New Colorado Cannabis Testing Requirements Are Now Effective
By Genevieve Meehan
Jul 5, 2024
New regulation changes for Colorado cannabis businesses are underway, including new Reduced Testing Allowance (RTA) requirements from The Marijuana Enforcement Division (MED) and other legislative changes that stores should be ready to implement by August 6.
Read on to learn more about how these recent rule changes may impact your cannabis business operations.
Reduced Testing Allowance
Every harvest and production batch of regulated marijuana is subject to required testing unless a licensee has achieved a Reduced Testing Allowance (RTA) in accordance with applicable rules.
Reminder for all License Types
As of January 8, 2024, all licensees interested in utilizing any RTA privileges were required to submit:
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An attestation form regarding their understanding of the testing rules and requirements
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Payment of the Reduced Testing Allowance Certification fee in Rule 2-205 of $4,000.00. The certification fee is per license and is due at the time of attestation.
Exercising the privileges of Reduced Testing Allowance is voluntary, however, if a licensee chooses to exercise this privilege, it must be in compliance with all MED Rules. Contact us if you have any questions about how to submit the RTA attestation or fee, or if you need support with confirming the compliance of your RTA procedures.
Reduced Testing Allowance for Microbial Contaminant Testing Rules Effective July 2024
Effective July 1, 2024, in order for a Regulated Marijuana Cultivation Facility to achieve a Reduced Testing Allowance for microbial contaminant testing, the licensee must comply with the following additional requirements:
Hazard Analysis and Critical Control Point (HACCP) System - Rule 4-120(B)(1)(b)
To achieve or maintain a Reduced Testing Allowance for microbial contaminants, cultivation facilities must have a Hazard Analysis and Critical Control Point (HACCP) System. A licensee’s HACCP must contain elements defined in ASTM D8250-19: “Standard Practice for Applying a Hazard Analysis Critical Control Points (HACCP) System for Cannabis Consumable Products.”
To streamline the implementation of HACCP Systems, our team has prepared a comprehensive template for licensees to customize. Schedule a meeting with Genevieve Meehan to discuss the details and request a copy of the template!
Reduced Testing Allowance Internal Audit - Rule 4-120(B)(1)(c)
To achieve or maintain a Reduced Testing Allowance for microbial contaminants, Cultivation Facilities must conduct an internal audit to assess substantial compliance with Rules 3-310, 3-330, 3-336, 4-110, 4-120, 5-210(D) and/or 6-210(D), and 5-210(E) and/or 6-210(E).
Cultivation licensees must achieve a passing score by demonstrating at least 80% compliance with the internal audit to achieve and maintain Reduced Testing Allowance privileges. The standard audit checklist can be found here.
Legislative Changes Effective August 6, 2024
During the 2024 Legislative Session, the Colorado General Assembly approved a bipartisan bill, SB24-76, aimed at streamlining the state’s marijuana regulations. This bill takes effect on August 6, 2024. Stores should prepare to implement changes related to new packaging and labeling requirements and the sale of non-cannabis food and beverage items by August 6. Contact Genevieve Meehan to discuss those changes and other highlights from the bill.
CDPHE Hemp Reminder: Annual CDPHE Registration
As a reminder to all CDPHE registered hemp and safe harbor hemp facilities, annual registration deadlines are rapidly approaching. This year, safe harbor hemp facilities will be asked to provide evidence of obtaining a third-party inspection confirming compliance with the current federal good manufacturing practices for food or dietary supplements as required by law.
See details for hemp registration here.
Contact Our Team
We are committed to helping your team ensure compliance with all regulatory state and local requirements. Vicente’s Compliance Team closely monitored these rule changes and is ready to support you with the on-site implementation of procedures and systems to meet these new standards. Click here to schedule a meeting with a member of our Compliance Team to discuss any questions or concerns.