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The CSQ Certification Program and applicable standards were built around ISO/IEC 17067
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1 CCR 212-3 Rule 3-335 · Marijuana Products Manufacturers

Colorado GMP for Cannabis 

Every regulated marijuana business must meet Colorado's General Sanitary Requirements (Rule 3-310), and products manufacturers must meet the Specific Health and Safety Requirements of Rule 3-335 — complying with local kitchen-related health-and-safety standards and Colorado's own retail-food establishment regulations (6 CCR 1010-2). Colorado verifies this by MED licensing and inspection and requires no third-party GMP certificate and names no private standard.

 

Colorado's Cannabis GMP Rules and Why CSQ Certification Is Worth It

Colorado legalized medical marijuana in 2000 and adult-use in 2012, and its stores made the first legal adult-use retail sales in the United States on January 1, 2014. The Marijuana Enforcement Division (MED), within the Department of Revenue, regulates the whole market under the Colorado Marijuana Rules (1 CCR 212-3). For products manufacturers, Colorado makes food-safety GMP practices mandatory, general sanitary requirements, a health-and-safety rule that folds in Colorado's own retail-food code, and mandatory state lab testing but it requires no third-party GMP certificate and names no private standard (with one narrow exception for specialty non-oral products). CSQ is an accredited, independent way to prove the food-safety GMP practices Colorado's rules already require. This page explains what Colorado actually requires, which CSQ standard fits your license, and where certification with Kiwa ASI adds value.
Colorado Marijuana · C.R.S. Title 44, Art. 10 · MED (1 CCR 212-3)

START HERE

Does Colorado Require Cannabis Operators to Be GMP Certified?

No — for ordinary edible and concentrate makers Colorado requires no accredited third-party GMP certificate. But GMP-style practices are mandatory: general sanitary requirements, a health-and-safety rule that pulls in Colorado's own retail-food code, and mandatory state lab testing. (One narrow exception carries a third-party-audit duty for specialty non-oral products.) Here is the short version, and why CSQ still matters.

WHO REGULATES WHAT

One regulator: the MED

The Marijuana Enforcement Division, within the Colorado Department of Revenue, licenses and regulates the entire market — cultivation, manufacturing, stores, and testing, medical and retail — under 1 CCR 212-3. (The statutory State Licensing Authority is the Department of Revenue's executive director; the MED administers on its behalf.) Edibles also answer to Colorado's own retail-food code (6 CCR 1010-2).

THE REQUIREMENT

GMP practices + state testing, not a certificate

Products manufacturers must meet Colorado's general sanitary rule (3-310) and health-and-safety rule (3-335), comply with Colorado's retail-food regulations (6 CCR 1010-2), and pass mandatory state lab testing. No accredited third-party GMP certificate is required for ordinary makers, and Colorado names no private GMP standard.

WHERE CSQ FITS

Voluntary — accredited proof of what CO expects

CSQ is an accredited (ISO/IEC 17065) cannabis-specific GMP certification. Colorado doesn't require it, but it gives independent, audit-ready proof of the food-safety GMP practices Colorado's rules already require — valuable for MED inspection readiness, diligence, and multi-state operators.

What Colorado actually requires

Colorado runs an adult-use program under Amendment 64 (2012; first U.S. adult-use retail sales January 1, 2014) and a medical program under Amendment 20 (2000). Both are regulated by the Marijuana Enforcement Division (MED), a division of the Colorado Department of Revenue, under the Colorado Marijuana Code (C.R.S. Title 44, Article 10) and the Colorado Marijuana Rules (1 CCR 212-3). The statutory State Licensing Authority is the Department of Revenue's executive director; the MED administers on its behalf. Operators need both a state and a local license.

For marijuana products manufacturers — the makers of edibles, concentrates, tinctures, and infused products — food-safety GMP practices are the law. Every regulated marijuana business must meet the General Sanitary Requirements of Rule 3-310, and products manufacturers must meet the Specific Health and Safety Requirements of Rule 3-335, which requires that edible-manufacturing areas comply with local kitchen-related health-and-safety standards and Colorado's own retail-food establishment regulations (6 CCR 1010-2). Every product is tested by a MED-licensed, ISO/IEC 17025-accredited testing facility before sale. What Colorado does not do is require an accredited third-party GMP certificate for ordinary edible and concentrate makers — its rules never use the phrase “Good Manufacturing Practices,” name no private standard (no SQF, BRCGS, FSSC, ISO, or CSQ), and do not tie edible manufacturing to 21 CFR Part 111 or 117; GMP is verified by MED licensing and inspection against Colorado's own rules. So in Colorado CSQ is voluntary: accredited, independent proof of the food-safety GMP practices Colorado's rules already require. (One narrow exception: an “Audited Product” intended for metered-dose nasal spray, vaginal, or rectal administration may not be transferred without a written independent audit by a certified quality or GMP auditor, completed within 24 months — Rules 6-325 and 5-325.)

