​Background

​The Minnesota Legislature passed a law in 2026 that streamlines the medical and adult-use cannabis supply chains. Under the new law, and among other requirements:

• ​The Office of Cannabis Management (OCM) must publish a list of all high-medical-need (HMN) products.
• ​Businesses with a medical cannabis retail endorsement must carry all products identified by the office as high medical need.
• ​Businesses with a medical cannabis manufacturing endorsement must manufacture HMN products.

​The HMN product list was developed based on engagement with medical cannabis patients and their caregivers, legal guardians, and health care practitioners as well as cannabis business license holders that currently or may in the future hold medical cannabis endorsements. In developing the list, the office also relied on a thorough review of existing data sources, including:

• /ocm/assets/OCM_Patient_Priorities_Public_2025_tcm1202-719618.pdf​Medical Cannabis Patient Priorities with Minnesota’s Emerging Adult-Use Market Report
• /ocm/assets/OCMProductUseReport_tcm1202-766976.pdf​Medical Cannabis Use Patterns Report
• /ocm/dmc/health-care-practitioners/guidance-materials/medical-cannabis-studies.jsp​Medical Cannabis Dosing and Chemical Composition Report
• ​Patient purchasing trends identified via Metrc, the state’s seed-to-sale system
• ​Medical cannabis complaints received by the office regarding product availability and access

Authority

• ​Laws of Minnesota 2026, chapter 123, section 97, amending Minnesota Statutes, section 342.51
• ​Laws of Minnesota 2026, chapter 123, section 98, amending Minnesota Statutes, section 342.51
• Laws of Minnesota 2026, chapter 123, section 102, amending Minnesota Statutes, section 342.51
• ​Laws of Minnesota 2026, chapter 123, section 103, amending Minnesota Statutes, section 342.515​

Guidance

Based on engagement and a review of existing data described above, the office developed the list using the following rationale.

Formulations

Required products cover four formulations:

• CBD-only – This formulation is important because some patients—including pediatric, elderly and working patients—need relief from CBD but either cannot have or do not want intoxicating cannabinoids like THC.
• High CBD ratio (1:15 THC:CBD or greater CBD) – This formulation is important because some patients need some THC but predominantly need CBD. This formulation may be used for pediatric, elderly and new medical cannabis patients.
• Balanced ratio (1:1 THC:CBD) – This formulation is important because some patients need the complementary benefits of THC and CBD and a higher dosage of THC than what is available in other formulations. This formulation is common for many patients and can be used as a means to move between other formulations.
• High THC dosage (at least 20 mg THC per serving; CBD may not exceed THC) – This formulation is important because some patients have a high tolerance for THC, for example patients who have used medical cannabis for an extended time. High THC dosage products may be THC-only or have up to as much CBD as THC.

Routes of administration

Required products cover two routes of administration. Enteral products are swallowed and absorbed through the gastrointestinal tract, and oromucosal products are held in the mouth and absorbed through the mucous membranes of the mouth:

• Enteral – This route of administration is important because it has a slower onset but provides longer-lasting relief. Some patients require this route for sustained symptom management over an extended time. Liquid enteral products are important for young children or other patients who struggle to swallow pills or chewable products due to their abilities or medical conditions. To meet varying accessibility needs, enteral administration is divided into two categories: (1) pills and (2) water soluble cannabinoid multiparticulate or oral solution/suspensions.
• Oromucosal – This route of administration is important because some patients require a fast-acting method of relief and cannot use inhalable methods. For example, this could include patients under 21 years of age or 21+ patients who have conditions contraindicated for smoking (e.g., lung cancer, asthma). Oromucosal products include tinctures and orally dissolvable products like lozenges.

HMN products

Many products that patients regularly use and rely on are not included in the list because the office has determined that they are likely to be readily available in a streamlined market. Products identified as HMN are products that patients rely on and are not likely to be sufficiently produced in a streamlined market.

Products identified as HMN may only be sold by a business with a medical cannabis retail endorsement to medical cannabis patients, unless also approved for sale to adult-use consumers. Currently, none of the product types on the list are approved adult-use product types, so listed products can only be manufactured and sold by businesses with a medical endorsement.

HMN products are identified by formulation and route of administration. Businesses with a medical cannabis manufacturing endorsement are statutorily required to manufacture HMN product. Businesses with a medical cannabis retail endorsement must carry products as stipulated in each of the product types, by formulation. Based on available data, the following have been identified as HMN products:

CBD-only

All retail locations with a medical cannabis retail endorsement must carry each of the following CBD-only product types. They can be of any dosage (mg per serving), in the following routes of administration:

• Enteral (water soluble cannabinoid multiparticulate or oral solution/suspension); and
• Oromucosal (orally dissolvable product or tincture).

High CBD ratio (1:15 THC:CBD or greater CBD)

All retail locations with a medical cannabis retail endorsement must carry each of the following high CBD ratio (1:15 THC:CBD or greater CBD) product types. They can be of any dosage (mg per serving), in the following routes of administration:

• Enteral (water soluble cannabinoid multiparticulate or oral solution/suspension); and
• Oromucosal (orally dissolvable product or tincture).

Balanced ratio (1:1 THC:CBD)

All retail locations with a medical cannabis retail endorsement must carry each of the following balanced ratio (1:1 THC:CBD) product types. They can be of any dosage (mg per serving), in the following routes of administration:

• Enteral (pill); and
• Enteral (water soluble cannabinoid multiparticulate or oral solution/suspension); and
• Oromucosal (orally dissolvable product or tincture).

High THC dosage (at least 20 mg THC per serving; CBD may not exceed THC)

All retail locations with a medical cannabis retail endorsement must carry one of the following high THC dosage (at least 20 mg THC per serving; CBD may not exceed THC) product types:

• Enteral (pill); or
• Enteral (water soluble cannabinoid multiparticulate or oral solution/suspension); or
• Oromucosal (orally dissolvable product or tincture).

The office will continually evaluate patient access and product availability to ensure that products identified as HMN are readily available consistent with law and that license holders with medical endorsements are meeting their statutory obligations.

Figure 1. Required High-Medical-Need Products by Formulation

Figure 1 provides an overview of high-medical-need (HMN) products as determined by the office.