The Microbusiness Cannabis Facility Types

Hello and welcome back to Stock Legal’s blog series on Cannabis Microbusiness Licenses in Missouri! In our last post, we walked through the basics of what a microbusiness license is, how many will be awarded, and when the application process for these licenses will begin. In this post, we will focus on the different types of microbusiness cannabis licenses available, and how they differ from the previously awarded commercial cannabis licenses.

On June 6, 2023, all application forms and instructions will be made available on the DCR website. As a slight correction to the first blog post, the Department of Health and Senior Services (“DHSS”) will open application windows each year, with the windows for 2024 and 2025 to be determined later. So, you will have three different application windows to be awarded a microbusiness cannabis license. There will be two different types of microbusiness cannabis licenses that you will have the opportunity to apply for, but importantly, you must keep in mind that you will only be able to own one license. So, you will need to decide prior to submitting your application which cannabis microbusiness you would like to operate. Also, please remember that you will need to be honest and forthright with the information requested on the application. If not, the DCR may determine you are ineligible for a license, even if you had been previously approved.

A microbusiness cannabis license differs from the commercial licenses already in operation throughout Missouri. A commercial medical or comprehensive dispensary is allowed to purchase products from any of the licensed cultivation, manufacturing, and other commercial dispensaries, compared to the microbusiness dispensary facility which may only purchase cannabis from other microbusiness facilities. A microbusiness wholesale facility, on the other hand, encompasses more than a commercial license. Under the current structure, a cultivator cannot manufacture any cannabis products. Likewise, a commercial manufacturer cannot grow its own marijuana for processing. A microbusiness wholesale facility is permitted to participate in both processes, all under the same license, but may only sell the cannabis it has grown and produced to other microbusiness facilities.

Micro Dispensary

A microbusiness dispensary facility (“Micro Dispensary”) is a dispensary that has been licensed by DHSS to engage in the process of dispensing marijuana for medical or adult use. A Micro Dispensary is allowed to engage in all the activities that a commercial dispensary license may do under the rules and regulations of the DHSS but is only allowed to acquire product from and sell product that was produced by microbusiness wholesale facility. These activities include:

1. Acquire and transfer marijuana, marijuana seeds, clones, and prerolls from a microbusiness wholesale facility.
2. Acquire and transfer marijuana-infused products and prerolls from a microbusiness wholesale facility.
3. Create and sell prerolls, which does not include the grinding of marijuana for use in prerolls or manufacture of marijuana-infused products.
4. Package and store (on- or off-site) marijuana product and drug paraphernalia used to administer marijuana products.
5. Transport and sell or distribute marijuana product and drug paraphernalia to another microbusiness facility, or individuals authorized to purchase marijuana product for personal or medical use.
   1. A comprehensive (commercial) license or microbusiness dispensary licensee may sell or distribute to individuals who are consumers, qualifying patients, or primary caregivers.
6. Transfer marijuana product to or from its own warehouse.

Micro Wholesale

A microbusiness wholesale facility (“Micro Wholesale”) enables owners to combine the concepts of a cultivation and manufacturing facility and is awarded by DHSS for the purposes of serving medical and adult use sectors of the industry. A Micro Wholesale license will enable you to engage in all or a portion of the following: growing, processing, or infusing practices. More precisely, a Micro Wholesale facility will be able to do all the following:

1. Cultivate, manufacture, package, and transport marijuana.
   1. Manufacturing includes the ability to produce infused products, edibles, concentrates, topicals, etc.
   2. For cultivation, a Micro Wholesale is allowed to cultivate up to 250 flowering plants. DHSS defines a “flowering plant” as a marijuana plant from the time it first exhibits signs of sexual maturity through harvest.
2. Transport to Micro Dispensaries, other Micro Wholesale facilities, and testing facilities products grown and manufactured by the Micro Wholesale facility.
3. Sell marijuana and marijuana infused products to Micro Dispensaries and other Micro Wholesale facilities.
4. Produce and sell pre-rolls and infused pre-rolls.
   
   

There is a lot to consider when it comes to choosing which microbusiness cannabis facility you would like to own, and unfortunately, I can’t make that decision for you.

• Are you someone who has a lot of retail experience and dealing with customers off the street? Then a Micro Dispensary may be the right choice for you.
• Do you have a “green thumb,” and is passionate about botany? A Micro Wholesale license may be the right choice for you.
• Or maybe you’re a chemist, or someone who likes to create something new? A Micro Wholesale license where you can extract, infuse, and alter the chemical structure of cannabis might be what excites you most.

Ultimately, the decision is one you must make, but please make sure to give it careful consideration. The purpose of this microbusiness program is to provide opportunities for those who are passionate and eager to get into the cannabis industry, but who have been unable to in the past, for various reasons. If the idea of owning a microbusiness cannabis license seems like “fun,” or is “something I could try just to see,” then please consider waiting to apply. These licenses are designed for those who wish to create a successful business and are willing to do the hard work to get it where it needs to be.

In the next blog post, we will dive into the application process itself, providing a timeline for you to follow, and some useful tips on different goals you should be checking off as you make your way through the timeline.