GMP
Kiwa ASI cGMP V2.0 Training
One day on current Good Manufacturing Practices for the people who run your floor every day.
Upcoming dates$499 per seat
Dates on request. Ask about upcoming dates
Michigan’s Cannabis GMP Rules: What They Require and What CSQ Proves
Michigan does not require any cannabis business to hold a third-party GMP certificate. But GMP is not optional for everyone: edible producers must comply with FDA human-food GMP, 21 CFR part 117, by rule, and Michigan’s rules expressly permit producers to become GMP certified, and cultivators GACP-GMP certified, by a body accredited under ISO 17065 (R 420.305(4) and (5)). Kiwa ASI audits and certifies cannabis and hemp operations to CSQ, turning the program Michigan already expects you to run into independent, documented proof.
- CSQ Certification Body
- R 420.305(4) Voluntary GMP
- 21 CFR part 117 for Edibles
- Cannabis & Hemp
Last updated October 28, 2026
Get a Michigan CSQ Audit Quote
Tell us your license type and what you grow or make. We’ll confirm your CSQ standard and level, quote the audit, and tell you the earliest dates we can offer. Certification is voluntary in Michigan, so the calendar is yours.
Does Michigan Require GMP Certification?
No. Nothing in Michigan’s statutes or rules requires a third-party GMP, QMS or CSQ certificate of any licensee. What the rules do instead is more interesting: they set real GMP duties for parts of the industry, and they expressly permit voluntary certification for producers and cultivators. Here is the short version.
The testing-allowances asterisk
R 420.305(4) and (5) each add that this accreditation “may enable the licensee certain allowances with testing” and that the agency will publish those allowances. As of October 2026 the Cannabis Regulatory Agency (CRA) has not published them, and no list of recognized certification bodies exists. The CRA floated incentive-program details in a 2023 feedback request, including reduced testing frequency for GMP-certified product batches, but today there is no allowance to claim. Certify for the proof, not for a testing break; if the program arrives, certified operators are the ones positioned for it.
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Voluntary
What Is Voluntary
Third-party certification. R 420.305(4) says “all marihuana producers may become certified to GMP by a body accredited under ISO 17065,” and R 420.305(5) opens the same door to GACP-GMP certification for cultivators. Permission, not mandate: no audit, no level and no certificate is required of anyone.
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Mandatory
What Is Already Mandatory
GMP practices for edible producers. R 420.403(8) requires compliance with FDA human-food GMP, 21 CFR part 117, plus formulation records, annual food-safety training, and a certified Food Protection Manager on site during production. Every business also owes written SOPs kept on site (R 420.206a), product that has passed batch testing at accredited labs before sale, and labeling, packaging and recall duties.
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The gap
Who Checks
For the mandatory practices, the CRA, through inspections and enforcement. For the quality system behind them, nobody, unless you choose independent proof. A voluntary CSQ audit is how Michigan operators put independent verification behind self-compliance; certified sites are listed on CSQ’s public registry.
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Audience
Who This Page Is For
Growers (Class A, B and C), processors, microbusinesses, retailers and provisioning centers, under both the adult-use and medical programs. The rules treat a processor under either act as a producer (R 420.401(1)(l)), so the same GMP logic applies across both markets.
R 420.305(4) and (5), Decoded
Michigan’s voluntary pathway is two short subrules of rule text, quoted here in full from the current Marihuana Rules:
“(4) All marihuana producers may become certified to GMP by a body accredited under ISO 17065. This accreditation may enable the licensee certain allowances with testing. The agency will publish those allowances and information on how to obtain approval for allowances. The standard used for certification for GMP must be American National Standards Institute (ANSI) accredited or equivalent.”
“(5) All marihuana cultivators may become certified to GACP-GMP by a body accredited under ISO 17065. This accreditation may enable the licensee certain allowances with testing. The agency will publish these allowances and information on how to obtain approval for allowances. The standard used for certification for GACP-GMP must be World Health Organization and American Herbal Products Association or equivalent.”
Four readings decide what this means for you.
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Reading 1
It Is Permission, Not a Mandate
“May become certified” is the whole obligation: there is none. Michigan wrote a voluntary pathway into its own rules, which is rarer than it sounds; most states say nothing about third-party GMP certification at all.
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Reading 2
The Named Accreditation Belongs to the Body
The rule speaks about who certifies you: “a body accredited under ISO 17065.” ASI Food Safety, LLC, the certification body behind Kiwa ASI and CSQ’s licensed certification body, holds ISO/IEC 17065 accreditation.
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Reading 3
The Standard Clause Is Separate
Each subrule adds a second test about the standard itself: ANSI accredited or equivalent for GMP, and WHO and AHPA or equivalent for GACP-GMP. Those clauses are the CRA’s to interpret, and no published guidance resolves them. Ask our certification team where CSQ stands on standard recognition before you rely on this clause for anything.
