Colorado OPC License Holders Can Make Bubble Hash

In Colorado, select cannabis ventures can have an Optional Premises Cultivation (OPC) license. An OPC license allows a medical cultivation business to grow its own medical cannabis crops. The state doesn’t allow OPCs to operate independently. Rather, an OPC facility must have an affiliation with a cannabis center or a producer of infused cannabis products. 

The state recently made a series of changes to provisions to its licensing regulations. Much of the modifications focused on relocating, replacing and adding equipment to processes, or relocating machines in its approved blueprint. For OPC holders, a key change came when it was ruled that OPC facilities could now produce bubble hash without filing an additional application. 

With the market rapidly warming to solventless products, now is the time for your venture to add a 100% solventless cannabis option to your product offering. Products like ice water hash are now easier to create than ever. When coupled with other solventless products, your business stands to grow in revenue and product reputation. 

In this article, we’ll delve into some of the recent regulatory changes OPC license holders should be aware of. And if you haven’t already made the splash into the sector, we’ll offer up some reasons why it’s time to consider taking that plunge sooner than later.

Key OPC Regulations to Be Aware Of

Under the revised regulations, OPC licenses need to be aware of several key parameters, both new and old in its legislation. 

Licensed cannabis cultivation facilities in Colorado are allowed to cultivate their own retail marijuana and can transfer retail product, as well as, water-based concentrates to research facilities or pesticide manufacturers. Storage of product is also allowed on-site, as long as the product is stored in a Limited Access Area while the company maintains consistent inventory tracking, per state rules. 

When it comes to concentrate production, OPC holders can produce water-based concentrates in an area of the facility that is clearly designated for its production. Additional extraction methods can't be performed in the same space. Furthermore, an OPC license does not grant a company to produce additional extracts, like rosin, where additional licenses are required. 

The Production Process

The state categorizes retail marijuana facility production under one of three types: 

  1. Water-Based Retail Marijuana Concentrate
  2. Food-Based Retail Marijuana Concentrate 
  3. Heat/Pressure Based Retail Marijuana Concentrate

Water-based product production requires its own set of criteria to meet state standards: 

  1. Equipment must be food-grade   
  2. Equipment is thoroughly cleaned after each production batch    
  3. Dry ice must be stored in a well ventilated room to prevent CO2 accumulation   
  4. Ensure all safety and sanitary equipment is provided to staff    
  5. Ensure that only drinking water and ice sourced from it are used in the process   
  6. If propylene glycol or glycerin is used, ensure it is food-grade      


The state allows producers a certain threshold of contaminants in its products when being tested. Water-based extracts are subject to testing of microbials like bacteria and fungus. Bacteria like salmonella and shiga-toxin producing escherichia coli (STEC) are tested for more than on colony forming unit in a sample. Yeast and mold are also analyzed, where a 104 colony forming unit is the threshold.

Metals like arsenic, cadmium, lead and mercury are also tested. Maximum limits vary, with lead allowed up to 1 parts per million (ppm), while arsenic and cadmium are set at .4 ppm. Mercury is at .2 ppm. 

If a product reaches market without being tested, it will be labeled with the statement: “The Retail Marijuana Concentrate contained within this package has not been tested for contaminants.” Companies can avoid the labeling and testing by having a facility that has had its facility validated as compliant. In that case, product will be labeled with the statement: “The Retail Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule R 1501.”

Product Labeling

Testing remains a top priority across all cannabis products, including solventless. Labeling is a key indicator for consumers that a product is tested an approved. As such, a label like so and is clearly marked on packages in Colorado. If a solventless brand did not test a batch of products, it must carry the a label stating "“The Retail Marijuana Concentrate contained within this package has not been tested for contaminants," though some exceptions apply. 

Meanwhile, a solventless brand that does test the batch will have a label reading “The Retail Marijuana Concentrate contained within this package complies with the mandatory contaminant testing required by rule R 1501.’

Other parameters extend to transferring products to retail locations. For concentrates, its label must contain a series of information, including license numbers for the flower’s cultivation facility and the license number for where the concentrate was produced.  Packaging is of the utmost concern as well. Various rules apply to liquid edibles versus those in solid form. The same goes for edibles in single-serve functions over a bundled package. 

Products must also contain specific labeling when concerning key areas of consumption. Take edibles for example, where labels must list information pertaining to the product's potency and come with the onset time warning “The intoxicating effects of this product may be delayed by up to 4 hours.”

Colorado OPCs Should Have Ice Water Hash Production

All Colorado OPCs should do themselves a favor and get into ice water hash production. The overhead is significantly lower than solvent-based extraction, while allowing your brand to establish itself as premier producer in the burgeoning space. Speaking of low overhead, our entire Bruteless™ Hash washers and accessories will set your company back just a fraction of what it would cost to get any other sophisticated operation up and running. 

In addition to an OPC license, be sure to consider a manufacturing infused products (MIP) license so you can press rosin as well. With both in your company’s arsenal, your business has the ability to produce an array of versatile, top-of-the-line cannabis concentrates that should fuel your company to profitability.