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Guidance Memo | GM-2026-09

Streamlining Minnesota’s cannabis supply chain

11/6/2026 11:20:23 AM

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​Background

In 2026, the Minnesota Legislature passed a law that merges (streamlines) the currently separated medical and adult-use cannabis supply chains serving the state market. Under the new law, effective Jan. 1, 2027, Minnesota’s definitions of medical cannabis flower and medical cannabinoid products will change. These and other changes to the law maintain the state’s medical cannabis program while improving patient access to medical cannabis and allowing for more efficient business operations. Except for select, high-medical-need products, a cannabis product’s designation as medical or adult-use will be determined at the point of retail sale, rather than at the point of cultivation or manufacturing.

Beginning in 2027, what will stay the same and what will change in Minnesota’s market under a streamlined supply chain?

Before 2027, medical and adult-use cannabis were required by law to be separated at the point of cultivation, meaning a business cultivating both medical and adult-use cannabis had to separate all activities, plants and products. Similarly, businesses participating in both medical and adult-use markets have operated two separate inventories with distinct facility types in Metrc, the state’s seed-to-sale tracking system, under their single cannabis business license.

Beginning Jan. 1, 2027, the two supply chains will merge into one and processes will shift. However, several components of the existing regulatory structure remain the same. Cannabis businesses should review this guidance memo carefully to understand the changes and the related effects on their business. Businesses will be affected differently depending on their endorsements and business activities.

What stays the same?
  • Patients must still enroll in the medical cannabis registry program and consult with a pharmacist or certified medical cannabis consultant (CMCC) before becoming eligible to purchase medical cannabis and medical cannabis products. Patient enrollment is still valid for three years.
  • Cannabis businesses must still obtain medical cannabis endorsements (in addition to their cannabis license) to participate in the medical cannabis program and serve registered medical cannabis patients (referred to as registered patients for the remainder of this document).
  • When purchasing cannabis flower and cannabis products (referred to as cannabis or cannabis products for the remainder of this document) from any business with a medical cannabis retail endorsement, registered patients are exempt from the cannabis excise tax.
  • All products purchased by and for medical cannabis patients must contain the applicable patient-specific labels and medical cannabis designations.
What changes?
  • The point of distinction between medical and adult-use cannabis moves from the point of cultivation to the point of retail sale, meaning cannabis products will be designated as medical cannabis once they are sold to a registered patient or caregiver.
  • While the license and endorsement structure for cannabis businesses remains the same, there are both new requirements and expanded authorizations associated with medical cannabis endorsements. Additionally, the Minnesota Legislature directed the office to identify 1) high-medical-need (HMN) products and 2) HMN areas to better support access to medical cannabis for registered patients across the state.
  • HMN products—identified by the office in Guidance Memo 2026-08 (High-medical-need product list)—must be manufactured by businesses with a medical cannabis manufacturer endorsement and must be made available for retail sale by businesses with a medical cannabis retail endorsement (see below for more information about the medical cannabis endorsements, their requirements for businesses, and the additional activities they allow a business to conduct).
    • Further guidance about HMN areas is forthcoming.
  • A cannabis business with both medical cannabis and adult-use cannabis endorsements may consolidate inventories and business activities, removing previously separated processes. All cannabis businesses currently operating in both the medical and adult-use supply chains will have their product inventories consolidated into one primary facility in Metrc, as explained in Metrc Support Bulletin 75 (Streamlining the Supply Chain).
  • All cannabis businesses (both with and without medical cannabis endorsements) will have their Metrc facility types, Metrc license numbers, and certain procedures for Metrc updated. These updates will be administered by Metrc and OCM.

Authority

Guidance

Beginning Jan. 1, 2027, Minnesota will streamline its medical and adult-use cannabis supply chains and introduce changes to Accela, the state’s business licensing software, and Metrc, the state’s seed-to-sale tracking system. This guidance memo explains what licensed cannabis businesses need to know, how the changes affect their operations, and the steps required for businesses to maintain compliance during the transition. It also provides information about how streamlining will affect the supply chain and important changes to endorsements, product definitions, labeling, retail sales, and tracking processes.

