How is bud-trim line working in California?

A fair argument against weight-based taxes on raw marijuana plant material is that different parts of the plant need different tax rates.  So categories are needed.  A particularly difficult line to draw may be that between bud (flower) and trim (leaves).  That topic has been covered here, in a link below in my message to the California Department of Tax and Fee Administration via www.cdtfa.ca.gov/contact.htm.

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Dear Folks at the CDTFA:

The tax policy nonprofit Center for New Revenue is researching the administration of weight-based cannabis taxes.  In particular, we are looking at the line between bud or flower, which you tax at $9.25 per ounce, and the material you tax at $2.75 per ounce.

Whom might I speak to about that?

Earlier work from the Center on this topic appears at https://newrevenue.org/?s=bud-trim++. I was co-chair of the Regulatory and Tax Structure Working Group of the California Blue Ribbon Commission on marijuana legalization – a project of then Lieutenant Governor Newsom and the ACLU of Northern California. https://www.safeandsmartpolicy.org.

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They are on it:
“Thank you for contacting the California Department of Tax and Fee Administration. Your message has been received.”

The CDFTA and its predecessor, the Board of Equalization, have always responded carefully to my inquiries from out of state.

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Here, for instance, are the more involved current categories and tax rates per gram in Colorado:

Bud 26¢.
Trim 13¢
Wet whole plant 5¢
Bud for extraction 7¢
Trim for extraction 7¢

Those rates come from taking 15 percent of the Average Market Rate Prices here: https://www.colorado.gov/pacific/tax/marijuana-taxes-file

Period Rate: Jan.1 to March 31, 2019