New Jersey residents have until Sept. 30 to provide input on proposed updates to the rules for the state's legal marijuana marketplace from the Cannabis Regulatory Commission.

Todd Polyniak, a partner at Parsippany-based Sax who heads the cannabis practice there, has been analyzing the 325-page document and said the new, impending regulations run the gamut of what he would call a true cannabis industry in the Garden State.

"You can go from growing it to manufacturing it to wholesaling it to distributing it, and then finally selling it in retail or delivering it to a final customer," Polyniak said.

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The delivery aspect is one that advocates have been waiting for, and comes alongside new provisions on wholesalers which are both part of reformulated classes of licenses.

Polyniak said there is also an understanding that "good faith" efforts will be made by those who receive licenses to employ and engage professionals who fall into their social equity class, as the CRC continues to consider social equity a priority in reviewing applications.

"They're trying to say you need to do more than just say you did this, you need to demonstrate what process you went through to make sure that we're giving people the benefit of being used by you," Polyniak said.

But he said the same dilemma still exists from before these new rules were presented: Those who garner licenses may not be able to do anything with them if they don't have the cash to move their plans forward.

And for each conditional license, the clock is ticking.

"I think the state still needs to come through with some type of way of funding these startups, especially the social equity startups," Polyniak said. "They have 120 days plus 45 days to actually execute on that conditional license and convert it into an annual license. So that's not a whole lot of time to get everything done."

Polyniak did highlight one other condition of the new rules, a per-ounce excise fee that will be collected from cultivators with the intention of funding future social equity clauses.

The CRC said the proposal also covers safe-use information, waste management, and advertising and promotion.

Those who wish to register comment can do so through the CRC's website.

Patrick Lavery is a reporter and anchor for New Jersey 101.5. You can reach him at

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