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California cannabis enforcement

Key California cannabis enforcement tools, response deadlines, and related resources, in one place. Start with the document you received.

Just received something? ↓ By document ↓ Every enforcement article ↓

Attorney advertising. General information, not legal advice; reading it does not create an attorney-client relationship. The deadline in your matter is set by your document and the governing statute or regulation.

The first 24 hours

  1. Find the clock. Note the date and the way the document reached you (in person, email, mail, or a phone call to a manager). Most deadlines run from service or receipt, not from when you read it.
  2. Identify the tool. Match the document to a card below. Each one starts a different clock.
  3. Preserve everything. Keep the document, the envelope or email, inventory and track-and-trace records, and video. Follow the hold’s restrictions: segregate goods as required, and do not move, remediate, or destroy them without required authorization.
  4. Route communication through one person. Staff should be courteous and should not guess or volunteer answers to investigators.
  5. Call counsel before you respond. The response you send in the first days shapes the record the rest of the case is decided on.
Call or text (916) 572-6445
By the document you received

Seven key enforcement tools and the clocks they start

These are the default deadlines in the regulation or statute. Some notices may set a different date; others cannot. Calendar the earliest plausible deadline and confirm any extension in writing. Other tools, such as an interim suspension order, are not covered here; if you received something not listed, call.

DCC

Embargo notice

DCC may embargo cannabis or cannabis products when it has probable cause to believe they are adulterated or misbranded, or that their sale would otherwise violate the cannabis statute or regulations. The embargo restrictions apply immediately; the seven-day no-response threshold runs from the supplemental written notice.

  • Respond promptly after DCC provides the supplemental written notice. DCC may initiate condemnation proceedings if it cannot approve your proposed plan or receives no response within seven calendar days. This is not a guaranteed seven-day period before DCC can act.

Authority: 4 CCR § 17801.5 (a), (c), (d)(2), (f), (g)

You received a DCC embargo notice →
DCC

Emergency decision and order, including an administrative hold

One of DCC’s fastest tools: unless it says otherwise, the decision and order is effective when issued, before any hearing.

  • Immediately comply with the emergency order. While an administrative hold is in effect, do not sell, donate, transfer, transport, gift, or destroy the designated goods.
  • 24 hours after receipt of notice of an administrative hold: physically segregate the designated goods in a limited-access area and safeguard them against tampering, degradation, or contamination.
  • 3 business days after receipt of notice of the emergency decision: submit a written request for a hearing. Notice may be oral and may be given to a manager or other personnel at the licensed premises.

Authority: 4 CCR § 17815 (c), (e), (h)

A DCC emergency decision and order can shut you down the day it is issued →
DCC

Notice to Comply

DCC may issue a Notice to Comply for violations discovered during an inspection, investigation, or audit.

  • 30 calendar days by default, from personal service or the date the notice was emailed or mailed (not necessarily the day you read it): sign and return the notice describing how compliance was achieved. DCC may set a different date or require a corrective plan.

Authority: 4 CCR § 17801 (a), (c), (d)

How the firm handles Notices to Comply →
DCC

Citation, order of abatement, or fine

A formal citation can carry a fine and an order to correct by a set date. Two separate windows run from service.

  • 15 calendar days after service: request an informal conference in writing if you want one. It does not replace the hearing request or extend its deadline.
  • 30 calendar days after service: file a written request for a hearing to contest the citation. The fine is due within 30 days unless contested.
  • If modified after the informal conference, the original citation is treated as withdrawn and a new one issued; a hearing on the new citation must be requested within 30 calendar days after it issues.

Authority: 4 CCR § 17802, 4 CCR § 17803, 4 CCR § 17804; Bus. & Prof. Code § 26031.5

How the firm handles citations and fines →
DCC

Recall, voluntary or ordered

Every licensee in the chain has duties when a batch is adulterated or misbranded, not just the brand owner.

