Self-distribution.
For vertically integrated operators.

Self-distribution license work breaks cleanly into four operational areas. These are our named responsibilities — not coordination tasks. Where we own, we draft, file, credential, and close out. Where you own, we coordinate but the fleet and commercial decisions are yours.

Escalation path

When work crosses into privileged legal analysis — disputes over whether a transfer qualifies as self-distribution, enforcement appeals where a transport event was characterized as unlicensed, CDTFA audit defense — we coordinate with your counsel or introduce one from our retained network. The engagement letter names this boundary. We do not practice law.

How we draw the boundary with you

You own: vehicle procurement, driver employment, fleet management. We own: the four areas above. Where a decision is yours but we have a clear recommendation — add a Type 11 rather than stretch Type 13 to serve a third-party customer, or restructure ownership before filing to tighten the common-control documentation — we document the recommendation with rationale.

What’s explicitly out of scope

Third-party distribution (which requires Type 11 or a full Type 13 with different scope), vehicle purchase, driver recruitment, fleet maintenance, and any litigation work are not within this engagement.

The application path runs through 5 named milestones.

• Week 1. Ownership overlap verification
• Week 2‐4. SOPs + manifests
• Week 5‐6. Vehicle compliance + insurance
• Week 6‐8. Portal submission
• Week 8+. Deficiency & issuance

When we finish this self-distribution engagement, you have a defined set of documents, filings, and integrated workflows in hand. These are not summary memos. They are filed SOPs, issued bonds, a verified common-ownership structure, and a tracked record defensible against DCC audit, CHP roadside inspection, CDTFA reconciliation, and any diligence review.

The ten outputs, in detail

• Ownership-overlap documentation. Reconciled cap tables for the Type 13 self-distribution license and every source license it will transport for. BPC 26001(al) analysis. Common-ownership letter on file. Operating-agreement alignment so the same Owners, in the same proportions, appear on every license the transport scope covers.
• CCR 15311 transfer manifest SOP. End-to-end workflow for internal transfers between commonly-owned premises — manifest creation in METRC, picking, driver assignment, in-transit tracking, POD at destination, and reconciliation. Drafted to the actual fleet size, not a template.
• Vehicle compliance package. Per-vehicle file with GPS installation and data retention, locking cargo storage specification, alarm and immobilizer, commercial plates, DCC vehicle registration, and any local commercial-vehicle permits. Tracked for inspection, renewal, and replacement.
• Route & driver SOPs. Route plan for every origin-destination pair in the internal network. Driver qualification file covering background, training, identification, roadside-stop protocol, and METRC tagging competence.
• Source-license integration. Integrated SOPs with the cultivation, manufacturing, and/or retail licenses that generate or receive the product. METRC handoff protocol, inventory reconciliation at both ends, and exception handling for partial shipments and rejections.
• Third-party boundary memo. Written scope boundary explicitly excluding third-party transport, third-party testing hold, and any transfer outside the common-ownership family. Delivered to DCC in the application narrative so there is no ambiguity in the license record.
• CDTFA excise workflow. Analysis of which transfers are internal (typically no excise trigger at the internal move) versus arm's-length handoffs to a third-party retailer (15% excise at the retail handoff under Regulation 31C). Quarterly return preparation calendar. Reconciliation path from METRC transfers to excise remittance.
• Form 8113 surety bond. $5,000 DCC commercial cannabis licensee bond procured, filed, and tracked for renewal. Retained for 7 years per CCR 15037.
• Cargo & liability insurance. Cannabis-specific cargo insurance at DCC-required minimums, general liability, auto liability. Certificates of insurance on file and tracked for renewal.
• Monthly reconciliation. Recurring monthly report binding source-license output, Type 13 transfers, destination-license receipts, METRC activity, and excise liability. Used for internal audit, CDTFA review, and the next renewal.

Format and delivery

Every document is delivered as an editable source and a controlled PDF. Records retained for 7 years per CCR 15037. CDTFA records retained for 8 years where that retention extends.

Defensibility anchor

Every recommendation cites a specific authority. BPC 26070 for the Type 13 authority. BPC 26001(al) for common-ownership definition. CCR 15311 for transport and manifests. CDTFA Regulation 31C for excise. Form 8113 for the bond. If DCC, CDTFA, CHP, or a future diligence team asks “why did you do it this way?” the citation is in the document.

What’s not included

Third-party distribution scope, vehicle purchase, driver employment, fleet maintenance, and any privileged legal analysis (enforcement appeals, CDTFA audit defense, ownership-dispute litigation) are explicitly outside this scope. Where those are needed, we coordinate with retained counsel or introduce the appropriate specialist.

Deliverables are what we produce. Outcomes are what they enable.

• Authorized. to move your own product — no reliance on third-party distributor.
• Cost-efficient. no markup on self-moves; predictable logistics costs.
• Compliant. boundary with third-party work clearly documented.

No opinion-based compliance.

• BPC 26050 — core regulation for this license type.
• CCR 15311 — core regulation for this license type.
• CCR 15307 — core regulation for this license type.
• BPC 26001(al) — core regulation for this license type.
• Form 8113 — core regulation for this license type.
• Form DCC-LIC-019 — core regulation for this license type.

• Can I transport other licensees’ product? No — self-distribution is operator-only. Third-party transport requires full Type 13 or Type 11.
• Do I collect excise? When you hand product off to a retailer (third-party arm’s-length transfer), yes. When moving internally between your own licenses, no.
• Can I add third-party later? You’d need a separate Type 13 or Type 11 license.
• How does this work with METRC? Same manifests as Type 13 distribution; the licensee-to-licensee transfer is still logged.
• Cost? $60K–$250K year one. Vehicle fleet and insurance drive variance.