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Reading 4
The Testing Benefit Is Conditional
The rule says the accreditation “may enable” testing allowances, and its own test battery in R 420.305(3) applies “except as provided in subrule (4).” But the allowances the agency said it will publish have not been published as of October 2026, so today the rule gives you no testing break to claim. Treat any future allowance as upside, not as the business case.
Where the rules stand. These are the rules in force since March 2022. As of October 2026, a comprehensive CRA rules overhaul is pending but has not been filed; the current rules govern, and most of a filed overhaul would take effect 180 days after filing. A second current-rule hook sits in R 420.206(2): a cultivator holding good agricultural collection processes certification may sell immature plants to a marijuana sales location under allowances published by the agency, which are likewise unpublished today. Certification to CSQ is voluntary in Michigan, the standard-recognition clauses above are the CRA’s to interpret, and any testing allowance depends on what the agency publishes: confirm allowances with the CRA before relying on them.
For Edible Producers, GMP Is Already the Law
If you make edible marijuana products in Michigan, GMP is not a certification question, it is a compliance fact: R 420.403(8) requires compliance with 21 CFR part 117, FDA’s current good manufacturing practice and preventive-controls rule for human food. What Michigan does not require is anyone checking your system between inspections. A voluntary CSQ audit turns the GMP program you already owe into independently verified proof.
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The rule
The Part 117 Duty
Michigan’s rule is direct: “a producer of edible marihuana product” shall comply with 21 CFR part 117, including current good manufacturing practice and hazard analysis with risk-based preventive controls, with potentially hazardous ingredients stored at 40 degrees Fahrenheit or below (R 420.403(8)(a)). Michigan also offers an alternative route: ISO 22000 with ISO/TS 22002-1, adopted by reference (R 420.403(8)(e)(ii)). Either way, the duty is yours today, certificate or not.
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People
The People Requirements
A certified Food Protection Manager on site during the production of edible products (R 420.403(8)(d)), and at least two hours of annual food-safety training for employees covering allergens, sanitation and the rule’s other listed subjects (R 420.403(8)(c)). CSQ’s personnel sections ask for the same discipline, documented.
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Records
The Records and Packaging Duties
Formulation, recipe and shelf-stability records (R 420.403(8)(b) and (11)), allergen labeling under the federal Food Allergen Labeling and Consumer Protection Act (FALCPA) (R 420.403(7)(d)), opaque, child-resistant packaging per 16 CFR 1700.15 (R 420.403(10)), and THC limits published by the agency, with a 10 percent sale tolerance set by R 420.404. These are the exact disciplines a GMP audit samples.
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The stakes
Why Proof Beats Self-Compliance
Michigan’s regulator stayed busy in 2026: a September recall pulled 786 concentrate units statewide over a prohibited chemical, an August recall covered infused beverages that may have exceeded THC limits, and in September the CRA announced a 2 million dollar fine with license revocations. Recalls like these are the kind of process failure a GMP system is built to catch. A current CSQ certificate is standing evidence your system runs, before anyone asks.
About CSQ and part 117. CSQ standards were developed on the basis of FDA food and supplement regulations, 21 CFR Parts 111, 112, 117 and 120, along with ASTM standards, ISO standards, AHPA guidance and a HACCP module based on Codex Alimentarius. Michigan’s edible rule points to 21 CFR part 117, one of the regulations CSQ’s standards were built from. A CSQ audit independently verifies the GMP program you already run; it does not certify compliance with part 117 or with Michigan’s rules, and no certification substitutes for the state’s own inspections.
Match Your Michigan License to the Right CSQ Standard
CSQ publishes separate standards for cultivation, extraction, manufacturing, retail, and warehousing and distribution, so most Michigan license types map cleanly onto one or two scopes. Michigan names no level and no standard; the readiness checklist below shows what each level covers. If you hold more than one license, co-located scopes can be audited in the same visit, with each facility scoped individually; ask us to map yours.
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Adult-use & medical
Growers (Class A, B and C)
Growing, harvesting, drying, curing and trimming, from 100-plant Class A to stacked Class C licenses (adult-use caps 100, 500 and 2,000 plants, MCL 333.27959(2)). CSQ Cultivation is a cGACP and cGMP certification program developed on the basis of AHPA’s good agricultural and collection practices and good manufacturing practices for botanical materials, along with ASTM standards, ISO standards and a HACCP module based on Codex Alimentarius. R 420.305(5) is the rule that names the cultivator pathway; whether any standard meets its recognition clause is the CRA’s call, not ours.
- Standard: CSQ Cultivation, Version 2.0
- Level: Level 1 or higher; Level 2 and above add HACCP
- Minimum initial audit: 1-day offsite document evaluation plus 1 day onsite at Level 1
- No certificate mandated: certification is voluntary, independent proof
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Extraction · infused products
Processors
Extraction, infusion, edibles, beverages, vapes and topicals. Extraction maps to CSQ Extraction and finished products to CSQ Manufacturing; many Michigan processors hold both, and co-located scopes can be audited in the same visit, with each facility scoped individually. The rules treat a processor under the medical and adult-use acts alike as a producer (R 420.401(1)(l)), the exact word R 420.305(4) uses for the voluntary GMP pathway. If you make edibles, the part 117 duties above are already yours.