Streamlining changes to Metrc and inventory tracking

To streamline the cannabis supply chains in Metrc, the following updates will be made:

  1. Changes to current Metrc facility types to reflect new endorsements and permissions. All cannabis businesses utilize Metrc facility types and will see the updated names after changes are implemented.
  2. Inventory consolidation in Metrc for cannabis businesses operating in both the adult-use and medical cannabis markets before Jan. 1, 2027. Businesses are affected by this change if they hold a medical cannabis endorsement and operate multiple facilities in Metrc. Metrc Support will consolidate all product inventory into a single Metrc facility on behalf of businesses on a planned timeline and will transfer all unused tags.
  3. New Metrc license numbers will be issued for all cannabis businesses, regardless of license type or endorsements. Existing tags with old Metrc license numbers can be used until depleted. OCM will communicate to affected businesses which of their active Metrc facilities will sunset (legacy facility) and which will remain active (primary facility) in November.

Details about these Metrc updates follow.

1. Changes to Metrc facility types

Which businesses are affected: All cannabis businesses operating in and navigating Metrc are affected.

What will change and when: Metrc Support will manage the update to Metrc facility types directly and will make system changes on Dec. 28. The changes will set up businesses with the appropriate system permissions for the streamlined market in 2027. Transport, delivery, and testing facility types will not be updated.

Cannabis businesses are responsible for ensuring that their operations are consistent with the current law and their current operations and endorsements while the system updates are underway and until Jan. 1, 2027.*

Updates to Metrc facility types are based on the endorsements held by each license holder. For businesses with a medical cannabis endorsement, the Metrc facility type will now end with (M).

  • Cultivation or Cultivation (M) will be assigned to businesses endorsed to cultivate.
  • Manufacturing or Manufacturing (M) will be assigned to businesses endorsed to manufacture cannabis products.
  • Retail will be assigned to businesses endorsed to sell cannabis products to adult-use customers only. Retail (M) or Macro Retail (M) will be assigned to businesses endorsed to make retail sales to patients, caregivers or adult-use customers.
  • Wholesaler will be assigned to a business with a wholesale license. There is no medical cannabis endorsement for a wholesaler.
  • Transport, Delivery, and Testing facility types will not be updated.

*The updated facilities in Metrc reflect the authorized activities allowed for certain licenses and endorsements after Jan. 1, 2027, which include the ability to transfer products across the previously separate supply chains. Businesses should be aware that conducting transfers between supply chains before Jan. 1, 2027, is prohibited under Minnesota Statutes, chapter 342 and Minnesota Rules, chapter 9810—even if the Metrc system appears to allow these actions. Transferring products between supply chains before that date will result in a referral to OCM’s enforcement and compliance team and may lead to an administrative hold, fine, or other penalties.

If businesses need to complete business-to-business sales between Dec. 28 and Jan. 1, 2027, it is their responsibility to confirm that any sales of adult-use products remain in the adult-use supply chain, and medical cannabis products remain in the medical cannabis supply chain.

How businesses should prepare: Businesses that utilize third-party integrators or authorized software (such as a point-of-sale system) to record all required information in Metrc may experience interruptions to connections or integrations following the Dec. 28 system updates. Retail sales by a business cannot resume until the connection between the point-of-sale system and Metrc is reestablished. Businesses should contact their software vendors well in advance to ensure minimal disruption of services.

2. Inventory consolidation in Metrc

Which businesses are affected: Cannabis businesses with one or more medical cannabis endorsements currently operating facilities in both the adult-use and medical cannabis supply chains are affected. Licensed cannabis transporters, cannabis testing facilities, and cannabis delivery services are not affected by this process update. Cannabis businesses that do not currently operate in the medical supply chain will also not be affected by this process.

What will change and when: Metrc Support will manage the inventory consolidation process directly and will make system changes in January 2027 during the scheduled timeline outlined below. OCM will communicate to affected businesses which of their active Metrc facilities will sunset (legacy facility) and which will remain active (primary facility) in November. It is imperative that businesses prepare for the inventory consolidation process by following the steps below. If a business completes the required steps, Metrc Support will consolidate all unfinished packages, unfinished harvest batches, living plants and plant batches, and unused tags into this primary facility. Metrc will deactivate the legacy facility after all inventory is virtually consolidated.

