Does Washington DC Require Medical Cannabis Couriers to Obtain Courier Licenses?
Yes. According to the Medical Cannabis Amendment Act of 2022 (MCA), third-party businesses delivering medical cannabis and medical cannabis products on behalf of licensed retailer businesses must obtain a medical cannabis courier license from the ABCA to operate legally in the District.
A medical cannabis courier license permits the licensee to operate a marijuana business in DC for the purpose of delivering medical marijuana, medical marijuana concentrates, medical marijuana-infused products, or medical marijuana paraphernalia on behalf of licensed medical marijuana internet retailers or medical marijuana retailers to qualifying patients and caregivers.
Courier licensees must contract directly with a retailer or internet retailer license holder to deliver medical cannabis or medical cannabis products. However, courier licensees are permitted to use the internet, their own mobile application, telephone, or a similar technology platform to facilitate the sale of medical cannabis or medical cannabis products.
Note that a medical cannabis courier license is not permitted to offer curbside pick-up at a retailer, internet retailer, or its ABC Board-approved location to qualifying patients and caregivers.
What Are the Different Types of Courier Licenses in Washington DC?
Only one type of medical cannabis courier license is issued by the ABCA in Washington DC. The license is open to third parties delivering medical cannabis for licensed retailers and internet retailers to medical cannabis patients and caregivers. Courier licensees are permitted to use their employees or independent contractors to deliver medical cannabis or medical cannabis products.
How to Get a Medical Cannabis Courier License in Washington DC
The ABCA only considers applications from eligible persons applying for medical cannabis courier licenses. Therefore, you must fulfill the general eligibility conditions for your application to be accepted by the ABCA. These requirements include the following:
- The applicant's character is of high moral standing and aligns well with the obligations of licensure
- The applicant has attained a minimum age of 21 years
- The applicant has not been convicted of a felony, such as a violent crime, gun-related offense, tax evasion, fraud, or credit card fraud, in the 3 years preceding the application submission date
- The applicant has duly remitted the stipulated annual fee and falls under either the for-profit or non-profit corporate classification incorporated in the District
- The applicant is not a licensed authorized practitioner engaged in patient recommendations
- The applicant is not an individual whose authorization as a caregiver or qualifying patient has been rescinded by the Board
- The applicant has adhered to all stipulations set forth in the Legalization of Marijuana for Medical Treatment Initiative of 1999 (Act), as well as Title 22-C of the DC Municipal Regulations
- The applicant remains current with all tax filings and holds a "Clean Hands" status, denoting the absence of any outstanding debt to the District beyond $100
Note that DC Board Orders and Settlement Agreement terms apply and may affect eligibility for a medical cannabis manufacturer license.
Also, in compliance with the ABCA application criteria, an applicant is required to:
- Provide an authentic zoning determination letter issued by the Department of Buildings Zoning Administrator. This letter should corroborate the operational feasibility of a Courier service at the intended premises, further confirming that the designated physical address holds a zoning status other than residential. Before the Courier license is granted, the applicant must supply a certificate of occupancy issued by DOB. This certificate should pertain to the specific building where the licensed premises are proposed to be situated
- Provide a legally binding written lease, a documented intent to lease, or an agreement to purchase, which demonstrates the applicant's commitment to acquiring and utilizing all or a specific section of the building for the purpose of conducting a Courier business
- Provide a signed and notarized Medical Cannabis Facility Applicant Acknowledgment and Attestation Form
- Provide a completed Medical Cannabis Business License Application
- If a social equity applicant, provide valid documentation attesting to the social equity applicant status. A social equity applicant is defined by meeting two or more criteria as outlined in D.C. Official Code § 7-1671.01(20C) and satisfying the stipulations of D.C. Official Code § 7-1671.06(g)(1). To fulfill these requirements, the applicant must provide both the notarized Medical Cannabis Facility Applicant Social Equity Declaration Form and the Social Equity Applicant Attestation Statement
- If applicable, the applicant must submit substantiating documentation confirming the applicant's registration as a medical cannabis Certified Business Enterprise (CBE) approved by the District of Columbia's Department of Small and Local Business Development (DSLBD). In order to qualify as a medical cannabis CBE, the applicant must satisfactorily fulfill all criteria outlined in D.C. Official Code § 7-1671.01(12A) and § 7-1671.06(g)(2). This submission necessitates the provision of the following:
- Submit all of the other required documents listed on the Medical Cannabis Business License Application Checklist
- Submit a security plan with the application addressing, at a minimum, the following elements:
- Evidence that the business operation space complies with all security requirements set forth in Title 22-C of the regulations
- A site plan showing the whole structure the Courier’s business is housed in, including the streets, parking lots, other tenants within the facility, and any other entities that physically border the proposed location
- A floor plan of the business detailing the location of the following:
- All entrances and exits
- The location of windows, skylights, and roof hatches
- The location of cameras and their field of view.
