Friendly Reminder: Don’t forget that the feedback for the MN OCM Rulemaking is due by the end of the business day on February 12th! Make your voice heard!

Link to the original MN cannabis laws

Link to the OCM's proposed rule changes released in Jan 2025

Link to public comment, open through Feb 12, 2025 (see discussion to help formulate your response, or reach out)

Carpfish Creative's general insights based on the content of the proposed rules:

• Licensing and Limits:

  • The rules outline specific license types and limits for cannabis businesses, which may be of interest to potential business owners and investors.

  • The current licensing structure may be limited for smaller businesses:

    • Microbusiness yield limits (5,000 sq. ft) are seen as too restrictive

    • Suggestion to increase microbusiness limits to 10,000 sq. ft

    • This change could eliminate the need for centralized mezzobusinesses by adding three (3) microbusiness.

    
    

• Security Requirements:

  • Extensive security measures are detailed for cannabis businesses, including alarm systems, video surveillance, and access controls.

  • The extensive security measures may pose financial challenges:

    • Example: 90 days of 720p video storage for a micro business could cost up to $25,000.

    • This level of security might be disproportionately expensive for smaller operations

      
      

• Cultivation and Manufacturing Regulations:

  • Detailed requirements for cannabis cultivation and product manufacturing are provided, which could impact producers and consumers.

  • The extensive security measures may pose financial challenges:

    • Example: 90 days of 720p video storage for a micro business could cost up to $25,000.

    • This level of security might be disproportionately expensive for smaller operations

    
    

• Product Categories and Potency Limits:

  • The rules define approved product categories and set potency limits for various cannabis products.

  • The 70% potency limit for cannabis concentrates is causing concern:

    • May require manufacturers to adjust current buildout plans, increasing costs

    • Could limit medical-grade pain products to state medical and tribal institutions

    • Potentially creates issues with the social equity format proposed by the OCM

    
    

• Packaging and Labeling:

  • Specific requirements for packaging and labeling of cannabis products are outlined, which may affect both businesses and consumers.

  • Current labeling requirements are seen as overly cautionary:

    • Labeling resembles that used on explosives and other hazardous items

    • Argument that this level of warning is unnecessary for cannabis products

      
      

• Testing and Quality Control:

  • Regulations for testing cannabis products are included, which could be of interest to public health advocates and consumers.

  • The proposed testing regulations may have limitations:

    • Cultivators and manufacturers can specify which products were used in the process

    • Testing facilities are limited to reporting only on those specified metrics to the OCM

    • This could potentially limit the scope and effectiveness of quality control measures

• Delivery and Event Regulations:

  • Rules governing cannabis delivery services and cannabis events are detailed, which may generate public discussion.

  • The rules for cannabis delivery services and events are perceived as vague, potentially leaving room for confusion or misinterpretation.