Colorado Marijuana Manufacturing License

Does Colorado Require a Marijuana Manufacturing License to Make Cannabis Products?

Yes. As required by Amendment 64, any person or entity intending to operate a marijuana product manufacturing facility in Colorado must obtain the requisite state license. This license is referred to as a marijuana products manufacturer license. It permits the holder to run a facility that produces cannabis products such as concentrates, edibles, and tinctures. Marijuana products manufacturer licensees can only wholesale their product to state-licensed medical marijuana centers (dispensaries) and retail marijuana stores. The Marijuana Enforcement Division (MED) of the Colorado Department of Revenue (DOR) is tasked with licensing marijuana product manufacturing businesses in the state.

Does Colorado Require Licensed Cannabis Manufacturers to Have Cultivation Licenses?

No. It is not mandatory for licensed marijuana product manufacturing facilities in Colorado to obtain cultivation licenses. However, they can apply for one if they deem it necessary since the Marijuana Enforcement Division (MED) allows a person or entity to hold more than one marijuana business license in the state. The MED considers additional licenses held by a marijuana business separately, even if the different facilities are in the same location. Licensed marijuana products manufacturers can obtain marijuana from MED-licensed marijuana cultivation facilities in the state. A licensed marijuana products manufacturer can also cultivate its own marijuana once it gets a marijuana cultivation license.

How Does Colorado Classify Marijuana Manufacturing Licenses?

Colorado only has only three classes of marijuana products manufacturer licenses. It issues one for medical marijuana product manufacturers and another for retail manufacturers intending to produce adult-use marijuana products. The third manufacturing license is issued by the Marijuana Enforcement Division (MED) as a social equity license, a special kind of license known as marijuana accelerator manufacturer license to enable them to produce cannabis-infused products. This is a sub-type of retail marijuana product manufacturing license. It allows a social equity licensee to operate as marijuana products manufacturer on the premises of an accelerator-authorized marijuana products manufacturer. Usually, a marijuana products manufacturer with an accelerator approval gives financial and technical assistance support to a marijuana accelerator manufacturer.

What are the Different Types of Cannabis Manufacturing Licenses in Colorado?

Colorado's two types of marijuana manufacturing licenses are the medical marijuana and retail (recreational) marijuana products manufacturer licenses. A medical marijuana product manufacturer license allows the holder to establish a facility that manufactures medical marijuana products. In contrast, a retail marijuana product manufacturer license is given to individuals or entities that manufacture recreational marijuana products.

Typically, each of these facilities must prepare their products on licensed premises meant solely for the manufacturing and preparation of marijuana products for which they are licensed. Also, each can only use the equipment exclusively intended for the preparation of their products. It implies that a medical marijuana products manufacturing facility cannot use its premises or equipment to prepare recreational marijuana in Colorado. However, if a local jurisdiction permits, a medical marijuana products manufacturing licensee can share the same premises with a retail marijuana product license holder, provided there is a physical separation of each facility's inventory.

Does Colorado Require a Separate License to Manufacture Edibles?

There is no separate license issued for marijuana edibles manufacturing in Colorado. The marijuana products manufacturer license allows the holder to manufacture and prepare edibles, among other cannabis-infused products. A medical marijuana products manufacturer license authorizes the licensee to manufacture medical marijuana edibles, while a retail products manufacturer license permits its holder to manufacture recreational marijuana edibles.

How to Get a Cannabis Manufacturing License in Colorado

The marijuana licensing authority in Colorado is the Marijuana Enforcement Division (MED), a division under the Colorado Department of Revenue (DOR). Anyone or entity that intends to get a marijuana products manufacturer license in the state must complete the Regulated Business License Application Form and submit it with requisite documents to the MED. While completing this form, an applicant must indicate that they are applying for a new retail or new medical license. They must also select either a medical marijuana transporter or retail marijuana transporter depending on the manufacturing license type of their interest.

