Reinforce Public Policy that Protects Public Health and Safety
Recent public health crises highlight renewed commitment and diligence of the licensed industry to be
open and transparent about its products and how they’re produced, to invest in research that increases
understanding about cannabis and to continue to collaborate with elected leaders, law enforcement and
regulators to drive the illicit market out of Washington.

Defend Integrity of I-502 System
WACA will support proposals that strengthen the licensed system and that leverage the significant
resources invested to comply with state regulations. We oppose any effort that undermines the legal
system or improperly benefits anyone operating in the illicit market.

Location Compliance
WACA supports clarifying regulation so that an approved license-holder’s location cannot be found
out of compliance if, after designation as compliant and approved, unforeseen development creates a
restriction that was not there at the time of approval. The steps between identifying a compliant location
for a licensed retail cannabis business and final approval to open the doors are sequential and
comprehensive. No business can anticipate fluctuating real estate realities that change the environment
in a community from one month to the next.

Expand Access to CBD Products
Non-licensed businesses like grocery stores and gift shops can sell pure CBD products – but licensed, regulated businesses within the 502 marketplace cannot. Although CBD is no longer a controlled substance the FDA has yet to issue any regulation or guidance and therefore products sold in grocery stores are not regulated or tested. WACA is advocating to update cannabis laws so that licensed professionals (clearly experienced in cannabis, CBD) will be able to sell CBD-only products that are subject to the same testing requirements as other regulated THC products. Passage of this bill will give Washingtonians access to safe, regulated CBD-only products until the federal government take further action on the broader CBD market. 

Ownership Caps
Retailers can currently only hold up to five licenses and producer/processors can only hold up to three
licenses. WACA proposes to increase the ownership cap for license-holders or remove the cap entirely.
This approach would accomplish the goal of increasing canopy limits without increasing the state’s
overall canopy and aligning market demand with appropriately located retail locations.

Washington’s Regulated System is Not Yet Ready for Direct-to-Consumer Delivery
The regulated system in Washington is known for its rigor, containing far stricter rules than many other
states. Until the WSLCB has strengthened its tracking systems, improved its enforcement and inspection
culture and until additional safeguards are in place in terms of more laboratories, the system should not
be loosened to allow cannabis delivery.

Strengthen Fair and Effective Regulatory System
Washington’s licensed industry is among the first in the country and the rules and regulations to protect
public safety and support industry growth and compliance have improved every year. WACA proposes to
streamline rules for basic actions unrelated to public safety, product security or financing - e.g. moving a
shelf, installing new cameras – which can inadvertently halt operations until WSLCB inspectors sign-off
and instead establish a timing threshold that eases compliance for the LCB and the licensee. WACA also
supports the reclassification of LCB “officers” to “inspectors” as part of broader regulatory reform that is
in alignment with every other regulated industry – from food and beverage to waste management. The
designation would help improve credibility and establish trust by operating as regulators, not crime
fighters or law enforcement, and in the same way that health inspectors do not wear guns to review
kitchen standards, LCB representatives should not be carrying firearms as a condition of their job as

Pesticide Testing (Legislative/Regulatory)
WACA supports policy that codifies consistent requirements to ensure pesticide testing is effective.

Accelerate Product Testing (Legislative)
There are not enough certified laboratories to meet demand for safe, quality-controlled and tested
cannabis products. WACA will work to accelerate the lab certification process (through the Department of
Ecology) to be in place sooner than its current deadline of 2024.

Customer-Focused Advertising
Mindful of community expectations about marketing of cannabis, WACA proposes banning billboard
advertising that is highly visible to the passing public in exchange for larger store front signs that help
cannabis customers specifically looking for a location.

Adjust Licensing Fees for Small Business Start-Ups
The barrier to entry in the regulated cannabis market is especially onerous for those who are establishing
small businesses as opposed to expansion or establishment of larger companies. The current fee
structure disproportionately burdens license-holders with smaller canopy limits. For example, Tier 1 (the
smallest) license holders pay the same fees as their much larger competitors with Tier 2 or Tier 3
licenses. WACA supports adjusting license fees so they align with canopy size, thus accounting for
smaller businesses.

Questions? Contact Vicki Christophersen [email protected] 360.485.2026 or Brooke Davies [email protected] 540.336.7465