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Three California cannabis bills we tracked became law. Here’s what operators need to do before 2027

California’s 2026 legislative session is over, and three of the five cannabis bills we tracked earlier this year became law: AB 1965, AB 2249, and AB 2532.

Together, these laws change the rules for cannabis testing, certificates of analysis, packaging, advertising, edible labels, and multi-serving beverages. Some provisions take effect on January 1, 2027. Others arrive in July 2027 or January 2028. But none should be ignored until the last minute.

Packaging takes time to redesign. Contracts take time to renegotiate. Old inventory does not magically disappear when a new labeling rule arrives.

Here is what California cannabis businesses need to know, and what they should start doing now.

This is not a comprehensive summary of every cannabis-related measure enacted in 2026. It focuses on the five bills discussed in our earlier legislative update.

AB 1965, AB 2249 and AB 2532 all became law

Governor Newsom signed the following measures:

AB 1965: Expands the Department of Cannabis Control’s testing authority, requires retail licensees to provide certificates of analysis upon request, and strengthens oversight of licensed testing laboratories.
AB 2249: Clarifies when cannabis packaging, labeling, advertising, and marketing are “attractive to children.”
AB 2532: Adds new labeling rules for edibles and beverages and creates additional requirements for multi-serving cannabis drinks.

Under California’s default rule, a statute enacted during a regular legislative session takes effect on January 1 of the following year unless the statute specifies a later date or qualifies for immediate effectiveness. That means AB 1965 and AB 2532 begin producing compliance obligations in 2027, while AB 2249 gives businesses a longer runway for its new substantive standards.

Let’s take them one at a time.

AB 1965: testing moves downstream

AB 1965 is a testing and quality-assurance bill. Its most important feature is that state testing oversight does not necessarily stop after a product receives a passing result and enters the retail market.

The new law expressly provides that cannabis and cannabis products may be tested or retested. It also requires retailers and other licensees authorized to make retail sales to allow DCC to obtain or access products held or offered for sale for off-the-shelf laboratory testing.

That is significant. A certificate of analysis is no longer necessarily the end of the testing story.

A product can pass compliance testing, move through distribution, reach a retailer, and still be selected for additional state testing. If an off-the-shelf result conflicts with the original certificate, the problem can quickly move beyond the laboratory. Manufacturers, distributors, retailers, and brand owners may all find themselves dealing with quarantined inventory, regulator questions, customer complaints, recalls, or contract disputes.

Certificates of analysis on request

AB 1965 also requires a retailer to provide the certificate of analysis associated with a product held or offered for sale when requested by a customer or DCC.

That sounds simple. In practice, it could expose weak links in a company’s records.

Retailers should be able to connect each product on the shelf to the correct batch and certificate without delay. A certificate buried in an old email chain, stored under an inconsistent file name, or accessible only through a former employee is not much of a compliance system.

Before January 1, retail operators should consider:

Confirming that every active SKU can be matched to its batch-specific certificate of analysis.
Creating a uniform digital filing system for certificates.
Identifying which employees may respond to customer and regulator requests.
Developing a procedure for escalating missing, inconsistent, or suspicious records.
Confirming how long certificates and related batch records will be retained.

If a customer asks for a certificate, the employee handling the request should not look surprised or respond as if the customer asked to inspect the company’s tax returns.

Your California cannabis contracts need attention

Manufacturers, distributors, brands, and retailers should review their laboratory and supply agreements now. Important questions include:

Who receives notice when DCC selects a product for off-the-shelf testing?
Who controls communications with regulators?
Who pays for retesting, product holds, recalls, refunds, or destruction?
What happens when an off-the-shelf result conflicts with the original certificate?
Does the supplier have a duty to preserve testing and batch records?
Does the indemnity provision cover testing failures and mislabeled potency?
Can a retailer suspend sales immediately while the parties investigate?

A contract that merely says each party will “comply with applicable law” will rarely answer those questions.

AB 2249: Branding gets specific

California already prohibits cannabis packages, labels, advertising, and marketing that are attractive to children. AB 2249 does not invent that principle. It gives it sharper edges.

