Guidance Memo | GM-2025-06 (Updated Feb. 13, 2026)

Note: Guidance Memo 2025-06 is updated as of Feb. 13, 2026, superseding the versions published Jan. 2, 2026, and Nov. 19, 2025.
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. Cannabis licensing is ongoing, and manufacturers and cultivators are beginning to produce products. As businesses are still being licensed, OCM recognizes limited current transportation options. In an effort to support the emerging cannabis market OCM issues the following guidance to address these limited options.
Authority

Minnesota Statutes, section 342.28, subd. 1(13)
Minnesota Statutes, section 342.29, subd. 1(14)
Minnesota Statutes, section 342.30, subd. 1(6)
Minnesota Statutes, section 342.31, subd. 1(11)

Guidance
Until March 17, 2026, cannabis microbusiness license holders, cannabis mezzobusiness license holders, cannabis cultivator license holders, and cannabis manufacturer license holders may transport samples of their own cultivated or manufactured products to a Minnesota-licensed cannabis testing facility.

In order to qualify, the license holder must meet the following standards:

Create a manifest that meets the requirements of Minnesota Rules, part 9810.2300, subp. 3A, and maintain the manifest as required by Minnesota Rules, part 9810.2300, subp. 3B.
Equip the transportation vehicle with a storage compartment that meets the requirements of Minnesota Statutes, section 342.42, subd. 5 and submit a photo of the storage compartment to OCM via email to [email protected] for approval. OCM may reject storage compartments that do not meet requirements. The transport vehicle must meet the requirements of Minnesota Rules, part 9810.1500, subp. 17B(2), (3), and (5).
Submit the Vehicle Disclosure Form for Temporary Transport to Testing Facilities to the office via email to [email protected].
Have and attest to holding an active a commercial vehicle insurance policy for the transport vehicle.

What are the storage requirements for a vehicle?
A vehicle must have a storage device secured in the vehicle to prevent the device moving or being readily removed. At a minimum, this means that the device must be attached to the vehicle in a way that cannot be untied or easily cut or broken. The device must include a secure lock on the storage compartment that prevents access without a key, and the products cannot be visible from outside of the vehicle. At a minimum, this means that the device must be durable enough that a person could not bypass the lock by pulling on the device to reach in. The vehicle must also have measures to ensure the products are free from spoilage due to environmental factors such as heat or cold.

Please note that most vehicle trunks do not meet these requirements without modifications.
Metrc guidance
The transporter selection requirement has been turned off for the “Lab Transfer” transfer type when creating a new licensed transfer in Metrc to accommodate this temporary allowance. License holders must use the “Lab Transfer” transfer type when creating a transfer manifest to a lab for this temporary transfer allowance to apply. License holders may not use the "Lab Transfer" or "Lab Transfer with Transporter" types on transfers that do not involve a lab.

If you wish to use a licensed transporter when transferring lab samples to a testing facility before March 17, 2026, you will need to use the transfer type "Lab Transfer with Transporter." This transfer type includes transporter information on the Metrc-generated transfer manifest.