Action Alert! Protect Value-Added Cannabis Products!
The Cannabis Control Board (CCB) is in the process of revising their rules, including the consideration of cuts to Rule 2.2.4 regarding value-added cannabis products. Cannabis manufacturers need your support now - please express your concerns about banning cannabis value-added products and allow this industry to become successful!
Please consider a two-pronged Call to Action!
Details and instructions below.
Submit a comment to the CCB.
Submit a comment to Governor Scott’s office.
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On July 19, 2023, the CCB will vote on a proposed amendment to Rule 2.2.4 banning the sale of refrigerated and frozen cannabis products as well as any cannabis products containing meat and dairy. This proposed amendment will have significant, far-reaching negative and deeply impactful consequences for licensees, stakeholders, and ultimately, Vermonters, who will not benefit from the significant tax revenue potentially generated by this sector of the Vermont cannabis industry.
The proposed changes read:
Cannabis establishments shall:
(f) not produce any product that contains any meat or meat products;
(g) not produce any dairy product as defined in 6 V.S.A.§ 2672;
(h) not produce any product that requires time and temperature control for safety
Citing limited capacity as the main reason for the CCB’s inability to enforce/monitor temperature sensitive products, we ask Governor Scott and his administration to encourage cooperation and collaboration between the CCB, Department of Health, and the Agency of Agriculture and to instruct these agencies to fulfill their responsibilities in conducting food safety inspections of cannabis products and enforcing regulatory compliance. It is clear that administrative shortcomings are forcing the CCB to revise this rule to adapt to limited agency capacity. Governor Scott recently allowed H.270 (now Act 65) to pass into law without his signature but with a critique of the CCBs authority: “As an independent entity, the CCB regulates a multi-million-dollar industry with no oversight. Again, while I have complete confidence in the current CCB, this lack of oversight creates the risk for future mismanagement, conflicts of interest and other harmful impacts.” The legislature intends with the new law to increase the competitiveness and marketability of value added products by increasing the milligrams of THC allowed in a single package to 100 milligrams; and by now allowing cannabis producers to take back for resale products which they contracted manufacturers to produce from their plants.
Provide Public Comment to the CCBs proposed rule changes (by Mon., July 17!).
Ask the CCB to implement the legislative intent to increase the competitiveness and marketability of value-added cannabis products by voting against the relevant changes to Rule 2.2.4
> Contact: the CCB through their Public Input Form HERE or through the linked blue button above
> Subject: click Rule 2: Regulation of Cannabis Establishments
> Sample Message (Copy, Paste, Customize!):“The legislature just verified their intent to increase the competitiveness and marketability of value-added cannabis products with passing Act 65 into law that increases the milligrams of THC allowed in such products as well as allowing cannabis producers to take back for resale products which they contracted manufacturers to produce from their plants. I’m asking the CCB to vote against those proposed changes to Rule 2.2.4 that would impede the development and marketability and thus competitiveness of value-added cannabis products manufactured in Vermont by banning those products that contain meat or dairy products or require temperature control for food safety. In the recent Board meeting on June 26, 2023, it was recognized by regulators that other state AU markets regulate and allow temperature-sensitive products and meat and dairy products and that Vermont should, too.I will also be asking the Governor to ensure the needed collaboration among agencies to secure a successful implementation of the standing cannabis law and legislative intent. Respectfully, ....”
2. Ask Governor Scott to hold his administration accountable to cultivate the inter-agency cooperation needed to successfully produce and market value-added cannabis products in Vermont!
> Contact: Governor Scott HERE or by clicking the linked blue button above or leave a voicemail by calling (802) 828-3333!
> Subject: Protect the competitiveness and marketability of value-added cannabis products and ensure inter-agency collaboration
> Sample Message (Copy, Paste, Customize!):
“Dear Governor Scott, The legislature just verified their intent to increase the competitiveness and marketability of value-added cannabis products with passing Act 65 into law that increases the milligrams of THC allowed in such products as well as allowing cannabis producers to take back for resale products which they contracted manufacturers to produce from their plants. You have expressed your concerns regarding the CCBs authority, naming a risk for mismanagement, conflicts of interest and other potentially harmful impacts when you allowed Act 65 to pass into law. I’m reaching out to you now because I’m deeply concerned about the CCBs proposed changes to Rule 2.2.4, which would impede the development and marketability and thus competitiveness of value-added cannabis products manufactured in Vermont by banning those products that contain meat or dairy products or require temperature control for food safety due to lack of interagency support from the Department of Health and the Vermont Agency of Agriculture.
The Vermont excise tax revenue collected on cannabis and cannabis products has recently surpassed the tax revenue collected on alcohol. Regulated cannabis is a significant share of the state economy. The agency tasked with regulating cannabis and cannabis products should not be prevented from performing its duties and risk its growing revenue stream by other agencies' unwillingness to support them. Please be in touch with the CCB, the Department of Health and the Vermont Agency of Agriculture, Food, and Markets to ensure the needed collaboration among agencies to secure a successful implementation of the legislative intent and to protect the competitiveness and marketability of value-added cannabis products. Respectfully, ....”