Guidance Memo | GM-2025-03 (Updated Feb. 24, 2026)

Note: Guidance Memo 2025-03 is updated as of Feb. 24, 2026, superseding the versions published Dec. 19, 2025, and Oct. 10, 2025. The product transition period authorized by this guidance memo expired on March 31, 2026.
Background
The Minnesota Office of Cannabis Management (OCM) is charged with regulating both cannabis and hemp markets in bifurcated supply chains under Minnesota Statutes, chapter 342. With cannabis licensing now underway, OCM has begun the application and licensing process for lower-potency hemp edible (LPHE) businesses as passed by the Minnesota Legislature to replace the existing hemp registration process under Minnesota Statutes, section 151.72 – which contained the temporary regulations for what was known as hemp-derived cannabinoid products (HDCPs). The transition from temporary regulations to the permanent statutes and related rules will require changes to business practices.

In order to minimize the market disruptions, on July 2, 2025, OCM announced a product transition period for the cannabis, hemp, and medical cannabis markets. Recognizing the need expressed by hemp businesses for additional time to prepare for the transition to the law’s licensing framework, OCM now issues this guidance memo which clarifies the prior guidance on the product transition period and provides details on when applicants may expect to be licensed.
Summary
To support continuity for existing hemp-derived businesses, this guidance memo provides hemp manufacturers, hemp wholesalers, and hemp retailers with additional time to prepare for the transition to licensure under chapter 342. OCM will issue licenses to hemp retailers on a rolling basis following the October window. OCM will wait to issue licenses to hemp manufacturers and hemp wholesalers until March 31, 2026. This gives additional time to hemp manufacturers and wholesalers to ensure business practices comply with state law. By authorizing licensed hemp retailers, manufacturers, and wholesalers to sell existing products that are tested, manufactured compliant to section 151.72, and labeled with the two required universal symbols, the memo also outlines pathways for existing products to remain on retail shelves through the transition without compromising the public’s health and safety or compliance with statute. Businesses should review the memo carefully to understand how to ensure compliance through the transition.
Licensing timelines
The office opened the window for applications to LPHE manufacturers, LPHE wholesalers, and LPHE retailers on October 1, 2025, and closed the LPHE application window at noon (12 p.m. CDT), Friday, October 31, 2025. The office is reviewing all applications expeditiously to ensure timely conversion from section 151.72 to chapter 342.
LPHE retailers
The office is actively reviewing applications and is issuing LPHE retailer licenses on a rolling basis. Once an application is approved, OCM will invoice the applicant for the license fee, and they will commence operations as an LPHE retailer under section 342.46. Once licensed, LPHE retailers will operate subject to the authorizations and requirements of Minnesota Statutes, chapter 342 and Minnesota Rules, chapter 9810, including the authorized actions below (jump to LPHE retail operations post licensure).
LPHE wholesalers and manufacturers
The office is actively reviewing applications for LPHE manufacturers and LPHE wholesalers and has made requests to applicants for any additional information necessary to complete the application process. However, the office will not issue final approvals to hemp manufacturers and wholesalers before March 31, 2026. On, or immediately after March 31, 2026, the office will invoice LPHE manufacturer and wholesaler applicants for the license fee. Once a license has been issued, they will commence operations as LPHE manufacturers and LPHE wholesalers under sections 342.45 and 342.455 and will operate subject the authorizations and requirements of Minnesota Statutes, chapter 342 and Minnesota Rules, chapter 9810, including authorized actions below (jump to LPHE Manufacturer operations post-licensure and LPHE wholesale operations post licensure).
Cannabis businesses
The office continues to review site registrations for preliminarily approved cannabis businesses. Once licensed, cannabis businesses must operate subject to the authorizations and requirements of Minnesota Statutes, chapter 342 and Minnesota Rules, chapter 9810, including the authorized actions below (jump to Licensed cannabis businesses).
Product transition period
On July 2, 2025, the office issued guidance to the cannabis, hemp, and medical cannabis markets about a product transition period. This period is designed to provide a minimally disruptive transfer between prior governing statutes (section 151.72 and the Therapeutic Research Act) and the new unified regulatory statute (chapter 342). The following guidance clarifies the product transition period and provides additional detail