FIND YOUR PATH

Match Your Colorado License to the Right CSQ Standard

CSQ is voluntary in Colorado, so this is about which scope fits if you pursue certification. Match your license to the CSQ standard that fits; operators who hold more than one license can combine scopes into one coordinated audit with Kiwa ASI.

Cultivation Facility

C.R.S. §44-10-602 · MED

STANDARD

CSQ Cultivation v2.0.0

MINIMUM LEVEL

Level 1

PREP TIME

6–9 months

AUDIT LENGTH

~1 day onsite + 1 day offsite doc review (initial)

Retail or medical cultivation licensed by the MED. Foundation: cGACP (good agricultural and collection practices) plus cGMP, with Colorado's general sanitary requirements (Rule 3-310) and mandatory contaminant and potency testing.

Products Manufacturer

C.R.S. §44-10-603 · 1 CCR 212-3 Rule 3-335

STANDARD

CSQ Extraction / Manufacturing v2.0.0

MINIMUM LEVEL

Level 1

PREP TIME

6–9 months

AUDIT LENGTH

~1 day onsite + 1 day offsite doc review (initial)

The maker of edibles, concentrates, tinctures, and infused products — one license covers extraction and infusion, since Colorado has no separate extraction license. This is where Colorado's health-and-safety rule (3-335), the retail-food overlay (6 CCR 1010-2), and the Universal Symbol / per-serving rules bite hardest, and where CSQ maps most directly. CSQ items to watch: beverage-grade CO₂ (99.5%), food-grade non-denatured ethanol, allergen controls, and the per-serving Universal Symbol stamp.

Marijuana Store

C.R.S. §44-10-601 · MED

STANDARD

CSQ Retail v1.0.0

MINIMUM LEVEL

Level 1

PREP TIME

4–6 months

AUDIT LENGTH

~1 day onsite + 1 day offsite doc review (initial)

Retail or medical stores licensed by the MED. Built on cGHP (good handling practices) — storage, handling, inventory, seed-to-sale tracking (Rule 3-805), and the written recall plan every regulated marijuana business must keep (Rule 3-336).

Testing Facility

1 CCR 212-3 Rule 6-415 · MED-licensed

STANDARD

ISO/IEC 17025

MINIMUM LEVEL

N/A

PREP TIME

Varies

AUDIT LENGTH

Per accreditation body

Colorado requires marijuana testing to be run by a MED-licensed Regulated Marijuana Testing Facility accredited to ISO/IEC 17025 (Rule 6-415). CSQ does not certify testing labs; it requires them to be ISO/IEC 17025 accredited.

COLORADO REQUIRES VS. CSQ GOES FURTHER

What's a State Rule, and What's a CSQ Best Practice?

Colorado's regulations are the legal floor, enforced by MED licensing and inspection and mandatory state lab testing. CSQ is a voluntary published standard that documents GMP beyond that floor — and gives independent proof of the food-safety GMP practices Colorado's rules already require. Knowing which is which keeps you from over-buying or under-preparing.

What Colorado requires (the legal floor)

  • Both a state and a local license — Colorado Marijuana Code, C.R.S. Title 44, Article 10; Colorado Marijuana Rules, 1 CCR 212-3
  • General sanitary requirements for every regulated marijuana business — 1 CCR 212-3 Rule 3-310
  • Health-and-safety requirements for products manufacturers, including local kitchen standards and Colorado's retail-food establishment regulations (6 CCR 1010-2) — Rule 3-335
  • The Universal Symbol on packaging and stamped on each standardized serving of a multi-serving edible — Rules 3-1010 and 3-335(D)(4); serving limits of 10 mg active THC per serving and 100 mg per retail edible unit
  • Mandatory testing by a MED-licensed, ISO/IEC 17025-accredited testing facility — Rule 6-415; contaminant and potency testing (Rules 4-120, 4-125)
  • A written recall plan for every regulated marijuana business, with 48-hour Division notification — Rule 3-336
  • Seed-to-sale inventory tracking in the state's inventory-tracking system — Rule 3-805
  • No accredited third-party GMP certificate for ordinary edible and concentrate makers, and no private GMP standard named — one narrow exception: a third-party audit for non-oral “Audited Products” (Rules 6-325 / 5-325)

