On Jan.17, the New Jersey Cannabis Regulatory Commission (the CRC) released its proposed regulations for "cannabis consumption areas," or "consumption lounges," where medical or personal-use cannabis may be consumed by persons 21 or older. This article explores the proposed legislative framework to operate a consumption lounge in the state, and sets forth some of the anticipated, potential issues that may arise as these lounges become operational.

Under the proposed regulations, a consumption lounge must be operated by a permitted medical cannabis dispensary or a licensed Class 5 cannabis retailer that obtained both state and local endorsement. It should be noted that the host municipality has the power to adopt ordinances that permit, or prohibit, cannabis consumption lounges within the municipality. If permitted, these municipal ordinances may govern the manner, time and location of the operation, including minimum distances from schools, daycare facilities, playgrounds and places of worship.