CSQ CERTIFICATION
The CSQ Certification Program and applicable standards were built around ISO/IEC 17067
Michigan MRTMA & MMFLA · Cannabis Regulatory Agency · R 420 rules
Michigan GMP for Cannabis
Michigan licenses and inspects every cannabis grower, processor, retailer, and testing lab through the Cannabis Regulatory Agency, and edible producers must self-comply with federal human-food GMP (21 CFR part 117). Michigan does not require a third-party GMP certificate — but its rules expressly permit voluntary GMP certification by an ISO 17065-accredited body (R 420.305(4)), which is exactly what CSQ is.
Michigan's Cannabis GMP Rules and Why CSQ Certification Is Worth It
Michigan legalized both medical and adult-use marihuana and regulates producers through the Cannabis Regulatory Agency (CRA). Michigan does not require a third-party GMP certificate but its own rules expressly permit producers to become GMP certified by a body accredited under ISO 17065 (R 420.305(4)), which is exactly what CSQ is. This page explains what Michigan actually requires, which CSQ standard fits your license, and where certification with Kiwa ASI adds value.
START HERE
Does Michigan Require Cannabis Operators to Be GMP Certified?
No, Michigan does not mandate third-party GMP certification for cannabis operators. But GMP is not entirely optional: edible producers must self-comply with federal human-food GMP, and Michigan's own rules already point to voluntary ISO 17065 GMP certification. Here is the short version, and why CSQ still matters.
WHO THE CRA REGULATES
Growers, processors, retailers, testing labs
The CRA licenses adult-use establishments (MRTMA) and medical facilities (MMFLA): growers, processors, retailers/provisioning centers, secure transporters, and safety compliance facilities (testing labs). The same edible/manufacturing rules apply to both medical and adult-use processors.
THE REQUIREMENT
Edible GMP + lab testing, not a certificate
Edible producers must self-comply with 21 CFR part 117 human-food GMP or ISO 22000 (R 420.403(8)); every batch is tested by an ISO/IEC 17025 lab (R 420.305(1), (3)). No accredited third-party GMP certificate is required — but voluntary ISO 17065 GMP certification is expressly permitted.
WHERE CSQ FITS
Voluntary — and the accreditation MI's rule names
CSQ is an accredited (ISO/IEC 17065) cannabis-specific GMP certification. Michigan doesn't require it, but R 420.305(4) already recognizes ISO 17065 GMP certification — the exact accreditation CSQ holds — making it a natural, credible differentiator.
What Michigan actually requires
Michigan runs two parallel cannabis frameworks under one regulator: the adult-use Michigan Regulation and Taxation of Marihuana Act (MRTMA) and the medical Medical Marihuana Facilities Licensing Act (MMFLA), both administered by the Cannabis Regulatory Agency (CRA) within LARA under the R 420 administrative rules. (Michigan statute spells it “marihuana.”) Every marihuana business must keep up-to-date written standard operating procedures on site (R 420.206a), and every product batch must pass safety testing at an ISO/IEC 17025-accredited laboratory before sale (R 420.305(1), (3)).
For edibles, GMP practices are the law: a producer of edible marihuana product shall comply with 21 CFR part 117 — the FDA's Current Good Manufacturing Practice and Preventive Controls for Human Food — or, as an alternative, ISO 22000 (R 420.403(8)). Edible makers also need a certified Food Protection Manager on site, annual food-safety training, and formulation records. What Michigan does not do is require an accredited third-party GMP certificate. But here is the part that makes Michigan unusual: its rules expressly permit producers to become GMP certified by a body accredited under ISO 17065 (R 420.305(4)), and cultivators to become GACP-GMP certified the same way (R 420.305(5)). CSQ is an ISO/IEC 17065-accredited program — so in Michigan CSQ is voluntary, and the state's own rulebook already recognizes the accreditation it holds.
FIND YOUR PATH
Match Your Michigan License to the Right CSQ Standard
CSQ is voluntary in Michigan, so this is about which scope fits if you pursue certification. Match your CRA license to the CSQ standard that fits; operators who hold more than one license (Michigan allows vertical integration) can combine scopes into one coordinated audit with Kiwa ASI.
