In 2024, the California Department of Cannabis Control posted 64 recalls on the public recall portal. 26 were classified Voluntary and 38 were classified Mandatory. In 2025, the portal posted 93 recalls. 86 were Voluntary. 7 were Mandatory.
The mandatory pathway shrank by 31 entries year on year. The voluntary pathway grew by 60. The total went up. The classification ratio inverted.
Every count above is on the public DCC recall portal at recalls.cannabis.ca.gov, with the recall_type field visible on each entry. Anyone can reproduce these counts by filtering the portal by recall date and aggregating.
What the two labels mean under the regulation
Voluntary and Mandatory recalls are two procedures with two regulatory citations.
4 CCR § 17226 covers voluntary recalls. It requires licensees to "establish and implement written procedures for recalling cannabis goods that are determined to be misbranded or adulterated," to notify DCC within 24 hours, to quarantine recalled product for a minimum of 72 hours, and to track the recall through the state's track-and-trace system.
4 CCR § 17227 covers mandatory recalls. It is short. The operative sentence: "The Department may require licensees to conduct a recall of a cannabis good that is adulterated or misbranded in accordance with Business and Professions Code section 26039.1." BPC § 26039.1 is the underlying statutory authority.
§ 17227 then says the licensee "shall conduct the mandatory recall in the same manner as a voluntary recall as provided in section 17226." The retrieval, the quarantine, the destruction, the customer notification. Statutorily identical.
So the two labels do not classify what the licensee does with the product. They classify who signed the paperwork that started the recall. Voluntary is a recall the licensee notified DCC about. Mandatory is a recall DCC ordered.
The transition is monthly-visible
The flip did not happen evenly across the year. It happened over a narrow window in late 2024.
| Month | Total | Mandatory |
|---|---|---|
| 2024-07 | 7 | 6 |
| 2024-08 | 7 | 7 |
| 2024-09 | 9 | 8 |
| 2024-10 | 6 | 1 |
| 2024-11 | 3 | 0 |
| 2024-12 | 9 | 0 |
| 2025-01 | 4 | 0 |
| 2025-02 | 7 | 0 |
| 2025-03 | 14 | 1 |
July through September of 2024 ran 21 mandatory recalls in 90 days. October and November ran one combined. December ran zero. The mandatory pathway did not taper. It closed inside one fiscal quarter.
From January 2025 through May 2026, the public portal has posted 107 recalls. 7 were Mandatory. The 2026 year-to-date count is 14 recalls, all of them Voluntary.
Why the routing changed
A voluntary recall and a mandatory recall move product the same way. They differ on which entries land where on the licensee's enforcement file.
A mandatory recall under § 17227 is a formal departmental action. It produces a public order under BPC § 26039.1. It tends to be paired with the broader enforcement track DCC publishes on the compliance-action records page. It carries renewal-application consequences, and it is what a licensee's attorney has to disclose on the next license-renewal filing.
A voluntary recall under § 17226 is the licensee's own paperwork. It posts on the same portal. It uses the same notice template. The product retrieval looks identical from the public's view. But on the licensee's enforcement file, the entry reads "cooperated with the agency" rather than "agency issued an order."
When DCC has evidence of non-compliance and contacts a licensee, both sides have an administrative interest in the voluntary pathway. The agency moves the product without a hearing and without spending its formal-order budget on a single batch. The licensee avoids the enforcement-file consequence. The product is off the shelf either way.
California cannabis attorney Omar Figueroa, writing on his firm's site at omarfigueroa.com about the 2024 recall increase, named three contributing factors: new testing-laboratory regulations that took effect on January 1, 2024; an increase in DCC enforcement staffing focused on adulterated or misbranded products; and a transition from the DCC's initial "education" phase into an "enforcement" phase. The voluntary-vs-mandatory split is what happens after that transition, once the agency's compliance contacts have built up enough volume that hearing-cost economics start to matter. A regulator can either issue more orders or close more matters through the licensee-signed channel. The recall-type column on the public portal records which one it chose.
Operationally, the 2025 numbers are what a regulator does when it has settled into a high-volume enforcement cadence. The mandatory pathway stays available, but it is reserved for the cases where the licensee resists or the agency wants a formal order on the record. Most matters route the other way.
A Voluntary badge is not a clean enforcement file
The 92% voluntary share for 2025 looks, on a casual read, like California's cannabis operators got dramatically more proactive about pulling their own product. The reading is wrong.
Three operator-side reads that follow:
A Voluntary badge on a competitor or a supplier is not the regulator giving them a pass. It is the regulator routing a compliance contact through the lower-friction pathway. The licensee was in the conversation either way.
Recall count alone underreads the enforcement signal in 2025 forward. A 45% year-on-year rise in total recalls with a 92% voluntary share looks calm to an outside reader. The agency-contact volume that produced the recalls is the part the public surface does not separately publish.
A licensee with even a single Voluntary recall has been through a compliance conversation and signed DCC paperwork to settle it. That is a fact about their enforcement file, not a fact about how cooperative they happen to be on any given week.
The ratio is a regulator's pen, not an operator behavior change
The recall portal publishes both categories from the same surface and uses the same retrieval procedures for each. The classification flip between 2024 and 2025 records which form DCC asked the licensee to sign. It does not record a change in how often non-compliant product enters the supply chain, and it does not record a change in how willing operators are to pull it back out.
The recall count went up. The mandatory column went near-zero. Read those two together and the regulator's routing posture is the only variable that changed enough to account for both.
Sources: DCC recalls portal at recalls.cannabis.ca.gov; 4 CCR § 17226 (Voluntary Recalls) and § 17227 (Mandatory Recalls); BPC § 26039.1 (statutory authority for DCC-required recalls); Omar Figueroa, "Dramatic Increase in Cannabis Product Recalls in California", Law Offices of Omar Figueroa. Aggregate counts derived from the public recall portal as of 2026-05-24.