Colorado Criminal Defense - Medical Marijuana Business Consultations
My Blog

December 2010

Change of MMC license class

43.3- 300 on page 83 says a change in MMC class, moving from a 0-300 patient MMC up to a 300-500 patient MMC, is considered an application for a new license.

No indication that you get credit for the license fee you already paid.

A new license could also create moratorium problems.

Change of location

Does 43.3 on page 85 really say that you can not change locations unless it is in the same jurisdiction?  Sure seems to.

70/30 rules makes no sense

Very strict definition of the 70/30 rule. 

First issue, already addressed, is the broad definition of inventory. 

Second issue, is that you are only allowed to sell up to 30% of your yearly crop. Yearly, not daily.

This will hinder wholesale sales for no apparent reason.  What is the big concern if you can track where the medical marijuana came from and where it went?

Note: Sales to IPMs does not count towards the 70/30 numbers.


MMCs inventory will be limited to 6 plants and 2 ounces for each patient that has named them as their Primary Center.

Problem: The definition of "inventory" is too broad.

1) Clones should not count as plants.
2) Leaf, concentrate, and oils are considered part of your "weight.'
3) Product in your MMC and OPCO will be counted as your "inventory."

*Please note they do allow for extra plant count and weight under CRS 12-43.3-901(4)(e)
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