DCC licensee updates: what’s changed and what’s coming

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For cultivators, manufacturers, and most licensees.

Product sampling and quality assurance reviews

DCC and its representatives can test any cannabis or cannabis product that a licensee, their agents, or their employees have, control, or use. This can happen at any time, without notice, as part of an inspection, investigation, review, or audit. If you don’t provide the cannabis or products they ask for, you could face disciplinary action, including a notice to comply or a citation and fine. The rule is CCR title 4, section 17800.

Your operating name, and when you have to register it

If you do business under any name other than your legal business name, you need to register it with your county and add it to your DCC license record. That applies to a trade name, a doing-business-as (DBA) name, or a fictitious business name (FBN). If you don’t, DCC can issue a compliance or licensing action.

To add or change an operating name, the designated responsible party (DRP) submits a completed Form 27 from the email address listed for them in the license record, within 14 days of the change. One crossover note for anyone doing retail sales or temporary events: if you operate under a DBA, that name also has to appear on your employees’ badges. The relevant sections are CCR 15023 (business modifications) and CCR 15043 (employee badge requirement).

Using “organic” or “OCal” on your labels

The OCal certification program, run through the California Department of Food and Agriculture (CDFA), marks cannabis grown with organic practices so consumers can tell it apart on the shelf. You can only use the OCal seal, or organic language, if you’re certified. CCR section 17408 prohibits false or misleading information on product labels, and a false or misleading claim can bring a compliance action from DCC, up to a notice to comply or a citation and fine.

This one hits close to home. Nevada County has one of the highest rates of OCal-certified cannabis businesses in the state, and that says something about how our farmers grow. If you’re already certified, double-check that your labels match your status. And if certification is on your list, we teach a series on earning OCal through the nonprofit CCOF. Register for the free November webinar on getting OCal Certified.

We have someone in our network, Matt Hayashi with Cannabis Clearwater, who teaches a highly recommended OCal Certification Course. Alliance members get 15% off. Register for the course here.

Packaging, the Image Analyzer, and a 2028 change to watch

DCC’s Cannabis Product Image Analyzer (CPIA) lets you upload a photo of packaging or a label and get an AI-generated read on whether it may be attractive to children under CCR section 15040. Features flagged as attractive to children include:

• Images of minors or anyone under 21

• Cartoons

• Likenesses of images, characters, or phrases used to advertise to children

• Imitations of candy packaging or labeling

• The words “candy” or “candies,” or respelled variants like “kandy” or “kandeez”

Looking ahead: on August 31, 2026, the Governor signed AB 2249, which sets clearer standards for when packaging, labeling, advertising, or marketing counts as attractive to children. It takes effect January 1, 2028. The law names specific design features that may appeal to youth, including cartoons, certain characters and imagery, and child-oriented fonts, and it prohibits packaging that mimics non-cannabis children’s products along with overly stylized fruit imagery on edibles and vape products. DCC plans to release resources before 2028 to help you check your packaging, including updates to the Image Analyzer tool.

Industry-wide: federal rescheduling

The U.S. Department of Justice and the Drug Enforcement Administration (DEA) have opened registration for medicinal cannabis manufacturers, distributors, and testing laboratories. If you’ve already registered, you don’t need to do it again.

None of this should be read as advice on whether or how to take part in the federal medicinal cannabis program. If you need guidance, talk to your legal counsel. DCC says it will keep adding federal updates as they’re released, and it keeps federal rescheduling resources posted on its website.

For retailers

Two reminders worth a quick look if you sell at retail.

Daily purchase limits for adult-use customers. In a single day, one adult-use customer can buy up to 28.5 grams of non-concentrated cannabis (dried flower), 8 grams of concentrate (oils, waxes, and the like), or 6 immature plants. For products that contain both flower and concentrate, retailers apply the flower weight toward the non-concentrated limit and the concentrate amount toward the concentrate limit. Medicinal patient limits can differ. The rule is CCR section 15409.

Consumer brochure. DCC and the California Department of Public Health (CDPH) created an informational brochure that all storefront and non-storefront retailers, including microbusinesses with retail, must display and provide: at the point of sale, at in-person delivery, and online at the time of purchase. You also have to offer a copy to every new customer. It’s available to download on the DCC website.

Not sure how one of these changes lands on your operation? That’s what we’re here for. Reach out to our office and we’ll walk you through any of it. For DCC’s own guidance on applications, renewals, and current and upcoming regulations, start at cannabis.ca.gov, and their Community Relations Office answers questions at info@cannabis.ca.gov. One catch worth remembering: if your question is about a specific application or license, the email has to come from the designated responsible party, from the address on file, and include the application or license number.