Inventory consolidation schedule

Metrc Support will begin the inventory consolidation process at approximately 7 p.m. on the scheduled date and is expected to complete the updates by 6 a.m. the following day. During this window, normal business operations may be temporarily affected. Metrc Support will complete the inventory consolidation process for the specific facility types as outlined in the schedule below:

  • Retail facilities: Jan. 4, 2027
  • Manufacturer and wholesaler facilities: Jan. 7, 2027
  • Cultivation facilities: Jan. 11, 2027

How businesses should prepare: Businesses should identify the date that Metrc Support will complete inventory consolidation for the facility types the business currently operates. Businesses must complete the following steps for their legacy facility before their scheduled date so Metrc Support can successfully consolidate inventory. The primary facility will not be affected and can continue to operate without interruption.

  • All packages must have a test status of NotRequired, TestPassed, RetestPassed, NotSubmitted, or Remediated. Any other status will cause the consolidation to fail.
  • There must be no packages under administrative hold or administrative recall.
  • There must be no packages listed on a transfer manifest or currently in transit.
  • All processing jobs must be completed or discontinued.
  • All sales must be finalized.
  • All employee permissions must be removed from the legacy Metrc facility.

If the consolidation process is not successful during the planned window because a business has not completed the necessary preparation steps, the business is responsible for coordinating with Metrc Support to schedule and complete the inventory consolidation process by Jan. 15, 2027, and may experience operational interruptions.

Additional recommendations for how businesses should prepare for inventory consolidation

Scheduling lab sample requests:

  • OCM recommends that businesses stop submitting any new lab samples for packages in the legacy facility’s inventory by the end of the day on Dec. 18. However, businesses can continue submitting lab samples for packages from the primary facility throughout the entire inventory consolidation process.
  • If you anticipate any issues, contact metrc.ocm@state.mn.us at least three business days before your scheduled consolidation date.

Internally transferring product:

  • While a business may complete product transfers independently using the standard licensed transfer process, it is not recommended. Instead, the office strongly recommends that businesses wait until their scheduled consolidation date. Assistance may be limited during the transition period, due to the anticipated volume of requests. Waiting also ensures that Metrc Support will be available to assist if issues arise with transferring plants, plant batches, unfinished harvests and unused tags during the process or if a business cannot complete the transfers independently.
  • License holders that initiate internal transfers between the legacy and primary facility before Metrc supported consolidation are responsible for any mistakes, errors, or issues caused by those transfers.
  • Product transfers from the medical to the adult-use supply chain before Jan. 1, 2027, are prohibited. Any such transfer will result in a referral to the enforcement and compliance division and may lead to enforcement action.

Transferring product between unaffiliated licenses:

  • Businesses transferring products to another business between Jan. 1 and Jan. 15, 2027, should verify that the appropriate Metrc facilities (generally, the primary facilities) have been selected. Incomplete transfers will cause the inventory consolidation process to fail, including incoming transfers from other businesses. Businesses will be able to reference other businesses’ primary Metrc license facility numbers—OCM will share additional resources in November.

Historical production and sales data:

  • Businesses will lose all access to historical data from their legacy facility once the inventory consolidation process is complete.
  • Businesses are strongly advised to review the information and records they are required to retain per Minnesota Rules, chapter 9810, and Minnesota Statutes, chapter 342, as well as any data that may support ongoing business operations and also ensure all necessary materials are downloaded in advance.
  • Contact Metrc Support at support@metrc.com if assistance is needed to export or retrieve data.

3. New Metrc license numbers

Which businesses are affected: All licensed cannabis businesses currently operating in Metrc are affected.

What will change and when: Metrc Support will manage the updates to Metrc license numbers directly and will update all licensed businesses’ Metrc license numbers on Jan. 20, 2027, at approximately 12 a.m. OCM will notify businesses of their new Metrc license number in November to help businesses prepare for the transition; however, Metrc Support will not make the change until Jan. 20, 2027, following the inventory consolidation and facility type update processes.

How businesses should prepare: When the change happens on Jan. 20, 2027, it may interrupt the connection or integration between Metrc and other software services. Businesses should contact any software vendors in advance to advise them of the change to minimize service disruptions.

Following Jan. 20, 2027, Metrc license numbers will follow a seven-digit format. This number is distinct from cannabis businesses’ OCM (Accela) license number. When working with other licensed cannabis businesses, OCM recommends that you provide 1) your business name (as listed in Metrc), 2) your Metrc license number, and 3) your OCM (Accela) license number. Supplying all three will help business partners identify the correct facility when completing transfers.

