Guidance Memo | GM-2026-03
Guidance on making external transfers in Metrc for hemp concentrates and/or hemp-derived consumer products
7/9/2026 4:41:40 PM
Overview
This guidance memo provides instructions to licensed cannabis businesses on how to add the following to their Metrc inventory: hemp-derived consumer products (HDCPs) and hemp concentrates used to manufacture HDCPs and combination products. Hemp-derived consumer products (HDCPs) must be tracked by licensed cannabis businesses in Metrc pursuant to Minnesota Statutes, section 342.24, subdivision 5(a). Lower-potency hemp edibles (LPHEs) do not have the same tracking requirement and are not tracked in Metrc by either cannabis businesses or LPHE/hemp businesses.
Background
The Office of Cannabis Management (OCM) must review and approve all requests to add hemp concentrates and HDCPs to a business’s Metrc inventory. If applicable, OCM must verify the requested product is compliant with Minnesota Statutes, section 342.34, subdivision 5(c) by reviewing the certificate of analysis (COA). Each batch must be approved individually.
After approved hemp concentrates are transferred into Metrc, you will need to submit a lab sample for Minnesota compliance testing. You will not be able to manufacture with the product until after it is demonstrated that the product meets the Minnesota testing requirements under Minnesota Statutes, section 342.61 and the Cannabis Technical Authority (CTA).
HDCPs containing only non-intoxicating cannabinoids (CBD, CBG, CBN, and CBC) may be tested by laboratories based outside of Minnesota until May 1, 2027, consistent with Minnesota Statutes, section 342.61, subdivision 1(b).
All other HDCPs containing between 0-0.3% THC must be added to the cannabis wholesaler’s Metrc inventory first and then sent out for compliance testing through Metrc. They must pass Minnesota standards (Minnesota Statutes, section 342.61 and the CTA) before being offered for sale.
Authority
Definitions
Hemp derived consumer product (HDCP): A consumable product containing cannabinoids extracted from hemp. HDCPs must contain less than 0.3% total THC. A lower-potency hemp edible (LPHE) is not an HDCP. Refer to Minnesota Rules, parts 9810.2100, subparts 2-3 and 9810.2101, subpart 2B.
Certificate of analysis (COA): Document that includes results of compliance testing to ensure quality, safety, and that the product meets regulatory standards. Refer to Minnesota Rules, part 9810.3000, subpart 10D.
External transfer: Process within the Metrc system to bring product that was manufactured outside of the “closed-loop system” into Metrc.
Guidance
Effective July 1, 2026, cannabis businesses must follow this process for external transfers of HDCPs and hemp concentrates.
1. Submit an external transfer request to OCM for review using the appropriate form:
Hemp-derived consumer product (HDCP) transfer request form or Hemp concentrates transfer request form.
The submission form includes all of the information needed for OCM to determine if the product is compliant.
2. OCM will review the requests and inform you via email if the external transfer is approved or denied. If denied, OCM will provide the basis. If approved, you will be sent instructions on how to add the product to your inventory.
An online archive of guidance memos issued by OCM is available on our Guidance Memos webpage.