Grower (Class A / B / C)
MCL 333.27959(2) · R 420.305(5)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)
Cultivation, drying, curing, and trimming. Foundation: cGACP (good agricultural and collection practices) plus cGMP. Michigan expressly permits cultivators to become GACP-GMP certified by an ISO 17065 body (R 420.305(5)). Adult-use plant caps run 100 / 500 / 2,000 by class; class C is stackable.
Processor — Edibles / Concentrate
R 420.401 · R 420.403STANDARD
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)
Extraction and manufacturing of concentrate and infused products (edibles, beverages, vapes, topicals). Edible producers already owe 21 CFR part 117 human-food GMP (or ISO 22000), so this is where CSQ maps most directly. CSQ items to watch: beverage-grade CO₂ (99.5%), food-grade non-denatured ethanol, and residual-solvent controls.
Processor — Package / Label
R 420.401 · R 420.403 · R 420.504STANDARD
CSQ Manufacturing v2.0.0
MINIMUM LEVEL
Level 1
PREP TIME
4–6 months
AUDIT LENGTH
~1 day onsite + 1 day offsite doc review (initial)
Packaging and labeling of marihuana product. A lighter GMP scope focused on handling, child-resistant packaging (16 CFR 1700.15), allergen and ingredient labeling (FALCPA), and homogeneity controls.
Retailer / Provisioning Center
MCL 333.27959(2) · R 420.504STANDARD
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)
Adult-use retailers and medical provisioning centers. Built on cGHP (good handling practices) — storage, handling, inventory, verification against the statewide monitoring system, and staff training.
Safety Compliance Facility (Lab)
R 420.305(1) · R 420.305bSTANDARD
ISO/IEC 17025 + 40 CFR 160 GLP
MINIMUM LEVEL
N/A
PREP TIME
Varies
AUDIT LENGTH
Per accreditation body
Michigan requires testing labs to be ISO/IEC 17025:2017 accredited by an ILAC-recognized body and to follow Good Laboratory Practice (40 CFR 160). CSQ does not certify testing labs; it requires them to be ISO/IEC 17025 accredited.
MICHIGAN REQUIRES VS. CSQ GOES FURTHER
What's a State Rule, and What's a CSQ Best Practice?
Michigan's regulations are the legal floor, enforced by CRA licensing, inspection, and mandatory lab testing. CSQ is a voluntary published standard that documents GMP beyond that floor — and one carrying the ISO 17065 accreditation Michigan's own rules already recognize. Knowing which is which keeps you from over-buying or under-preparing.
What Michigan requires (the legal floor)
- CRA licensing for growers, processors, retailers, and testing labs — MRTMA (MCL 333.27951 et seq.) & MMFLA (MCL 333.27101 et seq.)
- Up-to-date written standard operating procedures on site for every marihuana business — R 420.206a
- Mandatory batch safety testing by an ISO/IEC 17025-accredited laboratory — R 420.305(1), (3)
- Edible producers self-comply with FDA human-food GMP (21 CFR part 117) or ISO 22000 — R 420.403(8)
- Edible controls: certified Food Protection Manager on site, annual food-safety training, formulation records — R 420.403(8)(b)–(d)
- Packaging & labeling: child-resistant (16 CFR 1700.15), allergen labeling (FALCPA), THC limits — R 420.403 / R 420.504 / R 420.404
- Voluntary GMP certification by an ISO 17065 body is expressly permitted, not required — R 420.305(4)–(5)
- No accredited third-party GMP certificate is required
What CSQ adds (voluntary best practice)
- An accredited (ISO/IEC 17065) cannabis GMP certification — the exact accreditation Michigan's rule already names (R 420.305(4))
- Built to meet the 21 CFR part 117 human-food GMP / ISO 22000 principles Michigan applies to edibles
- 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 — beyond Michigan's licensee recall duties
- 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)
- Multi-state standardization, retail and buyer assurance, and audit-ready documentation
- A HACCP team and certified lead (Level 2 only — not a Michigan requirement)
Quick glossary — the terms that show up in a Michigan CSQ audit
CRA
The Cannabis Regulatory Agency — Michigan's cannabis regulator, within LARA. Renamed from the Marijuana Regulatory Agency (MRA) by executive order in 2022.
MRTMA / MMFLA
The adult-use Michigan Regulation and Taxation of Marihuana Act (2018) and the medical Medical Marihuana Facilities Licensing Act (2016) — the two commercial-licensing frameworks the CRA administers.
