Advisory committee urges DCC to drop 3-product cap on multibatch cannabis packages

The California Cannabis Advisory Committee on Aug. 28 recommended that the Department of Cannabis Control (DCC) remove a proposed three-product limit on so-called multibatch cannabis packages and consider allowing multiple product types to be sold together under a single SKU.

Deputy Director Jacqueline Campion told the committee the department’s proposal would permit multibatch goods such as dual-chamber vapes or multistrain pre-roll packs and that each discrete batch in a package would need its own certificate of analysis (COA). “Each batch within the multibatch product must be tested in accordance with regulatory requirements and receive its own certificate of analysis,” Campion said during the presentation.

The recommendation follows extensive committee and public comment about balancing consumer choice and public-safety concerns. Member Brandon Levine, who represents industry perspectives on the committee, described the change as a practical accommodation for consumers and consumption lounges: “If you were to do this, I would recommend that we don't put a cap of 3 items… a patron can come in and buy this 1 gram in total, but get to taste 5 different products,” he said. Several small‑farm and craft‑industry commenters echoed that view, saying multibatch packages would lower costs, enable collaborations, and help bring consumers back to the regulated market.

Opponents and cautious voices urged precautions. Member Halperin Felsher, speaking from a youth‑protection perspective, said sampling and novelty flavors can increase appeal to adolescents and asked the DCC to ensure strong access controls and enforcement. Public commenter Becky Rapp raised safety and impairment concerns, saying sampling multiple products with different onset and potency could make it hard for consumers to track intake and could pose public‑safety risks when people leave lounges.

Committee members and industry speakers pressed DCC for technical clarifications on product definitions, lab sampling and packaging. Campion said the three‑product limit was a starting point based on feedback from Metrc (the state’s track‑and‑trace system) and the DCC’s testing experts and that “this is absolutely on the table for discussion.” She also offered a phased approach idea, with a pilot period to test whether expanding the limit creates operational or tracking problems.

After public comment the committee voted to revise the committee recommendation: remove the three‑product cap, permit multiple product types in multibatch packaging, and ask the DCC to return to the CAC with final regulatory language for further review. Member Levine moved the revised motion and Member Beck seconded. The motion passed with a majority recorded in favor and one recorded dissent based on youth‑access concerns.

What happens next: the DCC will consider the CAC’s recommendation as it develops formal rulemaking. Campion reiterated that any final regulation would go through the Administrative Procedure Act’s public rulemaking process, and that the department will consult its Metrc experts and the CAC on operational details such as labeling, QR‑code linking for COAs, and sampling/homogenization guidance for laboratories.

Votes and formal action: The committee recorded a motion to remove the 3‑product cap, remove the product‑type limitation, and request DCC return with final language for further review. Motion: remove the cap of 3 and allow multiple product types; Mover: Member Levine; Second: Member Beck. Outcome: passed (majority aye, one nay).