is, by definition, marijuana. Under the Medical Marihuana Facilities Licensing Act (MMFLA), marijuana and industrial hemp have the same meaning as defined in the Michigan Regulation and Taxation of Marihuana Act (MRTMA).

If law enforcement identifies an unlicensed business selling cannabis in any form with a concentration of THC (including THCA) greater than 0.3%, they can seize the product and the offenders may be subject to criminal charges.

“A person not licensed under the MRTMA or MMFLA who sells marijuana or possesses marijuana in quantities greater than allowed by statute is in violation of state law and the CRA will refer potential criminal complaints to the Michigan State Police,” said CRA Executive Director Brian Hanna. “We work shoulder to shoulder with law enforcement to ensure the health and safety of cannabis consumers in Michigan.”

“The Marijuana and Tobacco Investigation Section of the Michigan State Police is a key strategic partner of the CRA, and we are committed to investigating retailers who would offer for sale marijuana products and derivatives in violation of state law,” stated D/F/Lt. Thomas Kish, commander of the MSP Marijuana and Tobacco Investigation Section. “Further, both the MSP and CRA share health and safety concerns for consumers participating in Michigan’s licensed adult-use market and we will work diligently to do what we can to ensure these products meet all regulatory standards for safety.”

If members of the public witness businesses selling any cannabis in any form with a concentration of THC (including THCA) greater than 0.3%, without a license, or if employees suspect that their employer is selling cannabis in any form with a concentration of THC (including THCA) greater than 0.3%, without a license, they are encouraged to reach out to local law enforcement, the Michigan State Police, or the Cannabis Regulatory Agency.

CRA Warns of Specific Scam Targeted at Michigan Licensed Cannabis Businesses

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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.