- Standard: CSQ Extraction and/or CSQ Manufacturing, Version 2.0
- Level: Level 1 or higher; Level 2 and above add HACCP
- Minimum initial audit: 1-day offsite document evaluation plus 1 day onsite at Level 1, 1.5 days at Level 2
- No certificate mandated: certification is voluntary, independent proof
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Adult-use & medical
Retailers and Provisioning Centers
Retail storage, handling and sale, in either market. CSQ Retail is built on current good handling practices: inventory, storage, customer-facing controls and staff training. Note that R 420.305(4) and (5) speak to producers and cultivators; for retail the case is buyer assurance and process discipline, not a rule hook.
- Standard: CSQ Retail, Version 1.0
- Level: Level 1 or higher
- Minimum initial audit: 1-day offsite document evaluation plus 1 day onsite at Level 1
- No certificate mandated: certification is voluntary, independent proof
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Vertically integrated
Microbusinesses
A microbusiness grows, processes and sells under one roof (up to 150 mature plants); a Class A microbusiness grows up to 300 mature plants (R 420.105a) and buys its concentrates and infused products from licensed processors instead of processing its own. Cover every activity you perform by combining the CSQ standards that match, audited in the same visit where the scopes are co-located, with each facility scoped individually.
- Standard: CSQ Cultivation, Extraction, Manufacturing and/or Retail, to match your activities
- Level: Level 1 or higher; Level 2 and above add HACCP
- Minimum initial audit: 1-day offsite document evaluation plus 1 day onsite at Level 1
- No certificate mandated: certification is voluntary, independent proof
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ISO/IEC 17025
Safety Compliance Facilities (Labs)
Labs follow their own lane: Michigan requires its licensed testing laboratories to be accredited to ISO/IEC 17025:2017 by an ILAC-recognized accreditation body (or an entity the agency approves) within one year of licensure (R 420.305(1)), with quality programs conforming to good laboratory practice standards (R 420.305b). That is a state requirement, not a CSQ scope: CSQ publishes no laboratory standard, and Kiwa ASI does not provide laboratory testing.
- Standard: ISO/IEC 17025:2017 accreditation, required by Michigan
- CSQ publishes no laboratory standard
Secure transporters and warehousing. Michigan licenses secure transporters separately; CSQ’s Warehousing & Distribution standard, Version 1.0, covers storage and distribution operations, and your own standard’s storage and distribution sections (2A.9 in the producer standards, 2B.8 in Retail) cover the storage, shipping and receiving that happen inside a grower, processor or retail license. Ask us which configuration fits how your product actually moves.
What Michigan Requires vs. What CSQ Adds
Michigan’s rules are the legal floor. CSQ is a published, cannabis-specific standard that adds verified best practice the rules don’t spell out. Knowing which is which keeps you from over-buying or under-preparing.
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The legal floor
What Michigan Requires
- Up-to-date written SOPs kept on site and available to the agency, and the agency can require immediate correction and an SOP update within 1 business day when it finds a gap (R 420.206a)
- For edible producers: 21 CFR part 117 compliance, formulation and shelf-stability records, annual food-safety training, and a certified Food Protection Manager on site (R 420.403(8) and (11))
- Batch testing of potency, foreign matter, microbials, chemical residues, heavy metals, residual solvents and water activity through licensed labs (R 420.305(3))
- Labs accredited to ISO/IEC 17025:2017 by an ILAC-recognized body (R 420.305(1))
- Opaque, child-resistant packaging per 16 CFR 1700.15 (R 420.403(10)) and allergen labeling under FALCPA (R 420.403(7)(d))
- Retail labels with THC and CBD content, the universal symbol, lab name and test date, and required warnings (R 420.504(1))
- THC caps published by the agency (10 mg per serving and 200 mg per package for adult-use infused edibles, per the CRA technical bulletin revised April 24, 2025), with a 10 percent sale tolerance (R 420.404)
- Compliance with agency holds, recalls and safety warnings (R 420.502(2)), immediate pull of recalled product (R 420.403(4)), and 24-hour notification of theft, loss or criminal activity (R 420.804(1))
- Statewide monitoring system tracking from seed to sale
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Verified best practice
What CSQ Adds
- An annual certification audit, plus an unannounced audit at least every three years at every level
- A documented internal audit program (CSQ 1.5) and corrective and preventive action with annual trending (1.6)
- A written recall plan and a mock recall at least once a year, completed in under two hours (1.8): Michigan’s rules impose recall duties but require no recall plan or drill
- A risk-based environmental monitoring program for microbial hazards (2A.8)
- Annual ISO/IEC 17025 testing of facility air and water (2A.6, 2A.7)
- Process gases and extraction solvents of at least 99.5 percent purity unless otherwise specified, CO₂ of beverage grade or better (never medical grade), and non-denatured, food-grade ingredient ethanol (3B.1.5, 3B.1.6, 3C.1.3, 3C.1.4)
- Inhalation-grade ingredients for inhalable products, where food-grade or GRAS alone is not sufficient, plus route-of-administration risk assessments (3C.2)
- Cannabinoid and non-cannabinoid waste streams kept separate (2A.4.1, 2A.4.2) and contract manufacturers audited (2A.11)
- Supplier approval and vendor qualification (2A.11), with a certificate of analysis or conformance received for incoming materials and supplies (2A.10.2)
- Notice to your certification body within 72 hours of a recall, voluntary withdrawal or regulatory warning
- At Level 2 and above, a HACCP system built on the twelve Codex steps, with one team member and a back-up certified through a course approved by the International HACCP Alliance (4A.1, 4A.2)
What a CSQ Audit Looks Like in Michigan
An initial CSQ audit has three parts: a one-day offsite evaluation of your documentation (no more than six months before the site visit), the onsite audit, and the report. Minimum onsite time is 1 day at Level 1, 1.5 days at Level 2 and 2 days at Level 3, plus report time; Level 3 onsite audits are unannounced. Your actual time depends on the standards in scope and the size of your site. The auditor checks your written system against CSQ and Michigan’s rules (CSQ 1.3, Regulatory Compliance), watches your people work, and samples your records.
