Creating BHO requires an infused product license.

You can run bubble hash with ice water or dry sieve for kief on a grow license since those processes do not mix anything with the bud or THC. That was clarified by Matt Cook.

That is a good point though. Infused Product Manufactures (IPM)can not sell bud or products in a form for smoking. If that is the case, how can they create the caviar ? It can't be made on an OPCL by a grower, and it can't be sold by an IPM.

From HB10-1284:
(9) "MEDICAL MARIJUANA-INFUSED PRODUCT" MEANS A PRODUCT
INFUSED WITH MEDICAL MARIJUANA THAT IS INTENDED FOR USE OR
CONSUMPTION OTHER THAN BY SMOKING, INCLUDING BUT NOT LIMITED TO
EDIBLE PRODUCTS, OINTMENTS, AND TINCTURES. THESE PRODUCTS, WHEN
MANUFACTURED OR SOLD BY A LICENSED MEDICAL MARIJUANA CENTER OR
A MEDICAL MARIJUANA-INFUSED PRODUCT MANUFACTURER, SHALL NOT BE
CONSIDERED A FOOD OR DRUG FOR THE PURPOSES OF THE "COLORADO FOOD
AND DRUG ACT", PART 4 OF ARTICLE 5 OF TITLE 25, C.R.S.

Hmmmm.... Now I'm wondering, can an IPM even legally make BHO for that matter ?