Massachusetts Cannabis Control Commission Releases Draft Social Consumption Establishment Regulations for Formal Public Comment

By David M. Ullian, Tim Callahan

Aug 19, 2025

On August 14, 2025, the Massachusetts Cannabis Control Commission (the “Commission”) voted to formally release its draft amended Social Consumption Establishment regulations, marking a significant step towards finally launching on-premises consumption of cannabis in the Commonwealth. These proposed rules outline new license types, operational standards, and eligibility requirements.

The Commission published redlined versions of the Adult Use of Marijuana Regulations (935 CMR 500.000) and the Medical Use of Marijuana Regulations (935 CMR 501.000) showing the proposed changes. The proposed regulations would create three distinct Social Consumption Establishment license types and four separate Consumption Area categories.

This blog post provides a high-level overview of the proposed amended regulations and provides information on how interested stakeholders can submit comments to the Commission during the public comment period.

What You’ll Learn in This Blog Post

The Commission’s proposed regulations are extensive. Use these quick links to navigate to the sections that matter most to you:

Social Consumption License Types and Areas

Under the proposed amended regulations, three distinct Social Consumption Establishment license types would be available:

Supplemental On-Site Consumption
Hospitality On-Site Consumption
Marijuana Event Organizer

The rules also establish four separate types of Consumption Areas within licensed Social Consumption Establishments:

Indoor Non-Smoking
Indoor Smoking
Outdoor Non-Smoking
Outdoor Smoking

General Operations and Requirements for Social Consumption Establishments

Under the proposed regulations, a licensed Social Consumption Establishment would be authorized to:

Sell marijuana and marijuana products to consumers and allow on-premises consumption in designated consumption areas;
White label, repackage, transfer, waste, wholesale and warehouse marijuana and marijuana products;
Sell non-infused food, water, and drink items that are pre-packaged and shelf-stable; and
Sell, allow sales, or delivery of non-infused food or drinks for consumption on-site, with prior authorization from the Department of Public Health and local Board of Health.

The following operational requirements and restrictions are also notable:

For a licensee with an Indoor Smoking Consumption Area, the facility must be designed with a ventilation system that directs air to the outside of the building through a filtration system sufficient to remove smoke and vapor and mitigate odor at the property line.
No more than 3.5 grams of marijuana flower, and no more than two servings of marijuana-infused products that do not exceed 10 milligrams of Delta-9 THC, may be offered to a consumer for consumption at one time.
A Hospitality On-Site Consumption licensee or a Marijuana Event Organizer licensee cannot allow consumption in a space that is shared with another entity serving alcohol, unless there is a physical barrier separating the spaces or alcohol sales are not offered at the same time as consumption of marijuana.
Consumers must be offered a sealed exit bag to take unconsumed or partially consumed marijuana or marijuana products from the premises.
All venues must offer a designated Cooling Down Area where a consumer may spend time to allow the effects of consumption to dissipate.

Social Consumption Establishment License Type Details

Supplemental On-Site Consumption License

Allows eligible Retailers, Cultivators, Product Manufacturers, Microbusinesses, Craft Marijuana Cooperatives, Third-Party Transporters, or Delivery Operators to sell marijuana products to consumers for consumption in a designated consumption area within the Marijuana Establishment’s licensed premises.
Must be located within an approved Marijuana Establishment that has the same Persons or Entities Having Direct or Indirect Control.
The license application fee would be $1,500, and the annual license fee would be $5,000.

Hospitality On-Site Consumption License

Allows eligible applicants or licensees to establish a new business or operate within an existing Non-Cannabis Entity to sell marijuana products to consumers for consumption within a designated consumption area.
The license application fee would be $1,500, and the annual license fee would be $5,000.

Marijuana Event Organizer License

Permits eligible licensees to coordinate Temporary Consumption Events by submitting an Event Plan for approval by the Commission.
Can conduct no more than 24 single days of permitted sales and consumption activity during a calendar year and cannot host more than 5 consecutive days of sales and consumption activity at Temporary Consumption Events.
May operate a warehouse for the storage of finished marijuana products and marijuana accessories and for the preparation of sale to consumers at Temporary Consumption Events; otherwise, must disclose to the Commission all licensed Marijuana Establishments proposed to conduct retail sales at each Temporary Consumption Event.
Must obtain all the necessary local permitting required where the Temporary Consumption Event is proposed to be located prior to the Commission’s approval of an Event Plan.
Must submit an Event Plan no later than 90 days in advance of the planned date of the Temporary Consumption Event.
Sales or consumption of alcohol or tobacco cannot occur during the same time and within the same premises as the Temporary Consumption Event.
The license application fee would be $1,000, and the annual license fee would be $5,000. A $250 site review fee for each proposed event would also be required.

Exclusivity, Ownership and Control Restrictions, and Hosting Compensation

For the first 60 months from the date that the first Hospitality On-site Consumption Licensee receives a notice to commence operations, Social Consumption Establishment licenses would be limited on an exclusive basis to:
- Businesses controlled by and with majority ownership comprised of Economic Empowerment Priority Applicants or Social Equity Program (SEP) Participants;
- Microbusinesses; and
- Craft Marijuana Cooperatives.
A Person or Entity Having Direct or Indirect Control may be granted or hold up to three Social Consumption Establishment Licenses of each type.
Hospitality On-Site Consumption licensees and Marijuana Event Organizer licensees would be prohibited from conveying an ownership or control interest in the license as a condition of being housed or hosted by a Non-Cannabis Entity, unless the Social Consumption Establishment licensee and the Non-Cannabis Entity share the same Persons or Entities Having Direct or Indirect Control.
Hospitality On-Site Consumption licensees and Marijuana Event Organizer licensees would be permitted to pay a set fee or rent to a Non-Cannabis Entity for housing or hosting social consumption operations, but offering the Non-Cannabis Entity a percentage or portion of sales would be prohibited.

Agent Registration Badging

The draft amended regulations also propose changes to the Marijuana Establishment Agent registration process for all marijuana business license types, which aim to reduce redundancy and streamline efforts for both licensees and Commission staff.

An individual would be issued a single Marijuana Establishment Agent Registration card covering all licenses held by licensees that have the same Persons or Entities Having Direct or Indirect Control.

This change would eliminate the need for a Marijuana Establishment Agent to maintain multiple registrations while working for a corporate entity that holds multiple licenses.

Public Comment Period and Looking Ahead

The Commission is accepting comments on the proposed amended regulations, and interested stakeholders are encouraged to submit written comments via email to Commission@cccmass.com with the subject line “Regulation Comment”. The Commission will also hold a public hearing on September 8, 2025, for interested individuals to provide oral testimony directly to the Commission.

After the promulgation of final regulations in the coming months, the Commission will still need to implement a licensing process for the new Social Consumption Establishment License types.

Any municipalities that opt in to allowing Social Consumption Establishment licensees to operate within their borders will also need to develop their own local approval and permitting processes.

If you have any questions or would like to schedule a call with a Vicente LLP team member to discuss the proposed amended regulations and Social Consumption Establishment licensing opportunities, please contact us at boston@vicentellp.com or 617-934-2121.