Keep Calm and Comply On
12 Rules for Navigating the CRA’s Changes for Cannabis Businesses
The Cannabis Regulatory Agency (CRA) just dropped a major set of draft rule changes that every Michigan cannabis business needs to be aware of. While these rules aren’t official just yet, the writing’s on the wall, and savvy dispensary owners, growers, processors, and infused product makers should start prepping now.
Why? Because when the final rules hit, it’ll pay off to already be in compliance. Less stress. Fewer surprises. And no scrambling to fix things under pressure.
1. Prequalification Can Now Be Revoked
Under the previous rules, it used to be that once you were prequalified, you were good. Now? Not so much.
The CRA can now reassess and revoke prequalification if they decide you no longer meet the requirements. So, make sure your financials, background checks, and documentation stay clean and current. If you're applying under the medical framework, you’ll need to show updated bank records, submit fingerprints, and provide proof of funds — no exceptions.
2. License Changes = Paperwork First
Planning to update your ownership, business structure, brand names, or even just a DBA? You must submit a written request to the CRA before making any changes. Wait for their written approval first. Don’t just assume it’s all good.
Same goes for license renewals: you'll now need to list your full organizational structure and all associated brands upon renewal.
3. Notify the CRA About Almost Everything
Lease changes? New TMs? Legal battles? You guessed it...you need to report it.
If you’ve got a new contact email or you’re restructuring your business, let the CRA know. It's all about transparency and missing a notification can be a big problem later on.
4. Double-Entry Accounting is Now a Must
The CRA is tightening the screws on financial recordkeeping. Double-entry accounting systems are required across the board. If you’re a Designated Consumption Lounge or Marijuana Event Organizer, you must also keep hemp and marihuana revenues separated and reconciled monthly.
Basically, document everything. From SOP logs to sanitation checks to packaging runs, if it’s not written down (or logged digitally), it didn’t happen.
5. METRC: Real-Time or Bust
You now have 24 hours to enter product info into METRC after receipt. Cultivators? You need to report the exact grow room or area. Processors? You’ll need to track ingredients, methods, and waste.
And here's a key one: correct any errors within 7 days, or you could be looking at penalties.
6. Edible Makers: Get Certified
If you’re making edible products, you must now employ at least one certified food safety manager with credentials from an approved group like ServSafe, NRFSP, or Prometric.
On top of that, you’ll need to:
Keep Certificates of Analysis (COAs) for every non-cannabis ingredient.
Document every recipe and formulation.
Prove your process meets food safety standards.
7. Packaging & Labels Got an Update
Labels no longer need to list the strain, but they do need to include:
Serving size and dose.
Required info for each item in a multi-pack.
Packaging must be opaque, resealable, child-resistant, food-grade, and MDARD-compliant.
Optional: QR codes for traceability (a great idea if you’re scaling).
8. Infused Products? Keep It Clean
Infused products can’t:
Resemble candy or snacks kids love.
Be shaped like animals, people, or cartoons.
Mislead customers about contents or effects.
Also, servings must be clearly distinguishable. If it’s a chocolate bar with 10 doses, each square must be easily distinguished. It is the responsibility of both the producer and the seller to ensure edible and infused products comply with these standards.
9. Converted Cannabinoids? Hard No.
The CRA has officially banned the synthesis of THC from CBD and other cannabinoid conversions. If you’re making or selling converted products, stop now. This rule goes into effect immediately!
10. Cultivators: Time to Tag Up
All plants must be tagged once they hit eight (8) inches, and harvests need to be traceable back to each plant tag. Strain names? Optional for now.
Outdoor growers, record what’s grown in each row.
Also: All grows must employ a certified pesticide applicator under the update rules. Make sure that credential/certificate is up-to-date, on file, and stored on-site.
11. Employees with Records? Tread Carefully
The CRA has outlined how they evaluate job candidates with a criminal record. It's not an automatic “no,” but things like severity, time passed, and risk to public safety will be considered.
If someone has a history of distribution to minors or serious offenses, that is a likely dealbreaker.
12. Enforcement Just Got Sharper
The CRA now has broader powers, even after your license expires. They can issue immediate suspensions for:
Selling untested or unsafe products
Falsifying METRC data
Using banned ingredients or unapproved cannabinoids
Unauthorized changes to ownership or structure
Obstructing investigations
Employee fraud or serious misconduct
Start Now!
→ Audit your licenses – Is everything current, and correct?
→ Get your insurance in order – CRA now requires licensees to be listed as the insured and carry at least $100k in liability, with the CRA as a certificate holder.
→ Clean up METRC – Make sure your entries are accurate and timely and give every employee a unique login if you use integrated software.
→ Train your team – Especially on SOPs, METRC, and food safety (if you handle edibles).
→ Talk to your attorney – Keep them in the loop on business structure, DBAs, trademarks, and legal notices.
If you’re feeling overwhelmed, you’re not alone. These rule changes are dense, but that’s where we come in.
Need help getting compliant or auditing your operations? We’ve got your back. From METRC training to SOP documentation and license modifications, we help cannabis businesses stay protected, productive, and profitable. If you or someone you know is in need of marijuana expertise, the experienced cannabis legal team of Scott Roberts Law is an excellent resource for any cannabis business issues, schedule your consultation today to see if we can assist you with your medical marijuana business concerns.
