Today, Governor Pritzker signed into law the Cannabis Regulation and Tax Act (the “Act”) that was passed by the Illinois General Assembly on May 31, 2019. There was never any question about whether Governor Pritzker would sign the Act, but today’s signing is significant in that it officially starts the clock on certain provisions.

Most notably, existing medical marijuana dispensaries will have 60 days from today to apply for (1) Early Approval Adult Use Dispensing Organization Licenses for existing dispensaries, and (2) Early Approval Adult Use Dispensing Organization Licenses for new secondary sites. Similarly, current medical marijuana cultivators will have at least 60 days (but no more than 180 days), to apply for an Early Approval Adult Use Cultivation Center License to produce recreational cannabis and cannabis-infused products at their existing facilities. In addition, the signing triggers deadlines for various departments and offices to adopt rules in accordance with their prescribed responsibilities under the Act.

We will continue to track Illinois’s progress in rolling out its adult-use cannabis program.