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Yes. Neither the Alcoholic Beverage Control (“ABC”) Act nor the Medicinal and Adult-Use Cannabis Regulation and Safety Act (“MAUCRSA”) prohibit persons from holding licenses to manufacture or sell alcoholic beverages from holding a license authorized under the MAUCRSA. Applicants for ABC licenses will still need to meet all ABC licensing requirements, independently of any other licensing authority under the MAUCRSA.
No. There are three specific reasons why this is not permitted. First, since cannabis cannot be sold in the same premises as alcoholic beverages, any product that contains both cannabis and beverage alcohol cannot be sold at premises licensed with either an ABC license or a MAUCRSA license. (See FAQ # 2.) Second, regulations issued by the California Department of Public Health prohibit the sale of “edible cannabis products” as alcoholic beverages. (Title 17, California Code of Regulations, Section 40300.) Third, Business and Professions Code Section 25621.5 (AB-2914) expressly prohibits the sale, offering for sale, or providing cannabis or cannabis products at ABC -licensed premises, including an alcoholic beverage that contains cannabis or cannabis products.
1. Can I hold both an ABC license and a license to grow, process, or sell cannabis?
25621.5. (a) A licensee shall not, at its licensed premises, sell, offer, or provide cannabis or cannabis products, as defined in Section 26001, including an alcoholic beverage that contains cannabis or a cannabis product, and no alcoholic beverage shall be manufactured, sold, or offered for sale if it contains tetrahydrocannabinol or cannabinoids, regardless of source.
No. On September 27, 2018, Governor Brown signed Assembly Bill 2914 (enacting Business and Professions Code Section 25621.5), which makes it clear that alcoholic beverage licensees are prohibited from manufacturing, selling, or offering for sale any alcoholic beverages that contain tetrahydrocannabinol (THC) or cannabinoids (CBD), regardless of source. This means that neither cannabis nor industrial hemp (that contains THC or CBD) may be used in the manufacture of alcoholic beverages or in mixed drinks prepared at ABC-licensed premises.
No. Health and Safety Code Section 11362.3 prohibits the smoking or ingesting of cannabis or cannabis products in a public place, except as authorized under Business and Professions Code Section 26200. Businesses (including premises authorizing the sale or consumption of alcoholic beverages under both retail and non-retail licenses) licensed under the ABC Act are considered “public places” for this purpose (this also includes premises licensed under club licenses, or any other premises to which entry may otherwise be limited). This restriction applies even if the ABC licensee is not exercising the privileges of the license, such as after hours, while closed, or if the ABC license is surrendered or suspended.