The CNMI Cannabis Commission is now accepting commercial and noncommercial licenses applications. On June 23, 2020, the Commission at its meeting and pursuant to Public Law 20-66 and Public Law 21-05, adopted its proposed rules and regulations that set forth the application process. This article is an introduction on how to apply for the different kinds of cannabis licenses available in the CNMI.

1. Different Types of Licenses

The first step is to determine which kind of license are you going to apply for. Certain licenses also have different classes based on the size of the applicant’s operation. These are the options:

(1) Production License: If you would like to grow cannabis, you need a production license.

    1. Micro Production License: No more than twenty-five (25) mature marijuana plants
    2. Class I License: Less than 750 square feet under cultivation
    3. Class II License: 750 to 2,999 square feet under cultivation
    4. Class III License: 3,000 to 5,000 square feet under cultivation

(2) Processor License: If you want to use cannabis as raw material to produce other product, you need a processor license.

(3) Wholesale License: If you would like to become a wholesaler, which means you will buy large amount of cannabis and distribute to retailers, you need a wholesale license.

(4) Retail License: If you are going to sell cannabis to customers as a retailer, you need a retail license.

(5) Lounge License: If you are interested in opening a cannabis lounge which will allow consumers to use marijuana on-site, you need a lounge license.

    1. Class I License: Sell for on-site consumption
    2. Class II License: Allows for on-site consumption

2. Choose the Location

Because the cannabis industry is a special industry, there are restrictions on the location of certain kinds of cannabis businesses. Before submitting the application, it is best to confirm that the location of the business meets the requirements in the regulations.

First, no matter what kind of cannabis business the applicant is planning to open, the facility cannot be located on federal property. The facility should also not locate on CNMI Public land, unless there is an existing public land lease with existing hotels or commercial buildings.

In addition to the restriction above, a producer cannot apply for a license on the same lot as another producer licensee under common ownership. A processor who has an endorsement to process extracts may not use a premise in an area that is zoned exclusively for residential use.

Retailer premises and lounge premises may not locate within 500 feet of:

  1. a public or private school;
  2. Any church, hospital, medical clinic;
  3. Daycare center; or
  4. Youth center;

Specifically, “within 500 feet” means a straight-line measurement in a radius extending for 500 feet or less in any direction from the closest point anywhere on the boundary line of the real property used in the application to the closest point of the licensed premises.

3. Prepare Your Documents

Applicants need to prepare documents according to their business structure (Sole proprietorship, Corporation, LLC, etc.) and type of the licenses they are hoping to obtain.
Generally, each application at least needs to contain:

(1) Lease Agreement or Proof of Ownership of the premises the applicant is going to use for this application.

(2) Signage: This including the proposed premises exterior signage and interior design schematics.

(3) Scope of Operations: Applicant needs to submit a detail description of proposed business. The content of the description depends on the type of license you are going to apply.

(4) Floor Plan: The floor plan should be put on a standard letter size paper, must be clear, legible and include: (a) each room or area labelled with its intended use and dimensions (this must include designation of the consumer consumption area); (b) walls, partitions, windows; (c) storage, limited access areas, office space; (d) entrances and exits; (e) secured cannabis storage area; (f) furniture and fixture layout; (g) security features.

(5) Site Map: The site map needs to show representation of any interior or exterior spaces or buildings surrounding the proposed licensed area(s), pathways of travel, parking, and landscaping elements, and the surrounding area. Either a hand-drawn or computer generated site map is acceptable on a standard letter size paper, must be clear, legible and include: (a) the location of any other buildings/businesses on the same site, labelled as type of business and building names, and their entrances and exits; (b) a description of the type of separation proposed for any adjoining businesses; (c) road access and exits, including any relevant street names; and (d) parking lots.

(6) Standard Operating Procedures: It is an instruction for the employee to conduct the business.
The minimum requirement of the Standard Operating Procedures depends on the type of license the applicant is going to apply.

(7) Copy of Receipt of Payment for Zoning Application (Saipan only)

(8) Business License (Submit Later)

(9) Zoning Authorization (Submit Later) (Saipan only)

Additional materials may also be required depending on the type of license the applicant is trying to obtain.

4. Application Fee and License Fee

The fee depends on the type of license the applicant is applying for, and each applicant is required to submit a nonrefundable application fee. If the application is granted, a separate license fee will also be assessed.

Type of License Class of License Application Fee License Fee
Producer License      
  Micro Production $250 $500
  Class 1 $500 $1,000
  Class 2 $750 $3,700
  Class 3 $1,000 $6,500
Processor License   $1,000 $4,500
Wholesale License   $250 $2,000
Retail License   $1,000 $6,000
Marijuana Lounge      
  Class 1 $1,500 $5,000
  Class 2 $1,500 $3,500

5. Review and Inspection

After submitting the application package, the Commission will notify the applicant of any deficiencies and request additional information. If the Cannabis Commission believes that the application meets the requirements of the law and regulations, the Commission will notify the applicant regarding to the inspection process.

The premises the applicant uses to apply for business license needs to meet all of the requirements for the specific type of license. For example, if the applicant would like to get a license for a class 1 Marijuana Lounge, there must be a sign that reads “No Minors Permitted Anywhere on the Premises” posted in a prominent place.

After passing the inspection, if the Commission received all of the required documents, the Commission will proceed to its final review and decide whether a license should be granted.
If the licensing request is approved, the applicant will pay the license fee to a special account designate by the Commission. After the license is issued, all licensees still need to update the Commission on any changes to the information that was contained in the application, or as is required by the Commission.


Cannabis was used by doctors for medical purpose for a long time. In the recent years, cannabis has been legalized in different parts of the world. The legislature of the CNMI believes that a regulated cannabis market would benefit the health, safety, and overall quality of life for the CNMI residents. Because the CNMI is a new market, the are plenty of opportunities for investors. The long awaited for application process is now open. All you entrepreneurs who have been waiting to get started can apply now.

Anthea Yuan is an attorney with the Dotts Law Office and practices Tax Law. She received an LLM in Tax from Northwestern University, graduating with honors.
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