Managing Metrc tags during streamlining changes

Businesses may continue using existing Metrc tags until their current tag inventory is fully depleted. Any Metrc tags ordered and received by a cannabis business before Jan. 1, 2027, will reflect the legacy facility information (which will include the soon-to-be outdated facility name, number or facility type); however, these tags may still be applied to and used on cannabis products. Metrc packages with Metrc tags assigned with existing facility information will not need to be replaced/retagged. There will be a period where both yellow (medical) and blue (adult-use) tags will be used in the same supply chain. For all tag orders placed by a business after Jan. 1, 2027, the business will receive only blue Metrc tags.

Managing product labels during streamlining changes

Per Minnesota Statutes, section 342.63, all cannabis products must be labeled with the license number of the business that cultivated or manufactured the product. A business may include their OCM (Accela) license number or their new Metrc license number to comply with this requirement.

Compliant products manufactured before Jan. 1, 2027, and labeled with the license holder’s previous license number may continue to be sold if the product has not reached its expiration date.

After streamlining changes are implemented on Jan. 1, 2027, cannabis businesses must still obtain medical cannabis endorsements in addition to their cannabis business license to participate in the medical cannabis program and serve registered patients. While the license and endorsement structure for cannabis businesses remains the same, there are both new requirements and expanded authorizations associated with medical cannabis endorsements.

Transition information for businesses with existing medical cannabis endorsements and medical cannabis combination businesses

Licensed cannabis businesses with medical cannabis endorsements and medical cannabis combination businesses currently operating in the medical and adult-use supply chains will be able to maintain their current endorsements during the transition to a streamlined supply chain. OCM will contact each existing business to 1) confirm its intent to maintain equivalent medical cannabis endorsement(s) and 2) communicate new requirements each endorsement will have after Jan. 1, 2027. Businesses must respond to OCM with applicable documentation as requested.

Applicants with preliminary approval that are interested in obtaining medical cannabis endorsements along with their cannabis business license should review the new requirements for endorsements closely before finalizing their application.

Updated license and application numbers

Pursuant to Minnesota Statutes, section 342.295, subd. 9, medical cannabis combination business applicants and license holders will be converted to cannabis macrobusiness applicants and license holders by Jan. 1, 2027. In preparation for application or license conversion, OCM will update the application/license numbers of existing medical cannabis combination applicants and license holders. OCM will make this change in Accela and will communicate directly with medical cannabis combination applicants and license holders regarding this transition to their OCM (Accela) license numbers.

For licensed macrobusinesses, compliant products manufactured before Jan. 1, 2027—and labeled with the license holder’s prior medical cannabis combination license number—may continue to be sold if the product has not reached its expiration date. This includes any products intended to serve registered medical patients, even if they are not formulated as HMN products.

Adding or withdrawing endorsements

Businesses that want to add or withdraw (and no longer operate under) a medical endorsement should request the change after Jan. 1, 2027, by following the steps on OCM’s /ocm/businesses/making-changes/cannabis/index.jspMaking Cannabis Business Changes webpage. There is no fee for adding or removing endorsements.

Medical cannabis cultivation endorsement

Statutory reference: Minnesota Statutes, section 342.51, subd. 1b

Eligible license types: A cannabis microbusiness, cannabis mezzobusiness, cannabis macrobusiness,† or cannabis cultivator with a cannabis cultivation endorsement may apply for and obtain a medical cannabis cultivation endorsement.

†Per Minnesota Statutes, section 342.295, if a cannabis macrobusiness holds or obtains a cultivation endorsement, they must also obtain a medical cannabis cultivation endorsement and are required to participate in the medical market.

Expanded authorizations: Except for a cannabis macrobusiness, a cannabis business with a cultivation endorsement is eligible for expanded canopy size if they obtain the medical cannabis cultivation endorsement and meet the requirements.

  • A cannabis microbusiness with a medical cannabis cultivation endorsement may cultivate an additional 1,000 square feet of cannabis indoors or one-quarter acre outdoors in addition to the limits in Minnesota Statutes, section 342.28.
  • A cannabis mezzobusiness with a medical cannabis cultivation endorsement may cultivate an additional 3,000 square feet of cannabis indoors or one-half acre outdoors in addition to the limits in Minnesota Statutes, section 342.29.
  • A cannabis cultivator with a medical cannabis cultivation endorsement may cultivate an additional 6,000 square feet indoors or one acre outdoors in addition to the limits in Minnesota Statutes, section 342.30.