CSQ Audit Modules
| Module | What the auditor checks |
|---|---|
| 1 Management system (all levels) | Documented CSQ system with SOPs and a copy of Michigan’s rules, management commitment, regulatory compliance, records, internal audits, CAPA, complaints, recalls and withdrawals, product defense, fraud prevention and crisis management |
| 2A Good manufacturing practices (cultivation, extraction, manufacturing, deli-style) | Facility and infrastructure, equipment and calibration, cleaning and sanitation, waste, integrated pest management, air and water safety, environmental monitoring, storage, inventory and traceability, supplier approval, production and process controls, labeling and packaging, product testing, personnel |
| 2B Good handling practices (CSQ Retail, Version 1.0) | The retail twin of Module 2A: facility, sanitation, storage and temperature control, inventory management, product handling controls, labeling, sampling and personnel, built for dispensary-style operations |
| 3A / 3B / 3C / 3D / 3E Products and processes (all levels) | Cultivation (3A): water, fertigation, crop maintenance, harvest. Extraction (3B): process gases and solvents, extraction equipment, post-processing. Manufacturing (3C): ingredients, formulation, inhalable, ingestible and topical product controls, homogeneity and dosing. Deli-style retail (3D): herbal-material handling and pre-roll production. Retail (3E): cannabinoid materials and products handled at the store |
| 4A / 4B HACCP (Level 2 and above) | Hazard analysis, critical control points, monitoring, corrective actions, validation and verification. Module 4A (producers and deli-style) also requires a HACCP team with one member and a back-up certified through an IHA-approved course; plain Retail is audited to the basic HACCP module 4B |
| 5 Advanced quality management (Level 3) | Advanced management system requirements, safety and quality culture, customer satisfaction and product realization; Level 3 onsite audits are unannounced |
| Mock recall and traceability | Your annual mock recall record, plus a traceability exercise during the audit |
How CSQ Audits Are Scored
Each audit starts at 100, and every nonconformance deducts points. The final score decides the outcome:
| Result | Score | What happens next |
|---|---|---|
| Certified | 80–100 | Certificate; next annual certification audit in a year |
| Certified with surveillance | 70–79 | Certificate plus a surveillance audit in six months; a score of 79 or below on that audit suspends the certificate |
| Not certified | 0–69 | No certificate; wait six months before reapplying |
Certificates are valid for one year plus 45 days and are listed on CSQ’s public registry, where your wholesale buyers, inspectors and anyone else can look them up.
Nonconformance Categories
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Critical−100
A requirement that has not been implemented and is a significant risk to product safety and quality. A critical finding fails the audit.
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Major−10
A deficiency in meeting a CSQ requirement that, if not addressed, will likely lead to a risk to product safety and quality.
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Minor−1
A deficiency in meeting a CSQ requirement that, if not addressed, may lead to a risk to product safety or quality.
After the audit: corrective actions must be approved and closed within 30 calendar days of the closing meeting, and the final report and certificate follow within about 45 days. Every certified site also gets an unannounced audit at least once every three years. Agree blackout dates with us for days your operation won’t be running, and submit them no later than 60 days before the unannounced audit window; refusing an unannounced audit suspends the certificate.
Michigan GMP Audit Readiness Checklist
The CRA checks compliance through inspections and the statewide monitoring system, and a CSQ audit samples the same disciplines. Use this list to check you’re ready before the auditor arrives.
