On Tuesday, December 21, 2021, the City of Chicago ordered that many public accommodations, including restaurants, bars, coffee shops, gyms, and entertainment venues, must require patrons to present proof of full vaccination status before entry. The order becomes effective January 3, 2022, so time is short for businesses to establish processes and procedures for compliance with the new rules.

Conspicuously absent from the non-exhaustive list of specific venues covered by the order are cannabis retail establishments. This is likely by design. The thrust of the order focuses on businesses serving food and beverages, where patrons would otherwise, be permitted, under the Illinois mask mandate rules, to temporarily remove a facemask to eat or drink. In other words, businesses where patrons would not otherwise take down their masks, because they are not consuming anything on-site, would not be expressly covered by the order. Logically, then cannabis retailers are not covered (unless they are also serving food and/or drink on-site). 

While it is arguable that consumption of edibles and/or smoking or vaping on-site, where someone would need to take their mask down, could convert a business to a covered venue, Chicago’s cannabis regulations do not currently allow consumption of product on-site and as

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