What CSQ adds (voluntary best practice)

  • An accredited (ISO/IEC 17065) cannabis GMP certification — independent, audit-ready proof beyond MED inspection
  • Built to meet the sanitary and health-and-safety practices Colorado's rules require of products manufacturers (Rules 3-310 and 3-335) and its retail-food overlay (6 CCR 1010-2)
  • A documented internal audit program (Section 1.5) and CAPA system (Section 1.6)
  • An annual mock recall (Section 1.8) and verified traceability test — supporting the written recall plan (Rule 3-336) and seed-to-sale tracking (Rule 3-805) Colorado requires
  • Cannabinoid and non-cannabinoid waste streams kept completely separated (Section 2A.4 / 2B.4)
  • Beverage-grade CO₂ (99.5%) for extraction — medical-grade is not acceptable
  • Inhalation-grade ingredients for inhalable products (food-grade/GRAS is not sufficient)
  • MED inspection readiness, investor/lender/M&A diligence, multi-state standardization, and retail/buyer assurance
  • A HACCP team and certified lead (Level 2 only — not a Colorado requirement)
  • What CSQ does not replace: the per-serving Universal Symbol stamp (Rule 3-335(D)(4)) and mandatory state lab testing remain the operator's duty

Quick glossary — the terms that show up in a Colorado CSQ audit

MED

The Marijuana Enforcement Division, within the Colorado Department of Revenue — licenses and regulates the entire medical and retail marijuana market under 1 CCR 212-3. (The statutory State Licensing Authority is the Department of Revenue's executive director; the MED administers on its behalf.)

Colorado Marijuana Code

C.R.S. Title 44, Article 10 — the consolidated statute (medical and retail merged in 2020) that authorizes the market and the MED's rules.

1 CCR 212-3

The Colorado Marijuana Rules — the consolidated MED rules (2020) that replaced the former medical (212-1) and retail (212-2) rules; the operative source for sanitary, labeling, testing, and recall requirements.

Marijuana Products Manufacturer

A MED-licensed business (C.R.S. §44-10-603 retail / §44-10-503 medical) that makes edibles, concentrates, tinctures, and infused products — the license where Colorado's food-safety GMP practices apply most directly. (Formerly the Marijuana-Infused Products, or MIP, manufacturer.)

Universal Symbol

The MED-published “THC” diamond mark — black on edibles and infused products, red on all other product types — that must appear on packaging (Rule 3-1010) and be stamped, molded, or imprinted on each standardized serving of a multi-serving edible (Rule 3-335(D)(4)) — a manufacturing and mold constraint a certificate does not discharge.

6 CCR 1010-2

Colorado's own Retail Food Establishment Regulations (Department of Public Health and Environment). Rule 3-335 folds these into marijuana edible manufacturing — Colorado's own food code, not 21 CFR.

ISO/IEC 17025

The competence standard for testing laboratories. Colorado requires marijuana testing facilities to be MED-licensed and ISO/IEC 17025 accredited (Rule 6-415). CSQ requires the labs it relies on to hold the same.

ISO/IEC 17065

The accreditation standard for bodies that certify products and processes. CSQ is delivered by ASI Food Safety as an ISO/IEC 17065-accredited certification body — the basis for an independent, accredited GMP certificate.
THE AUDIT

What a CSQ Audit Actually Looks Like

A Colorado CSQ audit is an onsite review of your quality management system against the standard that fits each activity you perform. Here is how scoring, findings, and timing work — followed by the technical mapping table for the people who want it.

Scoring (100-point scale)

How CSQ scores you and what it means for your certificate

Score Outcome Surveillance Cycle
80–100 Certificate issued Annual surveillance audit
70–79 Certificate issued 6-month surveillance audit
Below 70 No certificate 6-month wait before re-audit

Findings categories

CRITICAL · –100 POINTS

Auto-fail finding

Regulatory non-compliance, product safety risk, or foundational QMS breakdown. A single Critical finding fails the audit regardless of other scores.

MAJOR · –10 POINTS

Significant gap

Systemic failures or significant deviations from CSQ requirements — not an immediate safety risk but requires corrective action.

