Kocot Law represents California cannabis businesses and individuals at every stage of the regulated and unregulated marketplace. From new license applications and Department of Cannabis Control (DCC) compliance to transactional work and criminal defense, our practice is built around the actual day-to-day legal needs of California cannabis operators — not generic business law applied to cannabis as an afterthought.

Ryan Kocot is admitted to practice in California, and California is the firm’s primary jurisdiction. We handle matters before the Department of Cannabis Control, city and county licensing authorities, the California Department of Tax and Fee Administration (CDTFA), and California state and superior courts.

California’s regulatory framework is complicated. California cannabis is governed primarily by the Medicinal and Adult-Use Cannabis Regulation and Safety Act (MAUCRSA), codified at Business & Professions Code § 26000 et seq., with implementing regulations in Title 4, Division 19 of the California Code of Regulations.

Since 2021, the Department of Cannabis Control has been the consolidated state regulator, taking over from the predecessor Bureau of Cannabis Control, CDFA’s CalCannabis Cultivation Licensing, and CDPH’s Manufactured Cannabis Safety Branch. That consolidation matters in practice: compliance, enforcement, and licensing now run through a single agency with unified procedures, but with substantially expanded enforcement capacity compared to the legacy three-agency structure.

Layered on top of state regulation is local control: Cal. Bus. & Prof. Code § 26200 reserves significant authority to cities and counties, including the ability to prohibit cannabis businesses outright. Approximately 60% of California municipalities still ban some form of commercial cannabis activity. Successful licensing in California requires winning approvals at both the local and state level and the local process is frequently the longer and harder path.

• Cultivation: Specialty Cottage, Specialty, Small, Medium, and Large licenses across Outdoor, Indoor, and Mixed-Light tiers; Nursery licenses
• Manufacturing: Type 6 (non-volatile), Type 7 (volatile), Type N (infusion), Type P (packaging)
• Distribution: Type 11 distribution and transport-only variants
• Retail: Type 10 storefront and Type 9 non-storefront delivery
• Microbusiness: Type 12 (combination cultivation, manufacturing, distribution, and retail)
• Testing Laboratory: Type 8
• Cannabis Event Organizer: Type 13 and temporary cannabis event licenses

DEA Registration FOR CALIFORNIA MEDICAL CANNABIS BUSINESSES

California-licensed medical marijuana operators now have a federal pathway. The April 2026 rescheduling of FDA-approved marijuana products to Schedule III, combined with state-licensed marijuana under medical-license-covered operations, opened federal DEA registration under 21 C.F.R. § 1301.13(k). For DCC-licensed medical operators, this means parallel federal registration is now available, and during the 60-day priority window, applications receive expedited review with conditional operating authority.

This matters for California operators whether or not you plan to immediately operate federally. Federal registration positions your business for the eventual federal market, allows interstate movement under the federal framework, opens access to federal banking and tax treatment available to Schedule III operators, and creates a federal compliance record that protects against future enforcement gaps.

Kocot Law handles DEA registration applications for all California operator types:

• Cultivators seeking federal registration alongside their DCC cultivation license, including § 1301.13(k)(6) Single Convention nominal-price compliance for marijuana cultivation
• Manufacturers and processors producing concentrates, infused products, and finished medical marijuana products under DCC manufacturing licenses
• Distributors moving product between licensed entities within the federal-state framework
• Retailers and dispensaries dispensing to qualified medical patients under DCC retail licenses
• Testing laboratories registered as analytical labs under controlled-substance authority
• Multi-state operators coordinating California DCC licensing with federal registration across multiple state license programs

The DEA application is technical and operational. It requires § 823(e)-(g) public-interest analysis, security plans meeting Part 1301 requirements, storage compliance under Part 1301, and operational details that frequently get applications stuck in review. Kocot Law handles the federal side from intake to issuance, working in parallel with your DCC licensing work so your California state license and federal DEA registration are aligned.

• New DCC annual license applications and renewals
• Local conditional use permits, commercial cannabis permits, and zoning entitlements
• Premises modifications and license amendments
• Ownership and financial-interest disclosures under Cal. Code Regs. tit. 4, § 15003 and § 15004
• Provisional license transitions and remaining wind-down matters
• License denials, suspensions, and revocation defense before DCC’s Office of Administrative Hearings

• METRC track-and-trace audits and corrective action
• Manifest discrepancy investigations and Notice of Non-Compliance responses
• Standard operating procedure development across cultivation, manufacturing, distribution, and retail
• Packaging, labeling, and Proposition 65 compliance
• Trade sample programs following SB 1186
• Cannabis equity program eligibility, applications, and grant administration
• DCC inspection preparation and response

• Entity formation and OpCo / IPCo / PropCo / EmployeeCo structuring
• Cultivation, manufacturing, distribution, and white-label agreements
• Membership interest purchase agreements (MIPAs) and asset purchase agreements (APAs)
• DCC ownership change notifications and pre-approvals
• Intellectual property licensing, intellectual property protection, and management services agreements
• Investor documentation, joint ventures, and capital raises 280E mitigation structuring

California still prosecutes unlicensed and out-of-license cultivation, sales, and distribution under Health & Safety Code §§ 11357–11362.85. We defend individuals charged with:

• Cultivation outside license parameters (canopy, plant count, premises boundaries)
• Diversion to and from the unlicensed market
• Tax evasion under Revenue and Taxation Code § 34010 et seq. and unlicensed commercial activity
• Search-and-seizure issues at licensed premises, including overbroad warrants and joint state/federal task force actions
• Cases where a regulatory compliance issue has been referred for criminal prosecution

This dual practice (regulatory and criminal) matters because the line between a Notice of Non-Compliance and a criminal referral is thinner than most operators realize.

• Cultivators of every tier, from Specialty Cottage operators to Large Mixed-Light farms
• Manufacturers running volatile and non-volatile extraction, infusion, and packaging operations
• Distributors managing multi-county supply chains and METRC-heavy operations
• Retailers including storefront dispensaries, non-storefront delivery, and microbusiness
• Testing laboratories and ancillary service providers I
• Investors and capital sources evaluating California cannabis acquisitions
• Multi-state operators establishing or restructuring California operations
• Founders and individuals facing license denials or criminal exposure