Frequently Asked Questions for Cannabis Businesses

No. Growing both indoor and outdoor simultaneously is prohibited under Minnesota Statutes, section 342.25, subdivision 7, and Minnesota Rules, part 9810.2000, subpart (3)(A). During the application process, an applicant must choose either indoor or outdoor cultivation, not both.

OCM does not maintain a definitive list of specific structures or materials that would count as “indoor” or “outdoor mixed-light" facilities. Generally, if your greenhouse is a permanent structure comprised of rigid walls, then it would not meet the definition of an outdoor mixed-light facility. If ultimately the facility is considered outdoor, then it would require fencing as described in Minnesota Rules, 9810.1500, subpart 15.

Yes. A business authorized to cultivate outdoors may start seeds or clones indoors.  Newly planted seeds or clones must be recorded in Metrc as an immature plant batch. Once the seedlings reach eight inches in height or width, they must be tagged individually with Metrc tags and moved to the approved outdoor location. The indoor facility used to start seeds must not be part of a dwelling. All other applicable zoning and building codes also apply.

No. Once plants reach eight inches in height or width, they must be tagged individually with Metrc tags and entered in Metrc. Once a plant is tagged, it cannot be moved from outdoor to indoor or vice versa. An indoor grower must keep all tagged plants indoors. An outdoor grower must keep all tagged plants outdoors.

Yes. A licensed cultivator may change from indoor to outdoor cultivation (or vice versa) by submitting a new site registration and final plans of record. A license holder may not switch until the new site registration is approved by OCM.

As a first step, the license holder should submit a new site registration in Accela and upload an amended final plan of record, including diagrams, which focuses only on the new cultivation area and plan to be added. A new site registration is required if switching from indoor to outdoor (or vice versa).  

Next, the license holder should email ocm.licensing@state.mn.us to inform OCM that updates have been made in Accela with the proposed changes. All requests for new activities are subject to OCM review, approval, and inspection, as well as local approval of the new site registration. OCM will notify the license holder once/if new activities/plans are approved.  

OCM understands that transporter and delivery businesses generally would not store regulated product. However, Minnesota rules require that in the event regulated product cannot be delivered or returned, the business has procedures in place to properly and safely store those cannabis products.  

Cannabis transporter and delivery workers cannot leave regulated product in a vehicle overnight or outside the operating hours of a cannabis transport or delivery business (Minnesota Rules, part  9810.1500, subp. 17C(3)). Additionally, cannabis businesses must develop procedures for storing regulated products (Minnesota Rules, part  9810.1104). That means  all cannabis businesses, including transporters and delivery, must have a site where they can properly store regulated products.  

In the event a regulated product is in the possession of a transporter or delivery business, and cannot be delivered or returned, the business must have procedures in place to properly and safely store those products. Although it is best practice for delivery businesses to return product as soon as possible, it is not required that the product be returned the same day. If products are not returned the same day, then the products must be placed in a secure storage area at a location that has been approved by the office. Storage requirements are listed in Minnesota Rules, part 9810.1104. This section includes a product storage area that cannot be in a home, is equipped with an alarm and surveillance system, and is in a controlled environment free from contamination.   

Yes. It is not required that the vehicles be stored at the same site as the regulated products.