MINOR · –1 POINT

Isolated finding

Documentation gap, single-occurrence lapse, or correctable deviation that is not systemic.

Audit timing & certificate validity

What to expect onsite and on the calendar

Item Detail
Level 1 audit 1 day onsite + 0.5 day report time
Level 2 audit 1.5 days onsite + 1 day report time
Level 3 audit 2 days onsite + 1 day report time (unannounced window)
Initial audit add-on +1 day for offsite documentation evaluation (all levels)
Corrective action window 30 days to close nonconformities
Certificate validity 1 year + 45 days from audit date
Provisional certificate Available for new operations (valid 6 months)
Dietary Supplement Addendum 4-hour minimum · Pass/Fail · separate report within 72 hours

How to Prepare | A Realistic Path to CSQ Certification

Because CSQ is voluntary in Colorado, step one is deciding whether it earns its place for you. If it does, most operators need 4 to 9 months, depending on license type and scope, to be ready for an initial audit. Here is a sequence that works.
01
Decide whether CSQ is right for you
Colorado doesn't require it, so weigh the value: MED inspection readiness, investor / lender / M&A diligence, multi-state standardization, and retail or buyer assurance. Because Colorado already requires food-safety GMP practices for products manufacturers, CSQ mostly certifies what you are already doing. If those matter, CSQ is worth pursuing.
02
Confirm your CSQ standard and level
Match your license — cultivation facility, products manufacturer, store — to its CSQ standard, and decide whether Level 1 is enough or you want Level 2/3. Write the answer down; it drives every other step.
03
Run a gap analysis
Compare your current state to the CSQ standard, mapped against Colorado's rules (the general sanitary requirements of Rule 3-310, the health-and-safety requirements of Rule 3-335, and Colorado's retail-food establishment regulations at 6 CCR 1010-2). ASI Training and Consulting, LLC can deliver a structured gap analysis as a separate engagement from the certification body.
04
Build the QMS documentation
Extend the food-safety controls Colorado already requires — sanitation, personnel hygiene and training, and allergen controls — into a full CSQ quality management system with SOPs, CAPA, internal audit, document control, and recall/traceability (supporting the written recall plan Colorado requires under Rule 3-336 and seed-to-sale tracking under Rule 3-805).
05
Address the cannabis-specific Critical items
The findings most likely to fail a first audit: CO₂ purity, ethanol grade, inhalation-grade ingredients, waste-stream separation, and route-of-administration risk assessments. Confirm your edibles carry the Universal Symbol on each standardized serving of a multi-serving edible (Rule 3-335(D)(4)) before the auditor arrives.
06
Train your team and run internal audits
Deliver competency-based, role-specific training on GMP, hygiene, PPE, allergen handling, and traceability. Then conduct a documented internal audit and an annual mock recall, and close nonconformities through CAPA.
07
Schedule your CSQ audit with Kiwa ASI
Schedule through Kiwa ASI in the CSQ Database. Allow time for the offsite documentation evaluation (1 day) plus the onsite audit (1–2 days depending on level). Request a quote to start.

Why Colorado Operators Choose Kiwa ASI

Kiwa ASI brings nearly a century of food safety expertise and the global Kiwa network's footprint in 30+ countries to Colorado — the first U.S. adult-use market, with more than $18 billion in regulated marijuana sales since 2014 and a mature, MED-regulated manufacturing base.
Accredited

ISO/IEC 17065 + CSQ-Licensed

Audits and certificates are issued by ASI Food Safety, LLC — an ISO/IEC 17065-accredited certification body licensed by CSQ.

Expertise

Food-grade rigor for cannabis

Our auditors are credentialed food safety, GMP, and HACCP professionals with cannabis-specific qualifications. Cannabis is being regulated like food. We've been doing food for decades.

Efficiency

Direct scheduling, no surprises

Pre-audit scoping clarifies level, scope, and Module 3 requirements before you're onsite. Audit reports are turned around inside the standard CSQ timeline.

Comprehensive

Training and consulting available

Pre-assessments and gap analyses are delivered by ASI Training and Consulting, LLC, a separate legal entity, kept structurally separate from the certification body to safeguard impartiality under ISO/IEC 17065.

Continuity

Surveillance, recertification, transfer

If you're already CSQ-certified through another body and the relationship isn't working, we accept transfer audits. Continuity matters as much as the initial certificate.

Frequently Asked Questions About Colorado Cannabis GMP & CSQ Certification