Minnesota Hemp-Derived Cannabinoid Product Registration Now Open Through August 31, 2025

By Meg Nash

Jun 16, 2025

The Minnesota Office of Cannabis Management (OCM) announced that it has opened a new registration window for businesses seeking to sell hemp-derived cannabinoid products (HDCPs) to consumers. This window is open now through August 31, 2025, allowing previously unregistered businesses to become eligible to sell HDCPs, including hemp-derived THC beverages, during the busy summer season.

After the August 31 deadline, the OCM will not accept new registrations or updates for September.

This announcement is a key step in Minnesota’s transition to a more formal licensing framework for HDCP businesses. According to the OCM, registrants who apply for a Lower Potency Hemp Edible (LPHE) license in October (see more info on this process below) will be allowed to continue operating in compliance with Minnesota Statutes §151.72 until they receive a license. Upon licensure, those businesses must then comply with Minnesota Statutes §342.46, Minnesota Rules part 9810.2503, and other applicable cannabis regulations.

Read on for a summary of the OCM’s Registrant-to-License Holder Conversion Guide for businesses preparing for upcoming changes. This blog also breaks down the key provisions in the 2025 Cannabis Omnibus bill, which introduces new product, packaging, and potency rules that all hemp businesses must understand and incorporate into their compliance plans.

How to Apply for Minnesota LPHE Business Licenses in October

In addition to the updated registration timeline, the OCM has shared important details regarding the upcoming fall licensing window. From October 1 through October 31 the agency will begin accepting LPHE license applications for three categories: lower-potency hemp edible retailers, lower-potency hemp edible manufacturers, and lower-potency hemp edible wholesalers. The last category is a new license type approved by the 2025 Legislature and signed into law by Gov. Tim Walz in May.

Businesses registered prior to April 14 and those newly registered after June 1, 2025, will be eligible to apply during the October licensing period.

OCM will begin enforcement actions against unlicensed sellers after the October application window closes. Enforcement activity will target any business that has not submitted an LPHE license application, is not currently in the cannabis business license application process or has not received a license.

Notably, current registrants who have already undergone an inspection will not be required to complete another pre-licensure inspection, streamlining the process for many applicants.

Key Changes to Minnesota Hemp Product Rules, Packaging, and Operations Under LPHE Licensing

Under current law, only two product types are permitted:

Nonintoxicating cannabinoid products
Edible cannabinoid products (including hemp beverages)

Minnesota’s new framework will allow for an expanded range of products including:

Artificially derived cannabinoids
Hemp concentrate
Hemp-derived consumer products (limited to flower and vapes)
Lower potency hemp edibles (including beverages)
Hemp-derived topical products (which do not require a license to produce or sell)

Lower-potency hemp edibles (LPHEs) will be subject to several new restrictions:

LPHEs may not contain artificially derived cannabinoids other than delta-9 THC
They cannot contain cannabis flower, cannabis concentrate, or cannabinoids derived from cannabis
They must comply with strict serving size and packaging limits
Additional prohibitions are outlined in OCM’s compliance materials

Packaging and Labeling Requirements

Under Chapter 342, additional requirements are imposed for packaging and labeling hemp products, most notably the requirement to include the symbols shown on page 13 of the attachment. We recommend careful review of these requirements and are happy to prepare a comparison checklist to ensure registrants are ready for compliance upon licensure.

Product Testing Requirements

Registrants can continue operating under Minn. Stat, § 151.72, Subd. 4, until they receive a license from OCM. Once licensed, all artificially derived cannabinoids, lower-potency hemp edibles, and hemp-derived consumer products must have a representative sample tested by an ISO 17025-accredited testing laboratory.

Starting on January 1, 2026, all testing must be done by a testing laboratory licensed by OCM. Products must comply with requirements set forth in Minnesota Rules, part 9810.3100, and OCM’s Technical Standards for Sampling and Testing Cannabis Products.

Facility Requirements

Under the current applicable law, products must be displayed behind a checkout counter where the public is not permitted or in a locked case. Licensees will have additional facility requirements under Chapter 342, including posting Notices required under Sec. 342.27, Subd. 6, and maintaining the retail facility in a clean and sanitary manner. Additional information is on page 16 of the attachment.

Location Requirements

Under Sec. 151.72, hemp business registrations are not required to be tied to a physical location. In contrast, Chapter 342 requires a hemp license to be associated with a physical premise. Lower potency hemp edible retailers are also permitted under Chapter 342 to have more than one business location associated with a single license.

