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Illinois Adult Use Craft Grower, Infuser, and Transporter License Application Deadline Extended, Again

Last Updated on Apr 3, 2020

"When the rules to play the game that you're playing change, you've gotta adapt your strategy and play the game differently; otherwise, you're going to lose."

The original deadline for the Illinois Adult Use Craft Grower, Infuser, and Transporter license applications was March 16. As COVID-19 made it's way to the United States, Illinois Governor JB Pritzker proactively extended the application deadline to March 30, via Executive Order 2020-03, for applicants that had not yet submitted in person. 

To flatten the curve of Coronavirus cases in Illinois, Governor Pritzker instated a stay-at-home and school closure order on March 21. These mandates were extended via executive order on April 1 and will remain in effect through at least April 30. Due to the disruption of day-to-day life from COVID-19, the Governor signed Executive Order 2020-17 on March 28, which extended the deadline for Adult-Use Cannabis Craft Grower, Infuser, and Transporter license applications a second time. All applications must now be submitted via United States Postal Service certified mail and postmarked on or before the new April 30, 2020 deadline. Due to the unknown timeline of the Coronavirus pandemic, fingerprinting, and zoning verification deficiencies will be allowed, see below for the complete details. For those who have already applied, you may now resubmit a revised application. Please take the time to review the specific details of these changes below.

Deadline and Submission Process Changes

  • Applications must be submitted via United States Postal Service certified mail
  • Must be postmarked on or before April 30, 2020

Application Resubmission Instructions

  • Applicants must submit a new COMPLETE APPLICATION, excluding payment. Payment will be taken from the originally submitted application and applied to the newly filed application.
  • The outside of the mailed package must indicate in capital letters "APPLICATION SUPPLEMENT."
  • By resubmitting an application, the applicant agrees that the previously submitted application is superseded in its entirety by the resubmitted application. The previously submitted application will be considered void and will not be reviewed, scored, or considered in any way.
  • DO NOT INCLUDE ADDITIONAL PAYMENT IF PAYMENT WAS INCLUDED IN THE ORIGINAL APPLICATION.

Allowable Application Deficiencies

  • If an applicant is unable to complete fingerprinting prior to submitting its application, a deficiency will be issued and the applicant will be given time to complete the fingerprinting process. Proper fingerprinting and background checks must be completed prior to award of a license.
  • If an applicant is unable to obtain zoning approvals prior to submitting its application, a deficiency will be issued. All zoning requirements must be met prior to award of a license.
Considering the above changes, do NOT slow down and coast into the finish line. Remember, every team now has the bandwidth to improve their applications, and the wise will use it. These license applications will be competitive, as we are looking at potentially the last vertically-integrated adult-use licenses in Illinois, a market set to be a leader in annual revenue. The time and effort that you put in now will make the difference between receiving a license or a disappointing email notifying you of your application denial.

This resubmission process is a chance to strengthen your application to be all it can and should be. Given the value of these licenses, it is paramount that you take the time to truly develop your application. Generic templates will not win you a license; this is almost a guarantee. Each application must be highly tailored to your specific operations, your selected and properly zoned location, and your unique team, otherwise you are wasting your time and money submitting these applications. If you have used a license application template to create your content, we strongly advise having an expert review your final application for completeness and accuracy. We have seen many of these templates fall far short of the best practices we provide our clients and what the Illinois Department of Agriculture will be looking for and expecting.

To finish strong and submit your team's best possible application, consider the following:

  • Review EVERY requirement outlined in the application's instructions. Have you met each requirement?
  • Review your application content
    • Have you proven beyond a doubt that you are qualified to operate a compliant adult-use cannabis business in the state of Illinois?
    • Is your team the strongest it can be?
    • Are your resumes as thorough as they can be?
    • Do you have fully developed facility plans? Floor plans? 3D renderings? Security plans? Operational plans?
    • Are your non-narrative exhibits clean and organized, or are they a jumbled mess of poorly-scanned documents? Are all of the details 100% correct and verified?
    • Is your application as specific as possible regarding power and water usage? Is it accurate to your proposed facility or generic?
    • Do your floor plans, security plans, and site plans comply with the instructions of the application? Are you missing anything in these plans that could potentially lower your score?
    • Does your content cover every single regulation in the Emergency Rules (8 IAC 1300) and the Cannabis Regulation and Tax Act (410 ILCS 705/) and any of the clarifications from the FAQ round one and two?
    • Are your environmental policies and strategies sufficient enough? Have you considered everything you can do to be as environmentally sustainable as possible?
    • Does your Infusion Plan include all the regulations related to the Food Safety Modernization Act ("FSMA"), the Illinois Food, Drug, and Cosmetic Act, Sanitary Food Preparation Act, and the Food Handling Regulation Enforcement Act? Or did you only include the regulations in the Emergency Rules and the Cannabis Regulation and Tax Act?
    • Does your Cultivation Plan address all possible factors that may lead to production delays to ensure you genuinely meet consumer demand?
Never in our over a decade of cannabis business licensing experience have we seen a program give not only one but now two deadline extensions. If you have any questions or would like a second opinion on your application, contact us today. We are happy and able to help.

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