Requirements for the endorsement: Annually, a cannabis business with a medical cannabis cultivation endorsement must sell at least 25% of the cannabis flower they cultivate to a cannabis business with a medical cannabis endorsement. For microbusinesses, mezzobusinesses and macrobusinesses, this could include cannabis flower transfers to their own manufacturing or retail sites if they also hold a medical cannabis manufacturing or medical cannabis retail endorsement. The new Metrc facility type names will be a key indicator to business partners that selling cannabis to this facility meets this medical endorsement requirement.

Medical cannabis manufacturer endorsement

Statutory reference: Minnesota Statutes, section 342.51, subd. 1c

Eligible license types: A cannabis microbusiness, cannabis mezzobusiness, cannabis macrobusiness,‡ or cannabis manufacturer with a cannabis manufacturing endorsement may apply for and obtain a medical cannabis manufacturer endorsement.

‡Per Minnesota Statutes, section 342.295, a cannabis macrobusiness is required to obtain a medical cannabis manufacturer endorsement and manufacture HMN products.

Expanded authorizations: A cannabis microbusiness or a cannabis mezzobusiness with a manufacturing endorsement is eligible for expanded manufacturing limits of up to 25% above the limit established by the office in rule if they obtain the medical cannabis cultivation endorsement and meet the requirements. A cannabis manufacturer business does not have manufacturing limits. A medical cannabis manufacturer endorsement does not authorize a cannabis macrobusiness to expand the manufacturing limit for that license type.

Requirements for the endorsement: Effective Jan. 1, 2027, all cannabis products manufactured by cannabis businesses with manufacturing endorsements must be either an approved product category identified in Minnesota Rules, part 9810.2100, or identified as an HMN product by the office.

Under the law effective Jan. 1, 2027, cannabis businesses with the medical cannabis manufacturer endorsement are required to manufacture HMN products as identified by the office. For more information on the identified HMN products, refer to Guidance Memo 2026-08 (High-medical-need product list). A cannabis business with this endorsement is required to manufacture at least one of the identified HMN products.

By March 1, 2027, all businesses with a medical cannabis manufacturer endorsement must submit to OCM a revised product list that indicates which products they currently or will manufacture that qualify as HMN products. OCM will review the revised product list submission for approval. Once approved, businesses will have until July 1, 2027, to start manufacturing the identified HMN products.

Metrc item category changes to prepare for HMN product tracking

Metrc has added new item categories that align with the identified categories of HMN products. Businesses with a medical cannabis manufacturer endorsement (authorized to manufacture medical cannabinoid products) should use these for HMN products. Metrc item categories are: ORAL DISSOLVABLE (BULK/PACKAGE), ORAL SOLUTION (BULK/PACKAGED), MEDICAL TINCTURE (BULK/PACKAGED), WATER-SOLUBLE POWDER (BULK/PACKAGED) and PILL (BULK/PACKAGED). Descriptions of each category can be found in Metrc Support Bulletin 78 (Impacts of legislative changes for January 1, 2027). These item categories will be available for use starting Dec. 1.

Businesses that have been previously manufacturing medical cannabis products should review the Metrc support bulletin closely to ensure they are utilizing the new product item categories correctly during the transition.

Understanding statutory changes to the medical cannabis product definition and the effect on manufacturing processes
Updates to medical cannabinoid product formulation requirements

Effective Jan. 1, 2027, medical cannabinoid products may no longer be formulated with artificially derived cannabinoids (see the definition of medical cannabinoid product as amended in the 2026 legislative session, per Minnesota Statutes, section 342.01, subd. 52). To support businesses during the implementation of the streamlining changes, compliant products manufactured before Jan. 1, 2027, may continue to be sold if the product has not reached its expiration date.

