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Closing a Licensed Marijuana Business

The below information is to provide licensees with further instruction on how to properly close a licensed marihuana business with the Cannabis Regulatory Agency (CRA). 

Prior to expiration or relinquishing a license ALL the following items must be completed in Metrc:

  1. All transfer manifests must be cleared meaning no pending incoming or external transfers
  2. All packages must have a zero quantity and finalized, or be discontinued
  3. All remaining product and/or plants must be destroyed or transferred. Some transfers may require CRA approval in compliance with the administrative rules
  4. All harvest batches must be packaged and marked as finished in Metrc
  5. All sales must be finalized and uploaded in Metrc
  6. Licensee should print any reports or inactive data from Metrc for their records. Please note: once license is closed licensee will no longer have access to Metrc

The CRA will allow a one-time transfer exception with approval when a medical license is expiring, or relinquished.  This exception would allow the transfer of product from a medical license to an equivalent adult-use license (with common ownership). 

Transfers will only be considered if the following are completed:

  1. The licensee provides a written date the licensee agrees to cease operation. This information should be provided to licensing and included in the email requesting product transfer
  2. The sending and receiving business have common ownership
  3. Any product that is not transferable must be destroyed or sold as allowed by the administrative rules
  4. All packages requesting to be transferred must be compliance tested and test results reported in Metrc. The following products are ineligible for transfer:
    • Untested product
    • Unsourced caregiver product
    • Product on administrative hold
    • Expired edibles
    • Products exceeding the allowable THC limits
  5. Before a transfer will be approved, the inventory must be reconciled and any products identified in number 4 above will need to be resolved in Metrc or the transfer request will be denied
  6. All harvest batches have been packaged and harvest batch marked as finished in METRC

Please note that once Cannabis Regulatory Agency has approved this one-time exception transfer, the approved packages must be transferred, and license closed within 3 days.

Additional Information

  • Cannabis Regulatory Agency (CRA) may allow a one-time transfer of product from a medical to an adult-use license if the medical license is expiring and the licensee is not renewing.  
     
    For product to be eligible for transfer the below items must be meant:
    • The sending facility and receiving facility are equivalent licenses 
    • Transfers are between the medical facility and the adult-use establishment
    • The sending and receiving businesses have common ownership
    • Receiving establishment license is in good standing 
    • Product remaining in the expiring license is eligible for transfer and all non-transferable items have been sold or destroyed and appropriately documented in Metrc.
    • Outstanding Metrc functions are completed for expiring license (harvest batches finished, no pending transfers, all packages at a quantity of 0 or discontinued, etc.)
    Criteria for product to be eligible for transfer:
    • Edibles/Infused products have to be within the THC allowable limits for the adult-use market, not expired, and labeled properly.
    • Product must be tested and results from testing in Metrc
    • Harvest batches must be packaged, issued a Metrc package tag, and marked finished in Metrc.
    • Product cannot be derived from caregiver product.
    • Product cannot be on administrative hold.
    Transferring product between markets requires prior approval from Cannabis Regulatory Agency (CRA).  Transfers between the same market may or may not require prior approval.  
    To request a transfer, CRA would require a licensee to submit the “Transfer Request Form” to CRA-compliance@michigan.gov.  This form will be considered for approval only if the license grace period is ending in the next 30 days and request should be made no later than one week before the grace period ending. 
  • Cannabis Regulatory Agency (CRA) will allow a licensee to relinquish their license.  When a licensee relinquishes their license, the below items must be completed:
    1. The “license closure form” must be completed, sign and submitted.
    2. Licensee must provide CRA with a date they agree to cease operations
    3. All Metrc transfers/manifest must be cleared. 
    4. All Metrc packages must have a zero quantity, or the package must be discontinued.
    5. All remaining product and/or plants must be destroyed or transferred (Transfers may require CRA approval).
    6. All harvest batches must be packaged and marked as finished in Metrc.
    7. All sales must be finalized and uploaded into Metrc.
    8. All reports or inactive data from Metrc should be printed, for their records. 
    CRA will allow a one-time transfer of product for licensees that choose to relinquish their license if the below items are met:
    1. The sending facility and receiving establishment are equivalent licenses and have common ownership.
    2. An agreed upon date has been established for when the license is going to cease operation.
    3. Transfers are from the medical market to the adult use market.
    4. Receiving establishment license is in good standing 
    5. Product requesting to be transferred is eligible for transfer and all non-transferable items have been sold or destroyed and appropriately documented in METRC in accordance with the administrative rules.
    6. Outstanding METRC functions are completed for expiring license (harvest batches finished, no pending transfers, all packages at a quantity of 0 or discontinued, etc.)
    The one-time transfer requires CRA approval.  To request a transfer, complete the “Transfer Request Form” and submit to CRA-compliance@michigan.gov.
     
  • When a purchase/asset agreement has been processed through CRA’s licensing division, several steps are required to close the old license.  These steps below MUST be completed prior to the new license starting operations. 

    1. All Inventory must be transferred or destroyed and recorded in Metrc in accordance with the administrative rules. Transfers for medical licenses must receive CRA approval.  All transferred items (regardless of the requirement for approval) must meet the transfer criteria. 
      • Assistance from Metrc Support may be available for a one-time large transfer of existing inventory to the newly purchased license.  CRA approval is required please submit a One-time Transfer request form, if approved the CRA will notify Metrc support.
    2. All transfers/manifest must be cleared.
    3. All harvest batches must be packaged, assigned a Metrc tag and the harvest batch marked as finished in Metrc.
    4. All sales receipts must be finalized, and final adjustments made.
    5. Export and save all needed information from Metrc. Once the license is made inactive, the licensee will no longer have access to Metrc.

    Purchasing license must ensure that they are credentialed in Metrc and obtain Metrc package and/or plant tags prior to the transfer of product.

    Both licenses (old license and newly purchased license) cannot be in operation at the same time.

    For large purchase agreements with multiple licenses: all items must be completed for each license prior to the new licenses starting their operations. 

  • When a licensee has upgraded their license (example: AU-MB-000000 to AU-MB-A-000000), the old license needs to be closed immediately. 

    The following items need to be completed for the old license:

    1. All transfers/manifest must be cleared.
    2. All packages must have a zero quantity, or the package must be discontinued.
    3. All remaining product/packages and/or plants must be destroyed or transferred. Transfer of product for a license upgrade requires CRA approval.
    4. All harvest batches must be packaged, assigned a Metrc tag and the harvest batch marked as finished in Metrc.
    5. All sales must be finalized and uploaded into Metrc.

     Upgraded license will need to complete the following tasks prior to starting operations:

    1. Must ensure that they are credentialed in Metrc
    2. Obtain Metrc package and/or plant tags prior to the transfer of product.

    Both licenses (old license and newly purchased license) cannot be in operation at the same time.

    Please note: if the upgrade does not include all required license types for the product an example would be if a microbusiness is upgrading to a marihuana grower class A and a retailer but they are not applying for a processor, if there are products which are unable to be at a grower or retailer for example bulk concentrate, these will need to be destroyed or finished, tested in final form before the license can be closed. 

To Request a Transfer:

The CRA requires a licensee to submit the below transfer request form to CRA-compliance@michigan.gov.

Plant Transfer Request Form
AU to MED Transfer Request Form
MED to AU Transfer Request Form
One-Time Transfer Request Form

To Relinquish a License:

Before requesting to relinquish a license, complete all of the required METRC steps. Once completed, the following form can be completed and submitted to CRA-Amendments@michigan.gov.

Request to Close License Form