Guidance Memo | GM-2026-04
Explanation of expiration and best-by dates for cannabis and hemp products
8/17/2026 1:37:34 PM
Overview
This guidance memo provides an explanation for:
- The applicability, use, and calculation of expiration dates and best-by dates, which are required for packaged product labeling.
- The shelf life and expiration of bulk products that are not packaged for retail sale.
Authority
- Minnesota Statutes, section 342.02, subdivision 2(4)
- Minnesota Rules, part 9810.1401, subparts 2C, 3G, 4H
- Minnesota Rules, part 9810.1100, subp. 2A(6)(d)
- /ocm/businesses/resources/product-testing/technical-authority.jspCannabis Technical Authority (CTA), Section 6.9
Background
Minnesota Rules require that all dried cannabis flower products must be labeled with the date the product is best-by and that all ingestible cannabis, lower-potency hemp edible (LPHE) products, cannabis concentrate, and cannabis combination products must be labeled with an expiration date (Minnesota Rules, part 9810.1401, subparts 2C, 3G, 4H). Product that has passed the expiration date on the retail label may not be sold and must be destroyed [Minnesota Rules, part 9810.1100, subp. 2A(6)(d)].
Guidance
Products packaged for retail sales
The expiration or best-by date for all packaged products must be printed on the retail label. Shelf-life should be based on product stability established through stability testing (CTA, Section 6.9) and submitted to the office for approval. An expiration date or best-by date can be calculated by adding the shelf-life stability demonstrated to the date that compliance testing was reported. For example, if eight-month stability is demonstrated for a product tested on Jan. 1, the expiration date would be Aug. 31 of the same year.
Important: Until data have been collected establishing evidence-based expiration dates, a cannabis or hemp product will have expiration date or best-by date span of six months (Minnesota Rules, part 9810.3100, subp. 5F).
If a product undergoes remediation, the expiration date remains from the initial compliance test completion date.
Packaged products past their expiration date may not be sold and must be destroyed. Packaged products past their best-by date do not have a hard stop on sale. Retailers should work with the products’ cultivator or manufacturer to determine the risks of selling past the best-by date related to freshness, potency, and shelf stability.
Bulk products in final form not labeled for retail sale
For products that are processed into a final form but not yet placed into final packaging (for example: vapes, prerolls, deli-style flower, edibles, or tinctures), the expiration or best-by date is determined in the same way as in the corresponding packaged product form. Products past their expiration date may not be sold and must be destroyed. Products past their best-by date can be packaged and sold.
Bulk flower and concentrate products not labeled for retail sales
Bulk flower and concentrate products that are not labeled for retail sale can be considered stable for one year after the date that compliance testing is reported. A stability study is not required for bulk flower or concentrate products. After one year, the product is considered untested. Untested product can be destroyed, or untested bulk flower can be extracted, and the resulting concentrate can be submitted for compliance testing before further use. Untested concentrate can be resubmitted for compliance testing which can extend the expiration date of that concentrate beyond the initial one-year period. Untested concentrate can be combined with other concentrates before the resubmitted compliance testing. Untested concentrate cannot be used to formulate final products.
Metrc guidance
Metrc is used to track the best-by (for flower) or expiration (for concentrates and other products) dates for all packaged products. Best-by and use by terms are considered interchangeable in Metrc. Record all best-by dates in Metrc using the field use by, and expiration dates using the field expiration.
When a user creates a new Metrc package, they must record a use-by date. If this date must be adjusted after the initial entry, the date must be updated for each specific package separately. This process can be done by selecting a package and then selecting Edit Shelf Life. Only Metrc facilities that are licensed for cultivation or manufacturing can edit shelf life. Additional information on how to manage expiration and best-by dates within Metrc can be found in Metrc Support Bulletin 72.
All best-by dates in Metrc should match the retail label. If a packaged product is created in Metrc before compliance testing is completed, it can be assigned a temporary expiration date of no more than six months from date of packaging and updated after compliance testing is complete.
Bulk flower and concentrate products will have an optional expiration date license holders can use to allow for more transparent tracking. It is the responsibility of the business to monitor if bulk flower or concentrate product has expired or has passed the use by date.