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California's Pesticide Recall Chain Reaches Downstream Licensees: Three New DCC Notices and the Third-Party Biomass Problem

California's Department of Cannabis Control published three further adulteration recalls on September 14 and 15. One names a licensee that bought the cannabis from someone else — and that is the part operators need to read.
Compliance Carl
6
 Min Read
Published
September 26, 2026
Updated on:
September 26, 2026
Abstract diagram of one upstream supply node branching to five downstream nodes, two flagged in pink, illustrating a cultivation failure cascading to downstream cannabis licensees
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California's Department of Cannabis Control published three more voluntary recall notices on September 14 and 15, 2026: two covering products from Peace and Joy LLC, doing business as Tree House (license C11-0002011-LIC), and one covering Cali Lean Tincture products from 510 Consultants LLC (license C12-0000453-LIC). All three cite the same defect language DCC used five days earlier for a recall tied to license C11-0001216-LIC: cannabis "produced under unsanitary conditions" that failed to meet pesticide rules. The 510 Consultants notice adds one sentence the other two do not have — the contaminated cannabis was "sourced from a third-party cultivator" — and that sentence is why this recall round matters well beyond the two companies named in it.

The mechanism

The chain starts on September 9 and 10. DCC's recall portal lists a notice for Iced Infused Flower, business-recall-dated September 9 and published September 10, filed under license C11-0001216-LIC by Natura Distribution LLC (doing business as A2B and Heritage Co-Pack). Trade outlet MJBizDaily linked to that same notice in its coverage of a separate enforcement action: DCC suspended the cultivation permit of a large Lake County grow, Joel Michaely Farms, on September 8, one day after a farm worker's death, and cited the operation for untagged plants, missing track-and-trace records, and pesticide violations. A DCC spokesperson told MJBizDaily that "the recalls and embargos address all potentially contaminated product transferred from the cultivator since licensure." DCC's own recall notice, however, does not name Joel Michaely Farms — that link exists only in trade-press reporting on the suspension, not in the recall notice itself.

Four to five days later, DCC published the two recalls that make this a compliance story rather than a single news item. On September 14: Tree House Flower and Martini's Pre-Roll, both from Peace and Joy LLC, both business-recall-dated September 9. On September 15: Cali Lean Tincture from 510 Consultants LLC, also dated September 9. All three use nearly identical language — the cannabis "was produced under unsanitary conditions and the methods, facilities, or controls used to cultivate the cannabis did not conform with pesticide statutes and regulations." The 510 Consultants notice appends a further sentence: the cannabis "was sourced from a third-party cultivator." That is the detail our earlier coverage of California's vape and cannabis rules did not have occasion to cover, because that piece addressed consumer-facing vape recalls, not the licensee-to-licensee compliance chain behind a manufacturing recall.

Why it is not settled

Three things remain open. First, DCC has not named a cultivator common to the Tree House and 510 Consultants recalls; both notices identify the recalling licensee, not the farm that grew the cannabis. Second, the department has not confirmed that the biomass behind either notice came from Joel Michaely Farms — that connection currently exists only in trade-press reporting on the suspended grow. Third, a voluntary recall is not a finding of fault. It is a business decision made by the licensee holding the product, under DCC's expectation that adulterated cannabis be removed from the market once identified. None of the three September notices is labeled mandatory, and none states a cause beyond the standard adulteration language. Treat the timing as a pattern worth watching, not a proven supply-chain link.

Operator impact this week

  • Read your supply agreements for who bears recall costs and who is designated the "recalling party" when a defect originates upstream. The 510 Consultants notice shows a downstream purchaser can end up executing — and paying for — a recall triggered by a cultivator's pesticide failure.
  • Check whether your intake certificates of analysis actually test for the pesticide panel DCC is citing in this "Adulterated: Other" language, not just potency and the standard microbial and heavy-metal contaminants.
  • Confirm your lot traceability reaches back to the originating cultivator's license number in Metrc, not just to your own date of intake. Our note on compliance indicators that predict enforcement exposure early covers what that traceability should look like at the dashboard level.
  • Review your product-recall insurance language against what a "voluntary" recall does to coverage triggers and exclusions — see our breakdown of what underwriters require on a recall application.
  • Separate the two failure modes in your own risk register: recalling a product you manufactured is a different exposure than recalling a product you purchased finished or as biomass, where your due-diligence obligation at purchase is the open question.
  • Talk to your counsel before a similar notice reaches your license, particularly if your contracts are silent on which party controls recall costs and communications when the underlying defect is a vendor's.