R 420 rules
The CRA's consolidated administrative rules (Mich. Admin. Code R 420.1–R 420.1004) governing licensing, operations, edibles, testing, packaging, and recalls.
Producer
A processor under either the medical (MMFLA) or adult-use (MRTMA) framework (R 420.401(1)(l)) — the same manufacturing and edible rules apply to both.
21 CFR part 117
The FDA's Current Good Manufacturing Practice and Preventive Controls for Human Food. Michigan requires edible marihuana producers to self-comply with it (R 420.403(8)) — note it is Part 117 (food), not Part 111 (supplements).
ISO/IEC 17065
The accreditation standard for bodies that certify products and processes. Michigan's rules permit voluntary GMP certification by an ISO 17065-accredited body (R 420.305(4)); CSQ is delivered by an ISO/IEC 17065-accredited certification body.
ISO/IEC 17025
The competence standard for testing laboratories. Michigan safety compliance facilities must be ISO/IEC 17025:2017 accredited (R 420.305(1)); CSQ requires labs to hold the same.
GACP-GMP
Good Agricultural and Collection Practices combined with GMP — the voluntary certification pathway Michigan permits for cultivators (R 420.305(5)).
THE AUDIT
What a CSQ Audit Actually Looks Like
A Michigan 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 |
| Initial certification blackout | No initial certifications scheduled in November or December |
| Provisional certificate | Available for new operations (valid 6 months) |
| Dietary Supplement Addendum | 4-hour minimum · Pass/Fail · separate report within 72 hours |
For consultants, internal compliance leads, and operators who want the section-by-section map between Michigan's regulations and CSQ 2.0:
Michigan cannabis rules and corresponding CSQ 2.0 sections
| Missouri Requirement | Citation | CSQ Coverage |
|---|---|---|
| CRA licensing of marihuana establishments | MCL 333.27959 / R 420 | Module 1 (CSQMS) + Section 1.3 (Regulatory Compliance) |
| Up-to-date written SOPs on site | R 420.206a | Module 1 (CSQMS) + Section 1.4 (Document Control) |
| Edible producers comply with human-food GMP / ISO 22000 | R 420.403(8) (21 CFR 117) | Module 2A (cGMP) + Section 3C (formulated / ingestible product controls) |
| Voluntary ISO 17065 GMP / GACP-GMP certification permitted | R 420.305(4)–(5) | Whole standard — CSQ is delivered by an ISO/IEC 17065-accredited body |
| Safety compliance labs ISO/IEC 17025 accredited | R 420.305(1) | Section 2A.12.9 / 2B.11.7 (Product Sampling and Testing) — CSQ requires ISO/IEC 17025 labs |
| Packaging, labeling, allergen, and THC-limit rules | R 420.403 / R 420.504 / R 420.404 | Section 2A.12.8 / 2B.11.6 (Product Labeling and Packaging) |
| CRA recall / administrative-hold compliance | R 420.502 / R 420.403(4) | Section 1.8 (Recall & Traceability) + Section 1.6 (CAPA) |
How to Prepare | A Realistic Path to CSQ Certification
Because CSQ is voluntary in Michigan, step one is deciding whether it earns its place for you. If it does, most operators need 6 to 9 months to be ready for an initial audit. Here is a sequence that works.
01
Decide whether CSQ is right for you
Michigan doesn't require it, so weigh the value: multi-state standardization, retail and buyer assurance, and audit-ready documentation. If you make edibles or beverages you already owe 21 CFR part 117 GMP — CSQ certifies what you are already doing. If those matter, CSQ is worth pursuing.
02
Confirm your CSQ standard and level
Match your CRA license — grower, processor (edibles/concentrate or package/label), retailer — 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 (built to meet 21 CFR part 117 human-food GMP and ISO 22000 principles). ASI Training and Consulting, LLC can deliver a structured gap analysis as a separate engagement from the certification body.
04
Build the QMS documentation
Author or update SOPs for sanitation, process flow, cross-contamination, allergens, environmental monitoring, waste, traceability, and product release — the same written SOPs Michigan already requires on site (R 420.206a). Stand up your CAPA, internal audit, and document-control systems.