Medical cannabinoid products may continue to include cannabis extracts in combination with naturally occurring—not artificially derived—cannabinoids derived from hemp that are designated by the office as non-intoxicating (Minnesota Statutes, section 342.01, subd. 63). Per Minnesota Rules, part 9810.2100, subp. 4, the following cannabinoids are designated as nonintoxicating: cannabichromene (CBC), cannabidiol (CBD), cannabigerol (CBG), and cannabinol (CBN). Businesses manufacturing ratio hemp-infused cannabis products should refer to Metrc Support Bulletin 78 (Impacts of legislative changes for January 1, 2027) for the Metrc tracking process.

Labeling products to comply with medical cannabis requirements

Generally, once the supply chains are streamlined, most products can be sold to either a registry patient or an adult-use customer. However, if a product is sold to a medical registry patient or caregiver, the product must contain the patient-specific label along with the medical cannabis symbol. While retailers are responsible for ensuring any product sold to a registry participant meets these labeling requirements, manufacturers can add the medical cannabis symbol during the manufacturing process for products intended for medical patients only.

For both HMN products and medical cannabinoid products designed for vaporized delivery methods (vape products) that exceed the potency limit established for adult-use vaporized delivery methods in Minnesota Rules, part 9810.2100, subp. 2, OCM recommends manufacturers apply the required medical cannabis symbol to the label before sale to a retailer or wholesaler (Minnesota Rules, part 9810.1402, subp. 1). This ensures that these products are clearly identifiable throughout the supply chain.

Find and download the universal symbols required on labels on OCM’s /ocm/businesses/resources/packaging-and-labeling.jspPackaging, Labeling and Retail Posting Requirements webpage [Minnesota Statutes, section 342.51, subd. 1c(d); Minnesota Statutes, section 342.51, subd. 2(a)(4); Minnesota Rules, part 9810.1402, subp. 1].

Medical cannabis retail endorsement

Statutory reference: Minnesota Statutes, section 342.51, subd. 1d

Eligible license types: A cannabis microbusiness, cannabis mezzobusiness, cannabis macrobusiness,** or cannabis retailer with a retail operations endorsement may apply for and obtain a medical cannabis retail endorsement.

**Per Minnesota Statutes, section 342.295, if a cannabis macrobusiness obtains a retail operations endorsement, they are also required to obtain a medical cannabis retail endorsement and participate in the medical market.

Expanded authorizations: A cannabis business with a retail operations endorsement is eligible for additional retail locations if they obtain the medical cannabis retail endorsement and meet the requirements.

  • A cannabis microbusiness with a medical cannabis retail endorsement may operate one additional retail location, in excess of the limit established in Minnesota Statutes, section 342.28, subd. 2(d), if at least one retail location is in an HMN area.††
  • A cannabis mezzobusiness with a medical cannabis retail endorsement may operate two additional retail locations, in excess of the limit established in Minnesota Statutes, section 342.29, subd. 2(d), if at least two retail locations are in an HMN area.††
  • A cannabis retailer with a medical cannabis retail endorsement may operate up to three additional retail locations, in excess of the limit established in Minnesota Statutes, section 342.32, subd. 2, if at least three retail locations are in an HMN area.††
  • A cannabis macrobusiness is not eligible for additional locations; however, a cannabis macrobusiness with a medical cannabis retail endorsement may operate up to eight retail locations, and if they operate more than five locations, three of those locations must be in an HMN area.††

††Information about HMN areas is forthcoming.

Requirements for the endorsement: A cannabis business with a medical cannabis retail endorsement must:

  • Employ or contract with either a licensed pharmacist or a certified medical cannabis consultant (who has a certificate issued by the office and has completed the required training) to consult and provide final authorization for a person enrolled in the registry program [Minnesota Statutes, section 342.51, subd. 1d(b)].
  • Ensure availability of patient consultations.
  • Ensure that patients and caregivers enrolled in the medical registry program receive priority service.
  • For microbusinesses, mezzobusinesses and retailers, carry all HMN products identified by the office and make the products available to a registered patient or their caregiver within 24 hours of their request.
  • For macrobusinesses, have all HMN products in stock and available for sale (Minnesota Statutes, section 342.295, subd. 5).

If OCM determines a license holder with a medical cannabis retail endorsement has failed to provide HMN products as required for their license type, the license holder could face a penalty up to suspension or revocation of that endorsement.

Retailers with a medical cannabis retail endorsement that are unable to obtain a specific HMN product are encouraged—but not required—to notify OCM of the issue. Voluntary disclosure helps the office better understand emerging supply challenges and supports efforts to maintain consistent access for patients who rely on these products. A product shortage disclosure form will be available on July 1, 2027.