Jurisdictional contrast

California's three September recalls started with an enforcement action against a cultivator that then cascaded to the licensees who had purchased or processed its biomass, with each recalling company issuing its own notice under DCC's voluntary-recall framework — a posture shaped by broader shifts in the state's licensing structure, including the DCC's emergency licensing changes earlier this year.

Missouri's Division of Cannabis Regulation (DCR) catches the same underlying risk a different way. Under a routine sampling initiative it began running in July 2025, DCR independently retested Juicy J's Cherry Limeade Infused Pre-Rolls, made by CCMRB Processing LLC (license MAN000103), and found an Aspergillus mold failure — publishing what it labeled a mandatory recall on September 16, regardless of what the manufacturer's own COA had shown. See our broader look at Missouri's cannabis and hemp testing rules. The contrast is mechanical, not cosmetic: California's chain starts with an enforcement trigger against a cultivator and radiates outward to buyers through their own voluntary notices; Missouri's starts with the regulator's own retest of finished product on the shelf, independent of the licensee's paperwork. That difference changes who discovers the problem first and how much warning a downstream licensee gets before its product is named.

Colorado is tightening the testing side of the same risk further. Under Marijuana Enforcement Division Industry Bulletin 26:09, issued September 11, expanded residual-solvent testing for marijuana concentrates takes effect September 28 — 17 additional solvents beyond the state's existing panel, with a 31st (triethylamine) to follow once a lab is certified to test for it. The requirement was originally due July 1 and was delayed because no lab had the certification needed to run the new panel. For operators watching California's pesticide chain, Colorado's expansion is a reminder that a testing panel is not a fixed target: what your COA covers today may not cover what a regulator adds next quarter. That patchwork extends well beyond marijuana testing regimes — operators who also handle hemp-derived cannabinoid products should keep in mind that state-by-state delta-8 legality is just as fragmented and requires its own separate tracking. California's own compliance load has moved on multiple fronts this year too, from the AB 2249 and AB 2250 packaging changes working through Sacramento to the state's 2025 hemp enforcement activity.

What's next

  • September 28, 2026 — Colorado's expanded residual-solvent testing requirement takes effect for marijuana concentrates (17 new solvents; triethylamine enforcement to follow once a lab is certified).
  • Ongoing, no date announced — DCC's investigation into the Joel Michaely Farms suspension remains open; the department has not named a cultivator common to the Tree House or 510 Consultants recalls.
  • Ongoing — DCC has stated it is using Track and Trace to identify any additional batches connected to the suspended cultivator; further recall notices are possible if that review turns up more product.
  • Ongoing — Missouri DCR's recall covers 118 package tags across 19 dispensary licenses and one manufacturing facility; watch for whether additional CCMRB Processing lots fail the division's shelf-sampling.

FAQ

What does a DCC recall notice actually require a licensee to do?

A DCC recall notice identifies affected lots and requires the named licensee to pull them from sale and coordinate with retailers holding remaining inventory. All three September notices here are voluntary recalls, initiated by the licensee rather than ordered by DCC as a mandatory action. Talk to your counsel about what your specific notice requires in writing.

Who is responsible when contaminated cannabis came from a third-party cultivator?

Under DCC's recall framework, the obligation to issue and execute a recall follows the licensee holding and selling the finished product, not necessarily the cultivator whose pesticide failure caused the adulteration. The 510 Consultants notice states plainly that the cannabis was sourced from a third-party cultivator, yet 510 Consultants is the recalling party. Contractual liability between the two companies is a separate question governed by their supply agreement — talk to your counsel about how that risk is allocated in yours.

