California Officials Propose Cannabis Cultivation Rule Changes Focused on Sanitation, Harvest Tracking, and Nursery Operations

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California’s Department of Cannabis Control has issued a formal notice of proposed changes to state cultivation regulations that would significantly reshape how marijuana growers, nurseries, processors and other licensees operate, particularly when it comes to sanitation practices, harvest tracking, nursery activity, and temporary cannabis events. The proposal, released as part of DCC rulemaking DCC-2025-01-R, updates large portions of Title 4, Division 19 of the California Code of Regulations. Public comments are being accepted through April 28, with a public hearing scheduled for April 29.

At the core of the proposal are two themes: removing what the Department calls “superfluous, redundant, or expired” requirements that cultivators have struggled with for years, while simultaneously adding strict, clearly defined sanitation standards aimed at reducing contamination, adulteration, and product recalls in the licensed market.

One of the most notable changes is the elimination of several renewable energy, electricity reporting, and carbon offset requirements that indoor and mixed-light cultivators have been required to track and submit during license renewals. The Department says this change will reduce administrative burden for both licensees and inspectors, while having a neutral fiscal impact overall.

The proposal also removes the requirement for cultivators to create and maintain formal pest management plans and certain related attestations, instead focusing on direct compliance with pesticide laws enforced by the Department of Pesticide Regulation.

In place of those removed requirements, the Department is introducing detailed minimum sanitation standards that would apply to any licensee who handles unpackaged marijuana, including trimming, harvesting, processing, or packaging.

Under the proposed rules, tools such as scissors, sifters, and funnels must be cleaned and sanitized daily and between harvest batches. Equipment like trimming machines, tables, tarps, trays and rolling machines must also be sanitized daily. Containers used to store or transport harvested marijuana must be sanitized between batches and at the beginning and end of each growing season.

The regulations even specify acceptable sanitation methods, including chlorine solutions, iodine solutions, quaternary ammonium, and 70% isopropyl alcohol, with minimum contact times required.

The proposal also introduces formal handwashing and glove requirements for anyone handling unpackaged marijuana. Workers must either wash their hands for at least 15 seconds with soap and potable water before performing tasks or don new, single-use, food-safe gloves.

Animals, other than service animals, would be explicitly prohibited from entering indoor licensed areas or any outdoor area used for processing or packaging marijuana. Any animal waste discovered on a licensed premises would need to be removed immediately.

Beyond sanitation, the Department is also tightening and clarifying how harvest batches are tracked in the state’s track-and-trace system. Harvested plants hanging, drying, or curing must be clearly separated from other batches with visible boundaries and labeled with a harvest batch name that matches exactly what is entered into the system. Package tags must be assigned within 24 hours of processing completion, and all containers with the same UID must be kept contiguous to aid inspections.

Cultivators would be required to record wet weight immediately after harvest, waste weight, the initiating date of the harvest, and formally mark when the harvest is finished after drying, curing, trimming and packaging.

The rulemaking also includes important changes for nurseries and propagation. Under the proposal, cultivators who want to propagate immature plants or seeds for distribution to other licensees must hold a nursery license. However, cultivators would now be allowed to transfer immature plants and seeds to a licensed nursery via a distributor, and licensees holding multiple cultivation licenses would be allowed to transfer immature plants, seeds, or harvested marijuana between their own licensed premises through a distributor.

Another significant change involves canopy calculations. The proposal clarifies that canopy includes any area where mature plants may exist at any time, including plants used for seed production or research. If shelving is used, each level’s surface area must be included in total canopy calculations. These areas must be clearly labeled on premises diagrams.

The Department is also proposing to extend the allowable length of temporary cannabis event licenses from a maximum of four days to up to 30 consecutive days, a change that could substantially impact cannabis event organizers across the state.

According to the Department’s economic assessment, most marijuana businesses will incur minor annual costs ranging from roughly $1,800 to $4,200 due to the sanitation requirements. However, some indoor cultivators may realize savings of up to $800 annually due to the removal of electricity reporting and carbon offset requirements. The Department estimates around 17 jobs could be eliminated as a result of the changes but says the overall effect on businesses statewide is minimal.

The Department says the primary goal is public protection, citing increasing cases of contamination and adulteration of marijuana products that have led to embargoes and recalls. Officials say improved sanitation practices will directly improve product quality and indirectly improve worker safety.

The proposal affects an estimated 3,200 businesses statewide, roughly 90% of which the Department considers small businesses.

Public comments on the proposal are being accepted by mail or email through April 28, with the rulemaking file, proposed text, and supporting documents available through the Department’s website. A virtual public hearing will be held April 29 for stakeholders who wish to provide testimony.