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Documents
Paperwork to Have Ready
- Your Michigan license and a copy of the rules you follow
- Your CSQ-based quality manual and the SOPs R 420.206a already requires, covering sanitation, process flow, product release, recalls and complaints
- Supplier approval file, including certificates of analysis for CO₂, solvents, ethanol and ingredients
- An organization chart and job descriptions, with training records, and for edible producers the Food Protection Manager certificate and annual training log (R 420.403(8)(c) and (d))
- Formulation, recipe and shelf-stability records for edible products (R 420.403(8)(b) and (11))
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Records (CSQ recommends about 60 days)
Records You Need Running
- Batch and production records with quality-control review and release
- Cleaning and sanitation logs, pest control reports and equipment calibration records
- Environmental monitoring results and annual air and water test reports
- Lot testing certificates of analysis from your ISO/IEC 17025-accredited Michigan lab
- Statewide monitoring system reconciliations that tie inputs to finished lots, plus your mock recall record
- An internal audit report and a CAPA log showing findings closed
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CSQ specifics
Cannabis-Specific Items Auditors Check Closely
- Process-gas and CO₂ grade, and food-grade, non-denatured ingredient ethanol
- Inhalation-grade ingredients and route-of-administration risk assessments for formulated, inhalable and topical products
- Potency, homogeneity and dosing controls for infused products, against the CRA’s published THC limits
- Cannabinoid waste kept separate from non-cannabinoid waste
- Labels checked against R 420.504(1) before release: THC and CBD content, universal symbol, lab name and test date, and warnings, plus child-resistant packaging (R 420.403(10))
| Michigan requirement | Citation | CSQ sections |
|---|---|---|
| Licensing and regulatory compliance | MRTMA / MMFLA; R 420 rules | Module 1 (CSQMS) + 1.3 Regulatory Compliance |
| Written SOPs on site | R 420.206a | 1.4 Documentation and Recordkeeping + 2A.12.1 Standard Operating Procedures |
| Edible-producer GMP (21 CFR part 117; Michigan alternative: ISO 22000/ISO/TS 22002-1) | R 420.403(8)(a), (8)(e) | Module 2A (cGMP) + 3C.2.6 Ingestible Cannabinoid Products + Module 4A HACCP (Level 2 and above) |
| Formulation records, annual training, Food Protection Manager | R 420.403(8)(b)–(d) | 2A.13 Personnel Requirements (2A.13.2 Personnel Training) + 1.4 Documentation and Recordkeeping |
| Voluntary GMP / GACP-GMP certification pathway | R 420.305(4)–(5) | The certification itself: the whole standard, audited annually |
| Mandatory batch testing; accredited labs | R 420.305(1), (3) | 2A.12.9 Product Sampling and Testing |
| Packaging, labeling, allergens, THC limits | R 420.403(10), (7)(d); R 420.504; R 420.404 | 2A.12.8 Product Labeling and Packaging |
| Recall and administrative-hold compliance | R 420.502(2); R 420.403(4) | 1.8 Product Recalls and Withdrawals + 1.6 Corrective Actions and Preventive Actions (CAPA) |
| Waste management | R 420.211 | 2A.4 Waste Management (2A.4.1 Cannabinoid Waste; 2A.4.2 Non-Cannabinoid Waste) |
| Retail handling, storage, inventory and labeling (CSQ Retail, Version 1.0) | R 420.504; R 420.502(2) | 2B.8 Storage and Distribution + 2B.9 Inventory Management + 2B.11.6 Product Labeling + 2B.12 Personnel Requirements |
Mapping by Kiwa ASI to CSQ Version 2.0 producer standards and CSQ Retail Version 1.0; Michigan names no scheme and no level, and the mapping is Kiwa ASI’s reading of where each duty lands in CSQ, not a state-endorsed crosswalk. Level 1 covers the quality management system and GMP modules; Level 2 and above add HACCP. Ask us which configuration fits your facility.
How to Get CSQ Certified in Michigan
Michigan sets no deadline, so the calendar is yours. Most operations need several months to build the system and collect records before the audit; here is the path.
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01
Step 1: Decide What Certification Is For
Buyer assurance, multi-state consistency, investor diligence, inspection readiness, or positioning for the testing allowances the rule contemplates (none are published today). Writing the goal down shapes the scope, the level and the timing, because no regulator is setting them for you.
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02
Step 2: Choose Your Standard, Scope and Level
Match CSQ Cultivation, Extraction, Manufacturing, Retail or a combination to what you actually do, and choose a level: Level 1 is a complete GMP and quality management certification, Level 2 and above add HACCP. Request a quote so we can confirm scope and audit time.
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03
Step 3: Write the System
A quality manual on your chosen standard, SOPs for every operation (R 420.206a already requires them on site), batch records, supplier approval, sanitation, environmental monitoring, traceability tied to the statewide monitoring system, a recall plan, documentation and recordkeeping, internal audit and CAPA. Your program manager also takes CSQ’s online Certification Program Overview course, accessed through the CSQ website.
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04
Step 4: Train Your Team
Train every person on GMP, hygiene and their own procedures. Edible producers already owe at least two hours of annual food-safety training and a certified Food Protection Manager on site during production (R 420.403(8)(c) and (d)). For Level 2 and above, have one HACCP team member and a back-up certified through a course approved by the International HACCP Alliance.