The MED requires prospective marijuana products manufacturer licensees to determine their suitability before submitting their applications. As such, it provides two different forms to assist license applicants in finding their suitability. Applicants must complete the appropriate finding of suitability form and submit it with the Regulated Business Application Form to the MED. These forms are:

• The Marijuana Finding of Suitability Application Form - Owner Entity: This is for any entity that holds a minimum of 10% interest of the Regulated Marijuana Business owner's interest, such as:
  • An executive or qualified institutional investor with 30% or more of the Regulated Marijuana Business
  • Any affiliate or entity with authority to exercise control of the Regulated Marijuana Business
• The Marijuana Finding of Suitability Application Form - Natural person: This form is required for any natural person who holds at least 10% interest of the Regulated Marijuana Business owner's interest. Such persons include managers, executive officers, or other individuals who can exercise control of the Regulated Marijuana Business

Any owner entity submitting the owner entity suitability application must also fill out a natural person suitability application form and include it in their application submission.

A marijuana products manufacturer applicant must have their fingerprints taken and submit evidence of complete fingerprinting with their application. Applicants can engage the service of the MED-approved third-party fingerprint vendors in Colorado for fingerprinting. These vendors issue receipts for fingerprinting services rendered, which applicants can use as proof and submit with license applications to the MED.

Besides fingerprinting, a marijuana products manufacturer license applicant in Colorado must also meet specific state and federal employment requirements outlined by the Colorado Department of Labor and Employment (CDLE). The CDLE also provides an employer checklist that prospective marijuana license holders in Colorado can use to ensure compliance with the Department’s laws and regulations. Since marijuana business is regulated, applicants must also obtain a state tax license suitable for their proposed marijuana products manufacturing facility.

The MED requires applicants to pay all requisite fees via checks or money orders and attach the payment proof with their applications. Any fee due to the local jurisdictions where applicants intend to operate their facilities must also be included in the applications but as a separate form of payment. Once the required application and license fees are paid, an applicant can submit their completed application forms and supporting documentation via mail to one of the following MED’s office locations:

Marijuana Enforcement Division

1697 Cole Blvd., Suite 200

Lakewood, CO 80401

Northern Regional Office

Marijuana Enforcement Division

275 South Main Street, Suite 101

Longmont, CO 80501

Southern Regional Office

Marijuana Enforcement Division

2447 North Union Boulevard

Colorado Springs, CO 80909

Western Slope Regional Office

Marijuana Enforcement Division

632 Market Street, Suite G3

Grand Junction, CO 81505

Lakewood Office - MED Headquarters

1697 Cole Boulevard, # 200

Lakewood, CO 80401

The Lakewood office of the MED is the only office that accepts walk-in application submissions. Applicants who opt to deliver their applications in person can do so between 8:00 a.m. and 5:00 p.m. on weekdays. You can find its current office and its walk-in drop box for applications at this office.

Marijuana products manufacturer applicants in Colorado can also use the online application portal. However, new users must sign up to enable them to use the portal. License applicants who choose the online application option do not need to download the Regulated Business License Application Form. The Marijuana Enforcement Division provides a quick guide for applicants who would prefer to apply for marijuana licenses online on their website.

Typically, the MED approves or denies a submitted marijuana license application between 45 and 90 days after receiving it. The MED advises prospective marijuana licensees to confirm that the local authority in the municipality they want to operate their facility permits marijuana businesses to avoid application denial. The MED keeps and updates a list of local authorities in Colorado that allow marijuana businesses in their jurisdiction.

How Much Does a Cannabis Manufacturing License Cost in Colorado?

The Marijuana Enforcement Division (MED) will not process any marijuana license application or renewal request unless the requisite payments are received. These costs vary depending on the intended use (medical or retail) of cannabis products and levels as outlined below:

Medical Marijuana Products Manufacturer

• Application Fee/ License Fee:
  • Level 1 - $2,440/ $610
  • Level 2 - $3,680/ $920
  • Level 3 - $4,880/ $1,220

Retail Marijuana Products Manufacturer

• Application Fee - $5,000
• License Fee:
  • Level 1 - $2,850
  • Level 2 - $5,500
  • Level 3 - $8,200

Both medical and retail marijuana products manufacturer licensees pay a $460 fee as a license renewal application fee and $1,840 for license renewal. The widely used and acceptable payment means by the MED are checks and money orders, payable to the Colorado Department of Revenue. Applicants can also pay licensing fees via credit card authorization. Generally, the MED does not accept cash as a means of payment. An alternative payment option open to marijuana license applicants is an online payment option via a Colorado Interactive Payment System. The MED provides any applicant who chooses to pay online with online payment link options via email during their application.