Are the September 14–15 recalls connected to the September 10 Natura recall?

They share the same "Adulterated: Other" reason code and nearly identical defect language. DCC has not named a cultivator common to all three notices, and the department has not confirmed that the Tree House or 510 Consultants biomass came from the same source implicated in the separate farm-suspension matter. The investigation is open.

Does a passing certificate of analysis protect a retailer from a recall?

Not by itself. A COA only confirms what it was tested for. Missouri's Division of Cannabis Regulation illustrated the gap on September 16, when its own routine shelf-sampling caught an Aspergillus failure in a product that had already cleared the manufacturer's testing — regulators are increasingly retesting product independently rather than relying solely on a licensee's submitted COA.

What is a voluntary recall versus a mandatory recall?

A voluntary recall is initiated by the licensee itself, typically after a regulator flags a problem or the company identifies one internally; California's three September notices are all voluntary. A mandatory recall is ordered directly by the regulator — Missouri's Division of Cannabis Regulation labeled its September 16 Juicy J's action a mandatory recall. Which category applies changes who controls the process, but not the underlying obligation to get contaminated product out of the market.

Comparison: the September California recall chain

ProductLicenseeLicense numberDCC publication dateStated basisRecalling party's role
Iced Infused FlowerNatura Distribution LLC (dba A2B; Heritage Co-Pack)C11-0001216-LIC9/10/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Tree House FlowerPeace and Joy LLC dba Tree HouseC11-0002011-LIC9/14/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Martini's Pre-RollPeace and Joy LLC dba Tree HouseC11-0002011-LIC9/14/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Cali Lean Tincture510 Consultants LLCC12-0000453-LIC9/15/2026Adulterated: Other — cannabis sourced from a third-party cultivatorExplicitly stated: downstream purchaser

Sources

This is regulatory journalism, not legal advice — talk to your counsel.

Compliance Carl
Senior Compliance Editor
Compliance Carl is the senior editor desk at CannabisRegulations.ai. Carl writes about federal scheduling, state enforcement, carrier policy, and the operational compliance questions cannabis and hemp businesses actually face.

Featured Compliance Insights

September 23, 2026

California's Pesticide Recall Chain Reaches Downstream Licensees: Three New DCC Notices and the Third-Party Biomass Problem

California's Pesticide Recall Chain Reaches Downstream Licensees: Three New DCC Notices and the Third-Party Biomass Problem

California's Department of Cannabis Control published three more voluntary recall notices on September 14 and 15, 2026: two covering products from Peace and Joy LLC, doing business as Tree House (license C11-0002011-LIC), and one covering Cali Lean Tincture products from 510 Consultants LLC (license C12-0000453-LIC). All three cite the same defect language DCC used five days earlier for a recall tied to license C11-0001216-LIC: cannabis "produced under unsanitary conditions" that failed to meet pesticide rules. The 510 Consultants notice adds one sentence the other two do not have — the contaminated cannabis was "sourced from a third-party cultivator" — and that sentence is why this recall round matters well beyond the two companies named in it.

The mechanism

The chain starts on September 9 and 10. DCC's recall portal lists a notice for Iced Infused Flower, business-recall-dated September 9 and published September 10, filed under license C11-0001216-LIC by Natura Distribution LLC (doing business as A2B and Heritage Co-Pack). Trade outlet MJBizDaily linked to that same notice in its coverage of a separate enforcement action: DCC suspended the cultivation permit of a large Lake County grow, Joel Michaely Farms, on September 8, one day after a farm worker's death, and cited the operation for untagged plants, missing track-and-trace records, and pesticide violations. A DCC spokesperson told MJBizDaily that "the recalls and embargos address all potentially contaminated product transferred from the cultivator since licensure." DCC's own recall notice, however, does not name Joel Michaely Farms — that link exists only in trade-press reporting on the suspension, not in the recall notice itself.