  • 24 hours after initiating a recall: notify DCC.
  • 72 hours, minimum quarantine of recalled goods bound for destruction, with the required documents affixed, before they are destroyed. DCC may require a longer quarantine.
  • Within 5 days of a mandatory recall order, DCC must provide an opportunity for an informal proceeding. That is the agency’s obligation, not a five-day filing deadline for the licensee. Goods subject to the order cannot be moved without DCC’s prior written authorization.

Authority: 4 CCR § 17225, 4 CCR § 17226, 4 CCR § 17227; Bus. & Prof. Code § 26039.1 (c), (f)

California cannabis recalls: what licensees must do and when →
DCC

Accusation seeking license discipline

The formal case to suspend or revoke a license, heard under the Administrative Procedure Act. The first two clocks run at the same time.

  • 15 days after service: file a notice of defense. Failure to file waives the right to a hearing, although DCC retains discretion to permit a late filing or grant a hearing.
  • 30 days after service of the initial pleading, and before the hearing: make the written statutory discovery request to the other party. A 15-day window applies after service of an additional pleading.
  • 7 days after service of a default decision: serve a written motion asking that the decision be vacated and stating the grounds. Relief requires good cause and is discretionary.
  • 30 days after the last day on which reconsideration of a final DCC decision could be requested under Gov. Code § 11521: the Cannabis Control Appeals Panel must receive the notice of appeal.
  • Stay on appeal an appeal involving denial of a license renewal, cancellation, suspension, or revocation stays the decision until the Panel issues its final order. The Panel may vacate the stay on DCC’s motion showing an immediate danger to public health, safety, or welfare.

Authority: Gov. Code §§ 11505-11506, § 11507.6, § 11520, § 11521; 16 CCR §§ 6003-6005, 6014

DCC accusations: deadlines, defense, and your license →DCC is seeking to revoke your license. Can you keep your business open? →What to do when your California cannabis license is at risk →The multistate operator’s California enforcement problem →
DA or Attorney General, not DCC

State asset forfeiture

After a police seizure of cash, product, or vehicles, a district attorney or the Attorney General can move to forfeit them. A cannabis license does not automatically prevent forfeiture. Preserve your claim promptly so you can assert the applicable defenses.

  • 30 days after receipt of actual notice: file a verified claim in the appropriate superior court. If you were not personally served or served by mail, the period runs from publication of the notice; count from the first publication to be safe. Each claimant files separately.
  • 30 days after filing: serve a file-endorsed copy of the claim on the district attorney or Attorney General. Seek counsel immediately if any deadline may have passed.

Authority: Health & Saf. Code § 11488.4 (j), § 11488.5 (a)(1); Judicial Council form MC-200

Licensed but not immune: asset forfeiture →The $1.3 billion crackdown and California asset forfeiture →Transport SOPs: a defense against seizure and forfeiture →
Context

Where enforcement is headed

The state has said where it is putting enforcement money and attention, and the mistakes that cost licenses tend to repeat. Read these before anything arrives.

California just told you its enforcement strategy →California’s $227 million enforcement push →The #1 mistake operators make in a DCC enforcement action →When investigators talk to your team →Cannabis criminal charges: why the case may be bigger than the complaint →
From the blog

Every California enforcement article

Newest first, added here the day each one publishes. See the full archive.

Received something from DCC or a prosecutor?

A free 30-minute consultation can help identify the document, assess the apparent deadline, and discuss next steps. The firm handles enforcement defense in flat-fee phases; see how it works.

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Attorney advertising. This page is general information about California cannabis enforcement and is not legal advice. Reading it, calling, or submitting a form does not create an attorney-client relationship; none is formed unless and until Kocot Law completes a conflict check and both parties sign an engagement letter. Deadlines shown are the defaults in the cited statute or regulation; the deadline in your matter is controlled by your notice, how it was served, and the applicable law, and rules change. Prior results do not guarantee a similar outcome.

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