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05
Step 5: Run It and Audit Yourself
Operate the system, and build up about 60 days of records, which CSQ recommends before certification. Run a documented internal audit and a mock recall in under two hours, close what you find through CAPA, and check yourselves against the published standard before the real audit, a step CSQ strongly recommends and one your own team can run.
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06
Step 6: Schedule With Kiwa ASI
Sign the certification agreement with ASI Food Safety, LLC and set your audit dates with our certification team. Send your documents for the offsite evaluation, which can happen up to six months before the onsite audit, and pick an onsite date that leaves time for corrective actions.
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07
Step 7: Close Out and Keep It Current
Close corrective actions within 30 days of the closing meeting and receive your certificate, typically within about 45 days of the audit. Keep it current with the annual certification audit: a current certificate is standing, independent proof of the GMP program Michigan’s rules already expect you to run.
A worked example, start to certificate: a processor that decides in January to pursue Level 1 would have its system generating records by spring (CSQ recommends about 60 days of records), book the one-day offsite documentation evaluation by early summer, run the one-day onsite audit in late summer, close corrective actions within 30 days, and hold a certificate inside the year. That certificate is valid for one year plus 45 days, with an annual certification audit after that. A score below 70, or any critical finding, means a six-month wait before reapplying, which is the practical argument for building the system properly before booking the audit. Put your timeline in the form above and we’ll tell you the earliest audit dates we can offer.
Prepare Your Team with Kiwa ASI Training
Live online courses, taught by experienced food safety trainers, for the GMP disciplines Michigan’s rules expect and the qualifications CSQ asks for. CSQ’s own Certification Program Overview course for your program manager is taken online through CSQ.
HACCP
HACCP Certification Training
IHA-accredited HACCP certification. CSQ Level 2 and above on Cultivation, Extraction, Manufacturing and Deli-Style Retail need one HACCP team member and a back-up certified in an IHA-approved course (4A.2).
16 contact hours · 4 half-days · Live via Zoom · 8:30 AM–12:30 PM CT
Upcoming dates$695 per seat
Dates on request. Ask about upcoming dates
Part 117
PCQI Certification Training
The FSPCA Preventive Controls for Human Food course built on 21 CFR part 117, the rule Michigan’s edible producers must comply with under R 420.403(8)(a).
22 contact hours · 5 half-days · Live via Zoom · 8:30 AM–12:30 PM CT
Upcoming dates$899 per seat
Dates on request. Ask about upcoming dates
Internal Audit
Principles of Internal Auditing
Plan, run and report the internal audits CSQ requires (1.5), and follow up with corrective action (1.6).
Full day · Live online · 8:30 AM–2:30 PM CT
Upcoming dates$499 per seat
Dates on request. Ask about upcoming dates
EMP
Environmental Monitoring Program Training
Design the risk-based environmental monitoring program CSQ requires (2A.8), a discipline Michigan’s rules don’t spell out.
Half day · Live online
Upcoming dates$300 per seat
Dates on request. Ask about upcoming dates
Allergens
Allergen Management Training
Allergen risk assessment and cross-contact control for infused edibles and beverages, behind the FALCPA labeling Michigan requires (R 420.403(7)(d)).
4 hours · Live online
Upcoming dates$300 per seat
Dates on request. Ask about upcoming dates
Food Defense
Food Defense Coordinator Training
Threat assessments and a defense plan, supporting CSQ’s product defense and fraud prevention requirements (1.9, 1.10).
Full day · Live online · 8:30 AM–2:30 PM CT
Upcoming dates$499 per seat
Dates on request. Ask about upcoming dates
Need to train 6+ people? Request private training. Training is delivered separately from certification by a different legal entity, and taking a course has no effect on your audit result.
Why Michigan Operators Choose Kiwa ASI
Kiwa ASI has audited food safety and GMP programs for decades and brings the same discipline to Michigan’s cannabis operators, in a market where trust is becoming the differentiator.
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Accredited
CSQ’s Licensed Certification Body
CSQ certificates are issued by ASI Food Safety, LLC (Kiwa ASI), CSQ’s licensed certification body, which is accredited to ISO/IEC 17065. Michigan’s voluntary pathway speaks in ISO 17065 terms about the certifying body. ASI Food Safety, LLC holds ISO/IEC 17065 accreditation.
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Purpose-built
A Cannabis-Specific Standard
CSQ is purpose-built for cannabis operations, with standards covering cultivation, extraction, manufacturing, retail, and warehousing and distribution, each on three levels. You certify to a standard written for what you actually do, not a food scheme stretched to fit.
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First mover
Be First on the Registry
As of October 2026, the public CSQ registry lists 115 certified sites across 16 states, and none is in Michigan yet. Michigan producers and cultivators who certify now would be among the first in the state to hold a CSQ certificate issued by an ISO/IEC 17065 accredited certification body.
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Auditors
Qualified, Impartial Auditors
CSQ auditors need bioscience education (or equivalent work experience), IHA-recognized HACCP training and CSQ lead auditor training, and can’t audit a site they provided consulting to, including delivering training, in the past three years.