Four to five days later, DCC published the two recalls that make this a compliance story rather than a single news item. On September 14: Tree House Flower and Martini's Pre-Roll, both from Peace and Joy LLC, both business-recall-dated September 9. On September 15: Cali Lean Tincture from 510 Consultants LLC, also dated September 9. All three use nearly identical language — the cannabis "was produced under unsanitary conditions and the methods, facilities, or controls used to cultivate the cannabis did not conform with pesticide statutes and regulations." The 510 Consultants notice appends a further sentence: the cannabis "was sourced from a third-party cultivator." That is the detail our earlier coverage of California's vape and cannabis rules did not have occasion to cover, because that piece addressed consumer-facing vape recalls, not the licensee-to-licensee compliance chain behind a manufacturing recall.

Why it is not settled

Three things remain open. First, DCC has not named a cultivator common to the Tree House and 510 Consultants recalls; both notices identify the recalling licensee, not the farm that grew the cannabis. Second, the department has not confirmed that the biomass behind either notice came from Joel Michaely Farms — that connection currently exists only in trade-press reporting on the suspended grow. Third, a voluntary recall is not a finding of fault. It is a business decision made by the licensee holding the product, under DCC's expectation that adulterated cannabis be removed from the market once identified. None of the three September notices is labeled mandatory, and none states a cause beyond the standard adulteration language. Treat the timing as a pattern worth watching, not a proven supply-chain link.

Operator impact this week

  • Read your supply agreements for who bears recall costs and who is designated the "recalling party" when a defect originates upstream. The 510 Consultants notice shows a downstream purchaser can end up executing — and paying for — a recall triggered by a cultivator's pesticide failure.
  • Check whether your intake certificates of analysis actually test for the pesticide panel DCC is citing in this "Adulterated: Other" language, not just potency and the standard microbial and heavy-metal contaminants.
  • Confirm your lot traceability reaches back to the originating cultivator's license number in Metrc, not just to your own date of intake. Our note on compliance indicators that predict enforcement exposure early covers what that traceability should look like at the dashboard level.
  • Review your product-recall insurance language against what a "voluntary" recall does to coverage triggers and exclusions — see our breakdown of what underwriters require on a recall application.
  • Separate the two failure modes in your own risk register: recalling a product you manufactured is a different exposure than recalling a product you purchased finished or as biomass, where your due-diligence obligation at purchase is the open question.
  • Talk to your counsel before a similar notice reaches your license, particularly if your contracts are silent on which party controls recall costs and communications when the underlying defect is a vendor's.

Jurisdictional contrast

California's three September recalls started with an enforcement action against a cultivator that then cascaded to the licensees who had purchased or processed its biomass, with each recalling company issuing its own notice under DCC's voluntary-recall framework — a posture shaped by broader shifts in the state's licensing structure, including the DCC's emergency licensing changes earlier this year.

Missouri's Division of Cannabis Regulation (DCR) catches the same underlying risk a different way. Under a routine sampling initiative it began running in July 2025, DCR independently retested Juicy J's Cherry Limeade Infused Pre-Rolls, made by CCMRB Processing LLC (license MAN000103), and found an Aspergillus mold failure — publishing what it labeled a mandatory recall on September 16, regardless of what the manufacturer's own COA had shown. See our broader look at Missouri's cannabis and hemp testing rules. The contrast is mechanical, not cosmetic: California's chain starts with an enforcement trigger against a cultivator and radiates outward to buyers through their own voluntary notices; Missouri's starts with the regulator's own retest of finished product on the shelf, independent of the licensee's paperwork. That difference changes who discovers the problem first and how much warning a downstream licensee gets before its product is named.