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. Verify these 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 Michigan 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 Michigan — one of the largest U.S. cannabis markets, and one whose own rules already recognize ISO 17065-accredited GMP certification.
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.
Partnership
Global Kiwa network
Operations in 30+ countries. Useful when a Michigan operator expands into other state markets or builds an international supply chain.
Frequently Asked Questions About Michigan Cannabis GMP & CSQ Certification
No. Michigan does not mandate an accredited third-party GMP certificate. But GMP is not entirely optional: edible producers must self-comply with FDA human-food GMP (21 CFR part 117) or ISO 22000 (R 420.403(8)), every batch is tested by an ISO/IEC 17025 lab (R 420.305(1), (3)), and the state's rules expressly permit producers to become GMP certified by an ISO 17065-accredited body (R 420.305(4)). CSQ certification is voluntary — an independent, accredited way to prove your GMP program.
Both. Michigan legalized medical marihuana in 2008 (the Michigan Medical Marihuana Act) and licensed commercial medical facilities under the Medical Marihuana Facilities Licensing Act (2016). Adult-use (21+) marihuana was legalized by the Michigan Regulation and Taxation of Marihuana Act, approved by voters in 2018. Both commercial frameworks are run by the Cannabis Regulatory Agency.
The Cannabis Regulatory Agency (CRA), an agency within the Department of Licensing and Regulatory Affairs (LARA). It was renamed from the Marijuana Regulatory Agency (MRA) by executive order in 2022. The CRA administers both the adult-use (MRTMA) and medical (MMFLA) frameworks under the R 420 administrative rules. Michigan statute spells the substance “marihuana.”
Yes — as self-compliance, not certification. A producer of edible marihuana product must comply with 21 CFR part 117 (the FDA's Current Good Manufacturing Practice and Preventive Controls for Human Food) or, as an alternative, ISO 22000 (R 420.403(8)). Edible makers also need a certified Food Protection Manager on site, annual food-safety training, and formulation records. Michigan does not require these to be verified by a third-party certificate — that is where CSQ adds value.
No. GMP compliance is verified through CRA licensing, written SOPs, and mandatory batch testing — not by a required outside auditor. Michigan's rules do, however, expressly permit voluntary GMP certification by a body accredited under ISO 17065 (R 420.305(4)), and GACP-GMP certification for cultivators (R 420.305(5)). A CSQ certificate is voluntary and does not replace CRA licensing or lab testing.
No. Michigan's statutes and rules do not name CSQ or any private certification scheme. What they do name is ISO 17065 — the accreditation standard for GMP certification bodies (R 420.305(4)). CSQ is delivered by ASI Food Safety as an ISO/IEC 17065-accredited certification body, so it fits the pathway Michigan's rules already recognize. It is a voluntary differentiator, not a legal requirement.
Growers use CSQ Cultivation v2.0.0; processors making concentrate or edibles use CSQ Extraction or Manufacturing v2.0.0; package-and-label processors use CSQ Manufacturing; retailers and provisioning centers use CSQ Retail v1.0.0. Safety compliance facilities (testing labs) follow ISO/IEC 17025 and 40 CFR 160 GLP (CSQ does not certify labs but requires ISO/IEC 17025). Kiwa ASI can combine scopes into one coordinated audit.
Because it proves GMP rigor that licensing and lab testing alone don't document. The highest-value cases: an edible or beverage maker who already owes 21 CFR part 117 GMP and wants an accredited certificate to show for it, a multi-state operator standardizing GMP across programs, and retail or buyer assurance — plus audit-ready records. And Michigan's own rules already recognize the ISO 17065 accreditation CSQ holds.
There is no single published price: cost depends on which CSQ standards apply, which level you pursue, facility size and complexity, whether it is your initial audit (which adds an offsite documentation day), and whether you combine multiple facility scopes. Most operations need 6 to 9 months to prepare; a Level 1 audit is roughly 1 onsite day plus report time. Request a quote for a Michigan-specific scope.
Yes — but as separate legal entities to safeguard certification-body independence. CSQ certification audits are delivered by ASI Food Safety, LLC (the accredited certification body, ISO/IEC 17065 accredited and CSQ-licensed). Pre-assessments, gap analyses, training, and consulting are delivered by ASI Training and Consulting, LLC. The two operate independently to comply with ISO/IEC 17065 impartiality rules.