Skip links

DC Cannabis Trade Association (DCCTA) Proposes Changes to “Medical Cannabis Amendment Act of 2021”

Transition License Process as Currently Written Threatens to Put DC’s Medical Cannabis Program Out of Compliance with Federal Law


“Internet Retailers” Provision Included – An Entirely New Concept that has not Been Thoroughly Reviewed or Vetted – And Was Put in After Public Comment Period


Washington, DC – Following the DC Council’s markup of Bill 24-113, the “Medical Cannabis Amendment Act of 2022,” the DC Cannabis Trade Association (DCCTA) expressed its concerns about the bill in a letter to DC Council Chairman Phil Mendelson. DCCTA has worked tirelessly over many years to enable patients to access safe and effective cannabis therapeutics, in accordance with strict laws and regulations passed by the Council and implemented by DC regulatory agencies. However, this legislation in its current form would undermine years of efforts to build and foster a regulated cannabis marketplace in D.C. that effectively balances the needs of patients and our local communities.

First, transition licenses risk DC’s program coming out of compliance with various federal laws. Transition licensees must be required to maintain seed to sale tracking to ensure all cannabis comes from within the District of Columbia. Failure to enforce that means DC is actively condoning drug trafficking across state lines.

Additionally, allowing unregulated shops to automatically convert is a shameful exclusion of DC residents who have cannabis convictions, have abided by the law since, and have waited years for a legal license application process to open.

The legislation also creates an “internet retailer,” an entirely new concept that has not been thoroughly reviewed or vetted. This was added after the most recent public comment for this bill, which was in November of 2021, and fails to provide specific regulations to govern the operations of this new license class. The delivery of cannabis is already permitted in the District and the new courier license will help Social Equity applicants enter the marketplace.

DCCTA also expressed concerns about the lack of caps on the numbers of licenses to be issued and the lack of any requirement to assess whether new licenses are needed to meet patient needs. Caps on the number of licenses and greater distances between stores are vital for a healthy marketplace.

“We ask the DC council to slow this process down to allow for public comment, proper review of implementation details, and appropriate legal vetting to ensure DC’s cannabis program complies with federal law,” said Linda Mercado Greene, Chair of DCCTA. “The Council must ensure the program achieves true social equity goals, which the current draft fails to accomplish.”

Illegal operations have threatened to severely cripple DC’s cannabis industry. In recent years, the number of cannabis operations without business licenses has grown rapidly. These operators pay nothing to the DC government in taxes – unlike the legal, medical dispensaries who have borne the brunt by having to pay steep fees to stay in business.

Illegal operators are not overseen by any of the District’s government agencies, so their products do not get the same scrutiny as legal, medical dispensaries.

The bill will now head to the Committee of the Whole where it will be marked up.