Beginning January 1, 2028, “attractive to children” will mean designed or likely to appeal to people under 21, based on a nonexclusive set of indicators. Those indicators include certain cartoons; people who are or appear to be under 21; celebrities, influencers, characters, mascots, brands, or trade dress primarily associated with children’s entertainment; fantasy or mythological characters; images of candies, cereals, sweets, and desserts; bubble- or balloon-style lettering; and certain candy-related words or playful spellings.

The law also targets cannabis packaging or labeling that imitates or closely resembles non-cannabis products primarily marketed to children. Labels for edible cannabis products and vape cartridges may not use cartoon or overly stylized fruit imagery, although realistic fruit images may still be used to identify ingredients or accurately depict a production region.

DCC must develop compliance-assessment resources to help licensees evaluate packaging and labeling. The department may also regulate additional design elements or product characteristics that present heightened risks to children.

The 2028 date is not a free pass

The new statutory definition becomes operative on January 1, 2028. That does not mean anything goes until then.

Existing law already prohibits packaging and advertising that are attractive to children, and existing DCC regulations already address cartoons, child-oriented imagery, and products designed to imitate commonly available foods. AB 2249 adds more detailed statutory benchmarks and gives regulators a clearer enforcement framework.

Cannabis inventory is the hidden problem

Cannabis companies often order packaging in large quantities to reduce unit costs. That strategy becomes dangerous when the packaging may no longer be usable after January 1, 2028. A brand that waits until late 2027 to review its artwork could end up with pallets of obsolete labels, boxes, pouches, or vape packaging.

Companies should identify questionable designs early, estimate how long existing materials will last, and adjust print runs accordingly. They should also revisit agreements with designers, manufacturers, licensors, and packaging vendors.

AB 2532: beverages get complicated

AB 2532 adds requirements for edible cannabis products and cannabis beverages, with special attention to beverages containing more than one serving.

Effective January 1, 2027, labels and inserts for edible cannabis products and cannabis beverages must include the toll-free telephone number for the national Poison Help line.

Beginning July 1, 2027, the following will be required:

A multi-serving cannabis beverage label must clearly and conspicuously tell the consumer that the product contains multiple servings. It must state the size of one serving in fluid ounces to the nearest tenth and explain how to measure one serving accurately.
Multi-serving beverages in transparent containers, or containers that otherwise reveal the remaining liquid, must display unobstructed and conspicuous lines showing individual portions. An exception applies when the container’s shape makes accurate serving lines impossible.
A retailer selling a multi-serving cannabis beverage must offer the customer, on an as-needed basis and at no extra charge, a manufacturer-provided measuring device. The device must hold at least one fluid ounce and measure to the nearest tenth of a fluid ounce.
Cannabis businesses may not advertise or market a multi-serving beverage as a single-serving product or encourage consumers to drink multiple servings at once.

Responsibility is shared

Manufacturers will need compliant labels, containers, and measuring devices. Distributors will need to confirm they are moving compliant products and accompanying materials. Retailers will need to offer the measuring devices at the point of sale. Brand owners and marketing teams will need to review advertising claims and imagery.

That division of responsibility creates obvious opportunities for something to fall through the cracks. A manufacturer might deliver measuring devices to a distributor but fail to confirm that they reach the retailer. A retailer might receive the devices but store them in a back room. A brand might update the physical label while an online menu still presents the bottle as a single serving.

Each licensee should map the full process from production through the consumer transaction and assign responsibility for every step.

The bottom line

California operators have time, but not unlimited time. AB 1965 turns testing into a continuing retail-level risk. AB 2249 forces companies to look hard at branding and youth appeal. AB 2532 makes multi-serving beverages a shared compliance responsibility from the production line to the retail counter.

The businesses that start early will have options. They can revise contracts, reduce packaging orders, redesign carefully, train employees, and manage old inventory.

The businesses that wait may discover the same lesson California cannabis operators have learned before: a long compliance runway gets very short at the end.

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For more updates on recent marijuana legislation, including rescheduling and the DEA rulemaking process, please check out these recent posts: