Dear Friends,
We are writing to make you aware of a developing situation affecting a significant portion of New Jersey’s cannabis market and to encourage you to contact us if you believe your operations may be impacted.
As of yesterday, the New Jersey Cannabis Regulatory Commission (“CRC”) implemented a statewide “Administrative Hold” in METRC affecting packages that, at any point, interacted with a specific licensee -- Mollitiam -- currently under CRC review. While the CRC has not yet issued a formal public statement detailing the scope or duration of this action, the hold appears to be compliance-related and not tied to any public health or safety concern.
Based on information currently circulating within the industry, the issue appears to stem from alleged cultivation activity associated with Mollitiam that reportedly occurred at a non-sanctioned satellite site. The CRC has treated this activity as an unauthorized grow. As a result, METRC packages with downstream exposure to this material have been placed on Administrative Hold pending further regulatory determination. We understand that a substantial number of operators, including manufacturers and dispensaries, across the state may be affected, and the scope continues to evolve.
What this means operationally:
- Any product placed on an Administrative Hold should be removed from sale immediately.
- Held product should be clearly labeled and segregated in a designated quarantine area.
- No transfers, processing, or sales of held inventory should occur unless and until the CRC provides written authorization.
- At this time, the timeline for resolution remains unclear, and additional guidance from the CRC is expected.
We are actively monitoring the situation, speaking directly with stakeholders, and tracking CRC communications as they develop. Internally, the CRC appears divided on next steps, and the matter may escalate depending on how it is resolved administratively in the immediate term.
If you:
- Have received Metrc notifications regarding an Administrative Hold;
- Are uncertain whether your inventory or prior transfers are implicated; or
- Need assistance with compliance steps, documentation, or risk assessment
We strongly recommend that you reach out to us as soon as possible. Early review and documentation may be critical depending on how the CRC ultimately proceeds.
In the meantime, we recommend proceeding conservatively and maintaining strict compliance protocols.