MEMORANDUM IN OPPOSITION

June 24, 2026

A.11562 (Bronson) / S.10643 (Ramos)

AN ACT to amend the cannabis law, in relation to labor peace agreements and the cannabis industry wage board.

The Empire State Green Standard Alliance (GSA), a statewide organization advocating for cannabis consumers, public health, product safety, and a sustainable regulated marketplace, respectfully opposes this legislation.

GSA supports fair wages, safe workplaces, and the rights of employees to organize. However, this legislation would create significant foreseeable negative consequences for New York's legal cannabis market at a time when the State should be focused on strengthening licensed operators and transitioning consumers away from the illicit market.

The proposed Cannabis Industry Wage Board would be granted broad authority to establish wage standards across an industry that remains economically fragile and unstable. Unlike mature industries with established market stability where wage boards have been established, like the agricultural and food delivery service industries, New York's cannabis market continues to face substantial challenges including excessive taxation, high regulatory costs, limited access to capital, and ongoing competition from illicit operators.

Any increase in labor costs resulting from the actions of the wage board will inevitably increase the cost of legal cannabis products. Higher consumer prices will further incentivize consumers toward unlicensed operators who are not subject to any testing requirements, taxation, labor standards, or consumer protection regulations. Such an outcome would undermine public health objectives, reduce tax revenues, and further undermine the legal market the Office of Cannabis Management has spent years establishing.

The legislation is also inconsistent with the social equity goals of the Marijuana Regulation and Taxation Act (MRTA). Many social and economic equity licensees, microbusinesses, and small cannabis operators are already operating on narrow margins. Unlike larger operators, these businesses operate with limited access to capital and lack the resources necessary to absorb increases in labor costs or comply with additional regulatory requirements. The result will be further market consolidation and reduced opportunities for the small businesses the MRTA was intended to support.

GSA is not aware of any studies or analyses finding that employees in New York’s cannabis industry have been underpaid compared to employees in similar positions in other industries, that cannabis businesses have been taking advantage of employees within the industry, or that have signaled a need for a wage board to address these or similar concerns. As such, GSA is concerned that the proposed legislation is unnecessarily addressing a labor issue that does not actually exist, without any supporting evidence by further regulation and indirectly making it more costly for the New York cannabis small business licensees to operate in the industry.

In addition, this legislation may ultimately reduce options for consumers by increasing barriers for small cultivators, processors, retailers, and microbusinesses. A healthy cannabis market requires a diverse ecosystem of participants capable of competing with larger operators and serving consumers across New York State. Policies that increase costs without regard to operational realities risk reducing competition, limiting product diversity, and slowing the growth of the regulated marketplace Again, all this runs counter to the underlying goals of the MRTA.

GSA is also concerned that the legislation does not require any comprehensive economic impact analysis before wage recommendations are implemented or, once wage recommendations are set, does not require the contemplated wage board to evaluate the effect of its recommendations on consumer prices, illicit market competition, social equity licensees, product availability, small business viability, or overall market stability. Decisions affecting an entire regulated industry should be informed by economic data and market realities.

Accordingly, in order to ensure that a wage board for the cannabis industry is in fact warranted and, if so, that any such wage board conduct its work in a manner that does not detrimentally impact the burgeoning cannabis industry in New York State – particularly small businesses and equity licensees –, GSA recommends that this legislation be vetoed, or significantly amended to require, at the very least, an economic impact study before a wage board is established in law.

New York's primary cannabis policy objective should remain expanding participation in the legal market, increasing consumer access to safe and tested products, supporting social equity entrepreneurs, and reducing the market share of illicit operators. This legislation risks moving the State in the opposite direction and puts MRTA’s goal to provide a fair and equitable opportunity for all to participate in this industry at risk.

For these reasons, the Empire State Green Standard Alliance respectfully opposes A.11562/S.10643 and urges its rejection.

About the Empire State Green Standard Alliance

The Empire State Green Standard Alliance is led by a distinguished board advancing consumer protection, education, and fair policy in New York’s cannabis market. Herb Barbot serves as Board Chair, drawing on his experience as the inaugural Director of Operations at the New York State Office of Cannabis Management. Joseph Levey, a Founding Partner at Helbraun Levey, oversees licensing and regulatory matters. Mark Wagner, Counsel at The West Firm, provides corporate and regulatory legal expertise. Linda Baldwin, former General Counsel to the New York State Office of Cannabis Management, brings deep institutional knowledge of cannabis regulation, enforcement, and consumer protection frameworks. And Tiffany Walters, CEO of New York State Cannabis Connect, contributes deep insight into workforce development, equity and community engagement. Joe Rossi serves as Chief Strategist, bringing more than 18 years of experience in New York State government relations.

Download the press release here

Media Contact:

Joe Rossi

Email: joe.rossi@modernadvocacyllc.com

Website: www.greenstandardalliance.org