Colorado is tightening the testing side of the same risk further. Under Marijuana Enforcement Division Industry Bulletin 26:09, issued September 11, expanded residual-solvent testing for marijuana concentrates takes effect September 28 — 17 additional solvents beyond the state's existing panel, with a 31st (triethylamine) to follow once a lab is certified to test for it. The requirement was originally due July 1 and was delayed because no lab had the certification needed to run the new panel. For operators watching California's pesticide chain, Colorado's expansion is a reminder that a testing panel is not a fixed target: what your COA covers today may not cover what a regulator adds next quarter. That patchwork extends well beyond marijuana testing regimes — operators who also handle hemp-derived cannabinoid products should keep in mind that state-by-state delta-8 legality is just as fragmented and requires its own separate tracking. California's own compliance load has moved on multiple fronts this year too, from the AB 2249 and AB 2250 packaging changes working through Sacramento to the state's 2025 hemp enforcement activity.

What's next

  • September 28, 2026 — Colorado's expanded residual-solvent testing requirement takes effect for marijuana concentrates (17 new solvents; triethylamine enforcement to follow once a lab is certified).
  • Ongoing, no date announced — DCC's investigation into the Joel Michaely Farms suspension remains open; the department has not named a cultivator common to the Tree House or 510 Consultants recalls.
  • Ongoing — DCC has stated it is using Track and Trace to identify any additional batches connected to the suspended cultivator; further recall notices are possible if that review turns up more product.
  • Ongoing — Missouri DCR's recall covers 118 package tags across 19 dispensary licenses and one manufacturing facility; watch for whether additional CCMRB Processing lots fail the division's shelf-sampling.

FAQ

What does a DCC recall notice actually require a licensee to do?

A DCC recall notice identifies affected lots and requires the named licensee to pull them from sale and coordinate with retailers holding remaining inventory. All three September notices here are voluntary recalls, initiated by the licensee rather than ordered by DCC as a mandatory action. Talk to your counsel about what your specific notice requires in writing.

Who is responsible when contaminated cannabis came from a third-party cultivator?

Under DCC's recall framework, the obligation to issue and execute a recall follows the licensee holding and selling the finished product, not necessarily the cultivator whose pesticide failure caused the adulteration. The 510 Consultants notice states plainly that the cannabis was sourced from a third-party cultivator, yet 510 Consultants is the recalling party. Contractual liability between the two companies is a separate question governed by their supply agreement — talk to your counsel about how that risk is allocated in yours.

Are the September 14–15 recalls connected to the September 10 Natura recall?

They share the same "Adulterated: Other" reason code and nearly identical defect language. DCC has not named a cultivator common to all three notices, and the department has not confirmed that the Tree House or 510 Consultants biomass came from the same source implicated in the separate farm-suspension matter. The investigation is open.

Does a passing certificate of analysis protect a retailer from a recall?

Not by itself. A COA only confirms what it was tested for. Missouri's Division of Cannabis Regulation illustrated the gap on September 16, when its own routine shelf-sampling caught an Aspergillus failure in a product that had already cleared the manufacturer's testing — regulators are increasingly retesting product independently rather than relying solely on a licensee's submitted COA.

What is a voluntary recall versus a mandatory recall?

A voluntary recall is initiated by the licensee itself, typically after a regulator flags a problem or the company identifies one internally; California's three September notices are all voluntary. A mandatory recall is ordered directly by the regulator — Missouri's Division of Cannabis Regulation labeled its September 16 Juicy J's action a mandatory recall. Which category applies changes who controls the process, but not the underlying obligation to get contaminated product out of the market.

Comparison: the September California recall chain

ProductLicenseeLicense numberDCC publication dateStated basisRecalling party's role
Iced Infused FlowerNatura Distribution LLC (dba A2B; Heritage Co-Pack)C11-0001216-LIC9/10/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Tree House FlowerPeace and Joy LLC dba Tree HouseC11-0002011-LIC9/14/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Martini's Pre-RollPeace and Joy LLC dba Tree HouseC11-0002011-LIC9/14/2026Adulterated: Other — unsanitary conditions, pesticide non-conformanceNot stated in notice
Cali Lean Tincture510 Consultants LLCC12-0000453-LIC9/15/2026Adulterated: Other — cannabis sourced from a third-party cultivatorExplicitly stated: downstream purchaser

Sources

This is regulatory journalism, not legal advice — talk to your counsel.