City of Los Angeles Set to Accept Cannabis Delivery, Distribution, Non-Volatile Manufacturing, and Testing Lab Applications

On October 5, 2020, the City of Los Angeles Department of Cannabis Regulation (“DCR”) posted a notice on its website. Per the notice, DCR will begin accepting commercial cannabis license applications for distribution, non-volatile manufacturing, testing labs, and delivery on October 20, 2020 at 2:00 pm. Application processing for distributors, non-volatile manufacturers, and testing labs will be widely available to all those interested in applying. However, delivery application processing will initially only be available to previously verified Social Equity Applicants. Applicants applying for a delivery license must be verified as a Social Equity Individual Applicant pursuant to LAMC Section 104.20(a)(1).

Note: The DCR will provide information about how to be verified as a Social Equity Individual Applicant under the expanded eligibility verification criteria, pursuant to LAMC Section 104.20(b), later this calendar year. Upon verification, eligible Applicants will be able to submit commercial cannabis license applications for delivery, as this processing period for such licenses will be indefinite.

General Steps in the Los Angeles Cannabis License Application Process

1. Everyone who applies for one of the aforementioned licenses will first be required to complete the DCR’s Pre-Application Review process. If an applicant is deemed eligible pursuant to the pre-application review process, it will move onto step two. 

2. After being deemed eligible for further processing for one or more license types, Applicants will then need to complete the DCR’s Temporary Approval process . If approved, the temporary approval process will enable the applicant to engage in commercial cannabis activity (assuming the applicant has also received a state license to operate). 

Note: All applicants will receive invoices for the Pre-Application Review and the Temporary Approval fees. Such fees will be assessed in compliance with LAMC Section 104.19(a) and need to be paid within ten (10) days of receipt. 

Preparing for the Application Process

To prepare for the application window opening, applicants can visit the DCR’s website to review related Application Procedures and Resources.

To access the forms related to each part of the application process, please visit the DCR’s Application Forms and Documents page. There you can download and fill out the form necessary for the Pre-Application Review Process and the Temporary Approval Process. By visiting the DCR Application Forms and Documents page, you can also see what other documents are required during the application process. 

Process Information

Pre-Application Review Process

During the Pre-Application Review Process, the (DCR) will determine whether the applicant’s Primary Personnel (those subject to a background review pursuant to LAMC Section 104.03(a)(1)) are eligible to participate in the project and verify that the Owners (as defined by the LAMC) applying for the license are not disqualified under LAMC Section 104.03(a)(2). 

The DCR will accept attestations regarding compliance with LAMC Section 104.03(a)(1) until live scan background checks are available. During the Pre-Application Review Process the DCR must also verify that the Business Premises location proposed is eligible for Licensure under LAMC Section 104.03(a)(3). 

As a reminder, Primary Personnel convicted of any of the following offenses within the time specified are prohibited from applying for or holding a Temporary Approval of License:

  1. Illegal volatile Cannabis manufacturing under Health and Safety Code Section 11379.6 for a period of five years from the date of conviction.
  2. A violation of any State or local law involving wage or labor for a period of five years from the date of conviction.
  3. A violation of any law involving distribution of Cannabis to minors for a period of five years from the date of conviction.
  4. Illegal Commercial Cannabis Activity after April 1, 2018, for a period of five years from the date of conviction. 
  5. A violation of any State or local law involving distribution or sales of tobacco or alcohol to minors for a period of five years from the date of conviction. 
  6. A violent felony as defined in California Penal Code Section 667.5, a serious felony conviction as defined in California Penal Code Section 1192.7, or a felony conviction for violating any law involving violent crimes, sex trafficking, rape, crimes against children, gun crimes or hate crimes for a period of 20 years from the date of conviction or completion of a term of imprisonment, supervised release or probation imposed as a sentence for the conviction, whichever is later. 
  7. A felony conviction for a crime involving fraud, deceit, or embezzlement for a period of 20 years from the date of conviction. In addition, an individual with a felony conviction under this paragraph shall be prohibited from serving as an authorized agent or agent for service of process on any Application.

Additionally, Owners are prohibited from applying for or holding a Temporary Approval or License if:

  1. The Owner is an individual who holds office in, is employed by, or is appointed to, any agency of the State of California and any of its political subdivisions, including the City and any of its agencies, departments, commissions or boards, when the individual’s duties include the enforcement or regulation of Commercial Cannabis Activity or any other penal provisions of law of the State of California prohibiting or regulating Commercial Cannabis Activity. 
  1. The Owner is an entity that is incorporated outside of the United States

Temporary Approval Process

Once an applicant’s personnel and location have been verified as eligible through the Pre-Application Review Process, the applicant will move onto the Temporary Approval Process. Assuming the applicant has prepared its Temporary Approval application information ahead of time, this process will be relatively simple. The Temporary Approval Process steps released by the DCR are as follows:

  1. After receiving a determination of eligibility from DCR, upload the Temporary Approval application information and, if applicable, follow the procedures in the Social Equity Program – Entity Verification Information and Procedure Bulletin. 
  2. Pay the Temporary Approval Application Fee.
  3. Pay additional fees, if any, for DCR to review documents that must be re-submitted
  4. Obtain authorization from the applicable State licensing authority to conduct the Commercial Cannabis Activity(ies).
  5. Prepare for and schedule the Initial Inspection with DCR.
  6. Prepare for the LAFD Inspection.
  7. Resolve any deficiencies which may be discovered during an inspection, and/or schedule a follow-up inspection.
  8. Pay the Standard Inspection Fee if an additional inspection is necessary by DCR.

City of Los Angeles Department of Cannabis Regulation Resources

The DCR has prepared workflow visuals for both the Pre-Application Review Process and the Temporary Approval Process. Click the links below to access the visuals. 

Pre-Application Review Process Workflow Visual

Temporary Approval Process Workflow Visual

Additionally, the DCR released information and procedure bulletins for both the Pre-Application Review Process and the Temporary Approval Process. Both bulletins are linked below for your use. 

Pre-Application Review Information and Procedure Bulletin

Temporary Approval Information and Procedure Bulletin

If you would like more information about how to prepare to submit a cannabis license application for the City of Los Angeles on October 20, 2020, please contact or call Rogoway Law Group to schedule a consultation.

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