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Guide for CBD Product Sales at Special Events

Any vendor that operates on a temporary basis at an event in the City and County of Denver may sell or distribute products containing hemp or hemp-derived Cannabidiol (CBD) at the event as long as certain guidelines are followed. Under no circumstances may vendors sell or distribute marijuana or marijuana products within Denver.

 

I. Do I need a license to sell or distribute hemp/CBD products at special events?

Event organizers and vendors who intend to sell or distribute hemp/CBD products at special events in Denver may need a business license from the Denver Department of Excise and Licenses (EXL) and/or a tax license from the Treasury Division in the Denver Department of Finance (Treasury).

INGESTIBLE HEMP/CBD PRODUCTS:  

Vendors selling or distributing ingestible products at special events in Denver must obtain a Denver business license. Anything that can be ingested by a human being is considered an ingestible product.
Common examples of ingestible products include:

  • Food and food products containing hemp/CBD
  • Hemp tinctures, extracts, or ingestible oils containing hemp/CBD
  • Pills, supplements, or capsules containing hemp/CBD


Business license types: Vendors may need a temporary restaurant license, a food peddler license, and/or a peddler license, depending on the event configuration and manner in which the vendor sells or distributes product. Contact EXL for more information.

OTHER HEMP/CBD PRODUCTS:

Vendors do not currently need a business license to sell or distribute other hemp/CBD products. Common examples of other products include:

  • Topical products such as lotions or balms containing hemp/CBD
  • Pet supplements or treats containing hemp/CBD
  • Inhalable or vape-able hemp/CBD products

 

RETAIL SALES OF HEMP/CBD PRODUCTS

Any vendor who will be making hemp/CBD retail sales at a special event in Denver must obtain a tax license, regardless of whether a vendor needs a business license.

Tax license types: If a vendor has a current Denver sales tax license, no additional tax license is required. However, vendors who do not have a current Denver sales tax license may need a Denver special event sales tax license. State taxes may also apply. Contact Treasury for more information.

 

II. What requirements apply to ingestible hemp/CBD products?

As with any ingestible product, the Denver Department of Public Health and Environment (DDPHE) will evaluate all ingestible hemp/CBD products being sold or distributed at special events in accordance with the Denver Food Establishment Rules & Regulations. Evaluations are necessary to ensure that both the hemp/CBD ingredient and the final product being sold or distributed come from approved sources and to determine if refrigeration is needed.

 

APPROVED SOURCES:

INSIDE COLORADO: If the hemp/CBD product is produced in Colorado, the product must come from a source that is registered with and approved by the Colorado Department of Public Health and Environment (CDPHE) as a wholesale food manufacturer. Hemp/CBD ingredients sourced from within Colorado are considered from an approved source if all utilized parts of the hemp plant originate from a cultivator registered with the Colorado Department of Agriculture (CDA). CDPHE maintains a list of these registered and approved sources on their website.

OUTSIDE OF COLORADO: If the hemp/CBD product is produced outside of Colorado, verification that the product manufacturer is under regulatory public health oversight must be sent to PHIcomments@denvergov.org at least two weeks prior to the event. Hemp/CBD ingredients sourced from outside of Colorado are considered from an approved source if all utilized parts of the hemp plant originate from a cultivator operating under a regulated industrial hemp program which applies safe consumption criteria.

 

REFRIGERATION

Refrigeration at or below 41°F is required for the following types of ingestible hemp/CBD products:   

These types of products can be stored outside of refrigeration only if the vendor has a current shelf stability approval letter from DDPHE.

III. What are the penalties for selling or distributing ingestible hemp/CBD products without a license and required approval?

 

VENDORS

Vendors who sell or distribute ingestible hemp/CBD products at a special event without obtaining the required licensure and approvals will be issued a cease and desist order and may be cited criminally. Additional penalties and/or future permitting consequences may apply for noncompliance.


EVENT ORGANIZERS

Event organizers who allow vendors to sell or distribute ingestible hemp/CBD products without first obtaining the required licensure and approvals may also be cited, fined, and/or be subject to permitting consequences for subsequent events.

 

IV. Need more information?

 

BUSINESS LICENSING INFORMATION

Vendors and event organizers may contact EXL by email at EXLapplications@denvergov.org to learn more about licensing at special events and ask questions about other hemp/CBD regulations.

 

TAX LICENSING INFORMATION

Vendors and event organizers may contact Treasury by calling (720) 913-9446 to learn more about tax licensing for retail sales at special events.

 

APPROVED SOURCE AND REFRIGERATION INFORMATION

Vendors and event organizers may contact DDPHE by email at PHIcomments@denvergov.org  to ask questions and submit verifications regarding approved sources and shelf stability.

 

HEMP BULLETIN

Sign up for the City’s hemp bulletin to receive updates about hemp/CBD regulations in Denver.

 

This document is meant to assist businesses in determining what licensing they might need to operate in the City and County of Denver (the City). The information contained in this document is provided for guidance purposes only and is not intended to constitute legal advice. The City does not warrant or make any representations about the quality, content, accuracy, timeliness, or completeness of the information provided in this document. Such materials are subject to change without notification at any time and may not be up-to-date. It is the applicant’s own responsibility to ensure that they do not violate any applicable requirements and any applicable state or city laws and rules.