Liquor & Cannabis Law

Modifications to Help Liquor and Cannabis Board Licensees During COVID-19

Download PDF
Text reading "Washington State Ferries Grand Canyon Lines" in a stylized font.

On Tuesday, March 17, 2020, the Washington State Liquor and Cannabis Board (LCB) published temporary modifications in an effort to help licensees weather mandated closures or other business interruptions during COVID-19.

Below we provide a summary of these temporary modifications and guidance on how to take advantage of them:

  • Alcohol distributors may accept product returns from and issue refunds to alcohol retailers.
    • Distributors must email Lieutenant Robert Knowles at [email protected] the license number(s) of the alcohol retailer and the product returned.
    • This temporary modification does not affect the existing ban on exchanging product, which prohibits distributors from exchanging product currently held by a retailer for new or different product. 
  • Alcohol licensees may offer curbside service and delivery to customers.
    • Some licensees already have “to-go” or “off-premises privileges.” For these licensees, simply submit the Temporary Delivery and Curbside Service Form to the LCB.
    • For licensees who do not have off-premises privileges, you must file both an Application for Added Endorsement, and Temporary Delivery and Curbside Service form with the LCB. Please note: The LCB is working with local jurisdictions to waive the usual 20-day (or more) waiting period that would otherwise apply in this circumstance. As such, the required waiting period to obtain these temporary privileges may vary by local jurisdiction. 
  • The exchange of product must still take place within the boundaries of the “licensed property.” For example, once the LCB approves your temporary curbside service request, you could be permitted to deliver product to a customer in your parking lot even though the licensed premises technically stops at the door. 
  • Cannabis retailers may offer curbside services to qualified patients or their designated providers.
    • Please be clear on this point: Cannabis retailers may stay open as long as they implement appropriate social distancing measures.
    • Curbside service does not include the use of drive-through windows.
    • As with alcohol licensees, the exchange of product must still take place within the boundaries of the licensed property.

To the extent a licensee would be required to file a form or application with the LCB to take advantage of these temporary modifications in an effort to increase revenues during this time, Foster Garvey is offering a flat fee for many of these services. It is our goal to help clients manage these difficult times by taking full advantage of every available modification. 

For additional resources relating to the LCB’s response to COVID-19, you may visit the coronavirus section of the LCB’s site. And as always, if we can be of any assistance to you at this time, please know that our team is here for you.