- The location of alarm inputs and alarm sirens
- The location of the DVR and alarm control panel
- Restricted and public areas
- The form of security training provided for, and completed by, establishment personnel, including:
- Procedures for handling violent incidents, other emergencies, and calling MPD
- The number and location of cameras used by the establishment
- Security measures taken by the applicant to prevent individuals from entering the limited access area portion of the licensed premises
- The applicant’s closing procedures after the cessation of business each day
- The applicant’s plan to store medical cannabis overnight, if necessary
- The applicant’s plan to prevent theft or the diversion of medical cannabis, including maintaining all medical cannabis in a secure, locked room that is accessible only to authorized persons
- The type of security or alarm system and outdoor lighting to be used by the applicant
Applications should be presented in a legibly typed format, preferably employing a 12-point font size. The application should be submitted either in hard copy or electronically. All required documents must be compiled into a single PDF document for electronic submissions. If opting for electronic submission, kindly forward your application to ABCA.email@example.com. Alternatively, applications can be submitted via mail or in-person delivery to the following address:
2000 14th Street NW
Suite 400 South
Washington, DC 20009
Note that in compliance with regulations set forth by ABCA, failure to provide all mandatory documents and plans will render the application non-responsive and, consequently, rejected by ABCA. Applicant submissions for medical cannabis courier licenses, once accepted by ABCA, are subject to a 45-calendar day public comment period, as mandated by the regulations. Applications for medical cannabis courier licenses are only accepted during open application periods.
For further information on applying for a medical cannabis courier license in Washington DC, review the application instructions guide.
How Much Does a Medical Cannabis Courier License Cost in Washington DC?
In accordance with the ABCA Fee and Renewal Schedule, the annual fee for a standard courier license is $8,000. The annual fee for a social equity courier license is $2,000 for the first three years. Courier applicants are also required to pay their annual fee for the first year within 60 calendar days of ABC Board approval but prior to license issuance.
Also, an applicant for a medical cannabis license must pay a non-refundable fee as part of their application submission. The application fee for standard courier applications is $4,000. The application fee for a social equity courier applicant is $1,000.
Acceptable payment options include checks, money orders, cashier's checks, and credit cards. Among these, credit card payment is exclusively accessible to applicants who opt for in-person submissions. Such applicants must present their credit cards to an ABCA representative during the submission process. Alternatively, the ABCA accommodates electronic payment completion via a requested payment link. A payment link can be obtained by contacting ABCA to facilitate the electronic payment at ABCA.CannabisLicensing@dc.gov. The use of starter checks, cash, and phone-based payments are not allowed. Applicants are advised to make payment via money, order, or cashier's checks payable to the "DC Treasurer."
It is incumbent upon the applicant to bear the entirety of costs incurred during the preparation and submission phases of the application. The ABCA does not assume any responsibility for costs accrued by applicants during these preparatory or submission activities.
Can Medical Cannabis Courier Licensees Hold Other Cannabis Licenses in Washington DC?
No licensee holding any other type of cannabis license in Washington DC (retailer, internet retailer, cultivation center, manufacturer, or testing laboratory license) is also permitted to hold a courier license.