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Integrity
Impartiality, Disclosed
CSQ is owned by ASI Global Standards, LLC, which, like ASI Food Safety, LLC, is part of ASI Holdings. CSQ discloses that relationship and publishes an impartiality statement. The same three-year consulting bar applies to auditors, and every report gets an independent technical review before a certificate is issued.
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Partnership
Global Kiwa Network
Part of Kiwa, a testing, inspection and certification group operating in more than 30 countries. Kiwa ASI audits and certifies; it doesn’t provide laboratory testing.
Frequently Asked Questions About Michigan Cannabis GMP
Does Michigan require GMP or CSQ certification for cannabis businesses?
No. Michigan’s statutes and rules do not require, name or approve CSQ or any private certification scheme. What R 420.305(4) does is expressly permit producers to become GMP certified by a body accredited under ISO 17065, with R 420.305(5) doing the same for cultivators and GACP-GMP. CSQ audits are delivered by ASI Food Safety, LLC, which holds ISO/IEC 17065 accreditation. Certification is a voluntary differentiator, not a legal requirement, and the rule’s standard-recognition and testing-allowance questions belong to the CRA.
What does R 420.305(4) actually say?
Four things, in four sentences: “all marihuana producers may become certified to GMP by a body accredited under ISO 17065”; this accreditation “may enable the licensee certain allowances with testing”; the agency “will publish those allowances and information on how to obtain approval for allowances”; and “the standard used for certification for GMP must be American National Standards Institute (ANSI) accredited or equivalent.” The permission requires no agency action, the testing benefit is conditional on agency publication, and the standard clause is a recognition question only the CRA can answer.
Do GMP-certified producers get testing breaks in Michigan?
Not today. The rule says certification may enable testing allowances and that the agency will publish them, but as of October 2026 the CRA has published no allowances and no list of recognized certification bodies. The CRA floated incentive-program details in a 2023 feedback request, including reduced testing frequency for GMP-certified product batches, but today there is no allowance to claim. Confirm the current status with the CRA before relying on any testing benefit.
What GMP rules already apply to edible producers in Michigan?
R 420.403(8) requires a producer of edible marijuana product to comply with 21 CFR part 117, FDA’s human-food GMP and preventive-controls rule. It also requires formulation and shelf-stability records, at least two hours of annual food-safety training for employees, and a certified Food Protection Manager on site during production. Add child-resistant packaging (R 420.403(10)), FALCPA allergen labeling (R 420.403(7)(d)) and the CRA’s published THC limits, and an edibles operation already carries most of a GMP program by law. The certificate is the voluntary proof layer on top.
Can we use ISO 22000 instead of 21 CFR part 117 for edibles?
For the safe-preparation standards, yes: R 420.403(8)(e) accepts either 21 CFR part 117 or ISO 22000 plus ISO/TS 22002-1, which Michigan adopts by reference, while R 420.403(8)(a) separately names part 117. That choice is Michigan’s alternative, not CSQ’s basis: CSQ standards were developed on the basis of FDA regulations, 21 CFR Parts 111, 112, 117 and 120, plus ASTM standards, ISO standards, AHPA guidance and a Codex-based HACCP module. Whichever route you comply through, a CSQ audit independently verifies the GMP program you run.
Which CSQ standard fits my Michigan license?
Growers use CSQ Cultivation; processors use CSQ Extraction, CSQ Manufacturing or both; retailers and provisioning centers use CSQ Retail; microbusinesses combine the standards that match their activities, and co-located scopes can be audited in the same visit, with each facility scoped individually. Cultivation, Extraction and Manufacturing are on Version 2.0; Retail & Deli-Style Retail and Warehousing & Distribution are on Version 1.0. Safety compliance facilities follow Michigan’s own lane, ISO/IEC 17025 accreditation, which CSQ does not cover.
Which CSQ level should a Michigan operation choose?
Michigan sets no level, so the choice is yours. Level 1 (Modules 1 to 3) is a complete GMP and quality management certification. Level 2 adds a HACCP system. On Cultivation, Extraction, Manufacturing and Deli-Style Retail, that means one team member and a back-up certified through an International HACCP Alliance approved course; plain Retail certifies to a basic HACCP module. Level 3 adds advanced quality management, and its onsite audits are unannounced. Most first-time sites nationally certify at Level 1 or Level 2.
What about cultivators and GACP?
R 420.305(5) gives cultivators their own voluntary pathway: GACP-GMP certification by an ISO 17065-accredited body, with the standard to be WHO and AHPA or equivalent. CSQ Cultivation is a cGACP and cGMP certification program developed on the basis of AHPA’s good agricultural and collection practices and good manufacturing practices for botanical materials. Whether any particular standard meets the rule’s recognition clause is the CRA’s determination; ask our certification team where CSQ stands before relying on that clause.
Are medical and adult-use facilities treated differently?