For more information about HMN products as identified by the office, refer to Guidance Memo 2026-08 (High-medical-need product list). To learn more about HMN related Metrc item categories, refer to Metrc Support Bulletin 78 (Impacts of legislative changes for January 1, 2027).

Labeling products to comply with medical cannabis requirements

Retailers with a medical cannabis retail endorsement must be aware that any regulated product sold to a registered medical cannabis patient or a registered caregiver becomes a medical cannabis product at the final point of sale and must have both a patient-specific label and the medical cannabis symbol on the label. If the product label does not already contain the medical cannabis symbol, then the retailer must apply it at the point of sale along with the patient-specific label [Minnesota Statutes, section 342.51, subd. 1c(d); Minnesota Statutes, section 342.51, subd. 2(a)(4); Minnesota Rules, part 9810.1402, subp. 1].

Find and download the universal symbols required on labels on OCM's /ocm/businesses/resources/packaging-and-labeling.jspPackaging, Labeling and Retail Posting Requirements webpage.

Changes to point-of-sale systems

After Metrc makes the streamlining changes on Jan. 20, 2027, retailers authorized to sell to both adult use customers and registered patients will see two options when recording retail sales in Metrc. The Consumer designation must be selected for adult use sales, and the Patient designation must be selected for medical sales. When Patient is selected, Metrc will require entry of the patient or caregiver number associated with the purchase (refer to Metrc Support Bulletin 78 (Impacts of legislative changes for January 1, 2027).

Please consult your point-of-sale (POS) provider for questions on distinguishing patient and consumer sales within your POS system. For requirements related to recording pricing details, refer to Metrc Support Bulletin 55 (Recording Price of Product Sales).

Medical cannabinoid product distinctions for retailers to track

Retailers must be aware that potency limits differ between medical and adult use vape products. Per Minnesota Rules, part 9810.2101, subp. 2, cannabis concentrate products designed for vaporized delivery methods for sale in the adult-use market must not exceed 80% THC potency. The same limit does not apply to medical cannabinoid products designed for vaporized delivery methods (vape products) sold to registered medical cannabis patients. It is the retailer’s responsibility to ensure that products restricted to purchase by and for registered patients are not sold to adult use consumers. The potency information must be listed on the retail product label of all products.

Streamlining implementation timeline

  • By week of Nov. 23: OCM will inform all cannabis businesses of their new Metrc license numbers (which will take effect on Jan. 20, 2027). In preparation for the January 2027 inventory consolidation process, OCM will also inform cannabis businesses operating in both supply chains of their assigned primary and legacy Metrc facilities.
  • Dec. 18: OCM recommends that businesses currently operating in both supply chains stop using their legacy Metrc facility to submit product for testing.
  • Dec. 28: Metrc Support will update facility types based on the endorsements held by each license holder. Businesses must re-establish API connections before the start of business.
  • Jan. 1, 2027: Streamlining effective date. There is no longer a separation between the state’s medical and adult-use supply chains.
  • Jan. 4, 2027 (7 p.m. – 6 a.m. CT): Metrc Support will consolidate inventory of retail facilities (micro, mezzo, retail, and macro license types with retail endorsements) that previously operated in both the medical and adult-use supply chains. Businesses must complete all preparation steps before this date.
  • Jan. 7, 2027 (7 p.m. – 6 a.m. CT): Metrc Support will consolidate inventory of manufacturing facilities (micro, mezzo, retail, and macro license types with manufacturing endorsements) and wholesalers that previously operated in both the medical and adult-use supply chains. Businesses must complete all preparation steps by this date.
  • Jan. 11 (7 p.m. – 6 a.m. CT): Metrc Support will consolidate inventory of cultivation facilities (micro, mezzo, retail, and macro license types with cultivation endorsements) that previously operated in both the medical and adult-use supply chains. Businesses must complete all preparation steps by this date.
  • Jan. 15, 2027: The last date that Metrc can support businesses that have not completed the necessary inventory preparation and consolidation steps.
  • Jan. 20, 2027 (12 a.m. – 6 a.m. CT): Metrc Support will update all Metrc license numbers. Businesses must re-establish API connections before the start of business.

Additional resources