Minnesota Lower Potency Hemp Edible (LPHE) Rules for Onsite Consumption, Cannabis Events, and Delivery Services

Onsite Consumption

Current registrants can allow onsite consumption under Section 151.72 if the retailer holds an on-sale license issued under Chapter 340A. Chapter 342 imposes additional requirements for this, including an on-site endorsement from OCM.

Events

Under Sec. 151.72, hemp registrants are permitted to sell hemp products alongside alcohol at off-premises locations, such as street fairs. Once licensed, a lower-potency hemp edible retailer (LPHER) must partner with a cannabis event licensee to sell products at off-premises events.

Delivery

Lower-potency hemp edibles may be purchased for delivery from a licensed LPHE-R with a delivery endorsement. Cannabis delivery license holders are also permitted to deliver LPHE products to consumers but cannot purchase LPHE products for delivery from LPHE-R license holders, only cannabis businesses. To have LPHE products delivered, an LPHE-R must obtain a delivery endorsement for their license or work with a different LPHE-R license holder with a delivery endorsement—additional information on page 20 of the attachment.

New LPHE Wholesaler License and Out-of-State Sales Options for Minnesota Hemp Businesses

Expansion of Permitted Operations for LPHE Manufacturers

Under the updated legislation, LPHE manufacturers are now permitted to:

Manufacture, package and label products that are intended for sale out of state
Store products that are intended for sale out of state
Sell products containing cannabinoids that do not qualify as lower-potency hemp edibles but are compliant with the importing state's requirements to customers outside of the state.
- LPHE licensees that wish to sell products out of state must obtain a hemp product exporter endorsement from the OCM. LPHE Wholesalers can also obtain exporter endorsements.

Under the revised legislation, a new license type was created for LPHE Wholesalers. Licensees are permitted to:

Purchase LPHEs from other cannabis businesses
Sell LPHEs to cannabis businesses
Import LPHEs
Store and distribute out-of-state compliant products

Delivery Updates

Local registration is not required for LPHE retailers with a delivery endorsement if the LPHE Retailer does not operate in a retail location. LPHE Retailers are permitted to obtain delivery endorsements after providing all necessary information to OCM.

Out-of-State Prohibitions

A lower-potency hemp edible manufacturer may only sell or offer for sale products containing cannabinoids to customers outside the state if the products comply with the importing state's requirements.

What Minnesota’s 2025 Cannabis Omnibus Bill Means for Hemp and THC Beverage Businesses

The 2025 Cannabis Omnibus Bill introduces several new requirements that hemp businesses must keep in mind:

Product Form Restrictions

Under the new law, a product containing nonintoxicating cannabinoids, other than an edible cannabinoid product, may be sold for human or animal consumption only if it is intended for application externally to a part of the body of a human or animal. Products that can be consumed by vaporization or combustion, through chewing, drinking, or swallowing, or through injection or application to non-intact skin or a mucous membrane (except sublingual products) are prohibited.

Additionally, products containing any cannabinoid or THC cannot be sold to anyone under 21 years old.

Potency Restrictions

The bill also establishes new potency limits for edible cannabinoid products:

Beverages: Edible cannabinoid products intended to be consumed as a beverage must not contain more than 10 milligrams of any THC in a single container.
Other Edibles: An edible cannabinoid product that is not intended to be consumed as a beverage must contain no more than 5 milligrams of any tetrahydrocannabinol in a single serving and no more than 50 milligrams per package.

Under the new regulatory framework, the definition of a “lower potency hemp edible” specifies that the 5 mg per serving limit for non-beverage edibles and the 10 mg per container limit for beverages applies only to delta-9 THC. Businesses will need to follow this delta-9-specific calculation once licensed.

However, prior to licensure, throughout the summer of 2025, products sold for human or animal consumption must continue to comply with the broader potency limits outlined in Minnesota Statutes §151.72, subd. 5a(f), which includes:

No more than 0.3% total THC of any kind (not just delta-9)
No more than 5 milligrams of any tetrahydrocannabinol per serving
For non-beverage edibles: no more than 50 milligrams of total THC per package
For beverages: no more than two servings per container

Businesses must ensure their product formulations meet these thresholds during the registration period and be prepared to adjust THC calculations once they receive licensure under Chapter 342 delta-9-only.

Next Steps for Hemp Businesses: How to Prepare for Minnesota LPHE Compliance and Licensing

Businesses planning to operate in Minnesota’s hemp-derived market are encouraged to register before the August 31 deadline and begin preparing for the fall license application window. The team at Vicente LLP is available to assist with license application support, facility compliance, testing preparation, product packaging reviews, and strategic planning for delivery, events, or out-of-state sales.

Contact us today to discuss how we can help your business navigate Minnesota’s regulatory transition and position for long-term success.