Guidance Memos

Guidance Memo | GM-2026-01

Clarification of authorized activities for cannabis cultivator business license holders

4/10/2026 3:34:50 PM

Overview 

This guidance memo authorizes cannabis cultivator business license holders to purchase immature cannabis plants and seedlings from other licensed cannabis cultivator businesses, cannabis microbusinesses, cannabis mezzobusinesses, or medical cannabis combination businesses. 

Background

The Minnesota Office of Cannabis Management (OCM) is charged with regulating both cannabis and hemp markets in bifurcated supply chains under Minnesota Statutes, chapter 342. Cannabis licensing is ongoing, and cultivators are beginning to cultivate, harvest, package, and label cannabis plants and flower. Minnesota Statutes section 342.30, subdivision 1(3) authorizes cultivators to package and label immature cannabis plants and seedlings for sale to other cannabis businesses; and subdivision 1(4) authorizes cultivators to sell immature cannabis plants and seedlings and cannabis flower to other cannabis businesses. Minnesota Statutes, section 342.30 does not explicitly authorize a cultivator purchasing those same items. In an effort to support the emerging cannabis market and to clarify authorized activities of license holders, OCM issues the following guidance. 

Authority

Guidance 

Until further notice from OCM, licensed cannabis cultivators are authorized to purchase immature cannabis plants and seedlings from other authorized licensed cannabis cultivators, cannabis microbusinesses, cannabis mezzobusinesses, or medical cannabis combination businesses.  

Metrc guidance 

All cultivators are required to record the sale and purchase of immature plants or seedlings in Metrc using the standard wholesale transfer procedure. Review the Metrc Support Bulletin on processors brining new genetics into Metrc for detailed description.