LCB denies petition to allow prepackaged meals to qualify as a "complete meal"

The Washington State Liquor and Cannabis Board on April 22 voted to deny a petition seeking to amend WAC language so that prepackaged foods could qualify as a "complete meal" for licensing purposes.

Daniel Jacobs, the director’s office policy and rules coordinator, presented the recommendation to deny on behalf of the director's office. Jacobs summarized the rule and statutory history and said the agency has long excluded solely prepackaged frozen meals, carryout items from other businesses and snack food from the definition of a complete meal. "Allowing prepackaged food to constitute complete meals undermines the statutory definition of a restaurant," Jacobs said, and noted that rule language with these exclusions has been in place since 2010.

The petition, submitted March 3 by Barbara Jones on behalf of White Horse Saloon, argued that prepackaged foods have become more diverse and affordable and should be recognized in the rule definition. Jacobs and other staff told the board that while the availability and acceptance of prepackaged food have changed, the statutory definition of a restaurant emphasizes that complete meals be prepared, cooked and served by the establishment, and public-health safety questions fall to health departments rather than the Liquor and Cannabis Board.

Board members split on next steps. Speaker 6 (Pete) urged accepting the petition and directing a deeper agency review, arguing the industry faces economic strain and the rules have not been revisited in many years: "I believe that we should accept the petition ... we need an economist, not only for this rule, but for others." Staff and other board members raised resource constraints and noted that the legislature has signaled interest in this area; the chair said he did not support moving ahead of the legislature, suggesting agency engagement with lawmakers instead.

Speaker 3 (Ali) moved to deny the petition; the transcript records opposition from Speaker 6 and stated support from other members and the chair. The record does not include a roll-call vote tally in the transcript; the board announced denial. Jacobs said he would provide standard denial language to the petitioner but also encourage her to watch the meeting recording and take suggestions from the discussion about next steps.

What it means: The denial leaves current WAC definitions in place, so prepackaged meals still cannot count alone as a complete meal for licensing classifications. Board members asked staff to continue evaluating the issue informally and to coordinate with other jurisdictions and stakeholders so the agency is prepared if the legislature or the agency prioritizes deeper review.