Mostly no. Michigan consolidated its medical (MMFLA, 2016) and adult-use (MRTMA, 2018) programs under one set of rules, R 420.1 to 420.1004, run by the Cannabis Regulatory Agency. The rules define “producer” to mean a processor under either act (R 420.401(1)(l)), so the GMP duties and the voluntary certification pathway read the same across both markets. Plant-count classes differ: adult-use growers are capped at 100, 500 and 2,000 plants by class (MCL 333.27959(2)), medical at 500, 1,000 and 1,500 (MCL 333.27501(1)).
How long does CSQ certification take in Michigan?
Most operations need several months to build the system and collect records; CSQ recommends about 60 days of records before attempting certification. The audit itself is a 1-day offsite documentation evaluation, up to six months before the onsite visit, plus at least 1 day onsite at Level 1, 1.5 days at Level 2 or 2 days at Level 3. Corrective actions close within 30 days, and the final report and certificate follow within about 45 days. CSQ also has a provisional six-month certificate route for sites that must be audited before beginning operations and do not yet have production records; ask our certification team whether it fits your situation.
How much does CSQ certification cost in Michigan?
There’s no single price. Audit time drives the fee: your CSQ level (1, 1.5 or 2 days onsite minimum), the standards in scope, the number of employees and product types, the 1-day document evaluation on initial audits, the number of sites and travel. Request a quote for your Michigan scope.
How often do I need to be audited?
Once a year. A CSQ certificate is valid for one year plus 45 days, so the annual certification audit keeps it current. A score of 70–79 adds a surveillance audit about six months later, and a score of 79 or below on that audit suspends the certificate. Every certified site also gets an unannounced audit at least once every three years.
What happens if we fail the audit?
A score below 70, or any critical finding, means no certificate and a six-month wait before reapplying, so plan for one solid attempt. A score of 70–79 still earns a certificate with a surveillance audit six months later. Corrective actions from any audit must be approved and closed within 30 calendar days of the closing meeting.
Are Michigan testing labs part of CSQ certification?
No. Michigan requires its safety compliance facilities to be accredited to ISO/IEC 17025:2017 by an ILAC-recognized accreditation body (or an entity the agency approves) within one year of licensure (R 420.305(1)), with quality programs conforming to good laboratory practice standards (R 420.305b). CSQ publishes no laboratory standard; what CSQ requires of certified operations is that finished-product compliance testing run through ISO/IEC 17025 accredited laboratories (2A.12.9). Kiwa ASI audits and certifies; it does not provide laboratory testing.
What is happening with Michigan’s cannabis rules overhaul?
A comprehensive CRA rules overhaul (rule set 2023-25 LR) has been in progress since 2023, with a second public hearing in July 2026. As of October 2026 it has not been filed, so the rules in force since March 2022 govern, and most of a filed overhaul would take effect 180 days after filing. We re-verify this page against the current rules; if the overhaul takes effect, we will update this page to reflect the rules then in force.
Why pursue certification now, in a down market?
Because the market is consolidating on quality. Michigan’s 2025 sales fell about 3 percent to roughly 3.17 billion dollars, the first annual decline since adult-use sales began, with prices compressed and a new 24 percent wholesale tax in effect since January 2026 (under court challenge as of October 2026). As of the CRA’s September 2026 monthly report, 2,136 active adult-use licenses were competing, including 797 Class C growers and 270 processors, and enforcement stayed busy through 2026 with recalls and a 2 million dollar fine. In that market, buyers and surviving operators compete on trust and consistency, and an independent certificate is the cleanest way to show both. It also positions you for the testing allowances Michigan’s rule contemplates, if the CRA publishes them.
Does CSQ cover hemp operations too?
Yes. CSQ’s standards cover cannabinoid herbal materials, substances and products across cannabis and hemp alike, and Kiwa ASI audits and certifies hemp cannabinoid operations to CSQ in the same way. For multi-state operators, that means one certification program can span THC and hemp product lines across your footprint.
Who issues CSQ certificates, and are they accredited?
CSQ certificates are issued by ASI Food Safety, LLC, the company behind the Kiwa ASI brand and CSQ’s licensed certification body, which is accredited to ISO/IEC 17065. CSQ itself is a standard, so it isn’t accredited, and it isn’t GFSI-benchmarked. Certificates are listed on CSQ’s public registry, where anyone can verify them.
Ready to prove the program you already run?
Tell us your license type and what you grow or make. We’ll recommend a CSQ standard and level, quote your audit and tell you the earliest audit dates we can offer.
Standards & Trust
ASI Food Safety, LLC (Kiwa ASI) is currently CSQ's licensed certification body and is accredited to ISO/IEC 17065. CSQ is a standard, so it isn't itself accredited, and it isn't GFSI-benchmarked. Michigan mandates no certificate, approves no scheme or certifier, and has published no testing allowances; the voluntary pathway in R 420.305(4) and (5) names ISO 17065 accreditation for the certifying body, and its separate standard-recognition clauses are the CRA’s to interpret. CSQ is owned by ASI Global Standards, LLC, which, like ASI Food Safety, is part of ASI Holdings (see CSQ’s program oversight and impartiality statement). Kiwa ASI training is delivered separately from certification.