December 31st- Countdown To The Next Deadline

December 1st is around the corner. And, while many of you are still reeling from the new testing requirements, struggling to get on the shelves or working through failed tests, there is another deadline approaching. In the chaos of the last few months I wanted to send out a quick reminder.

Two things- early sales ends and you must have your processor license, like in your hands, by January 2017.

Early sales: This should come as no surprise for anyone. The Oregon Legislature did this industry a huge solid by letting the adult use market open early. First for flower and then for oil, edibles, etc. But, that is about to wind down. As of January 1st, medical dispensaries go back to being medical dispensaries and adult use customers can only buy cannabis from OLCC licensed dispensaries. If you are a producer, retailer or processor you fall back into your lane. If you operate under OHA you are back to OHA stores. If you have an OLCC license, then you can only sell to OLCC stores.

The challenge with this deadline are the numbers. There are only 12 OLCC licensed processors with 5 waiting to pay (193 have applied), 64 licensed dispensaries with 31 waiting to pay and 319 licensed producers (917 have applied). There are 429 licensees total with 59 waiting to pay. There are 1693 pending applications and 767 have been assigned out. If this year is any indication, then just the assigned out licenses might take the next 2 years to issue. This is not for lack of trying. There are no more dedicated and hard working people than the inspectors. They are, seriously, killing themselves to move quickly. If you are working with one, say thank you.

These numbers matter for a lot of reasons but they mostly matter because they are an indication of how many people were anticipating having an OLCC license, most likely by the end of this year, so they can continue to sell to adult use customers. I am suggesting, maybe a little early, that we should all be thinking about the impact of so many businesses going back to just being medical and, maybe, if there might be a fix to extend early sales. This industry does not need any more market disruption and this is about to be a huge problem.

Processor licenses: The OHA has a provisional list. If you are a processor and are selling into the market right now, you need to be on it. By the end of the year you need a real medical or OLCC processor license. Do you know even one person with a medical processor license in their hands? Me either. We are 38 days away from the end of the year. The OHA is still reviewing dispensary applications from spring as well as processing renewals from way, way back. I don’t know anyone who has received a medical card in a timely fashion. There are 140 processors on the provisional list. If you think OHA is getting to everyone on that list in 38 days, I would not bet on it. That means any processor, of any type, without one of the above licenses will cease operating in 38 days.

I know many of you are tired and still working through October 1st, but we should not ignore the next deadline. If we start now, maybe we can get OLCC, OHA and the Governor’s office to make some adjustments so January 1st is not as disruptive and October has been.

(On a positive note, we hear testing changes are coming next week.)