Background

Minnesota’s cannabis market is a closed-loop system, where all cannabis must be tracked from seed to sale to ensure that all products in the supply chain were legally sourced, grown, manufactured and sold. See Minnesota Statutes, sections 342.05, subdivision 1; 342.24, subdivision 5; see also Minnesota Rules, parts 9810.1300 to 9810.1302. Minnesota Rules, part 9810.2000, subpart 9, provides the date by which all license holders engaged in cultivation must ensure compliance with these requirements.

This guidance memo provides direction to license holders authorized to cultivate cannabis on what constitutes an authorized source for cannabis seeds, immature cannabis plants, cannabis mother plants, cannabis plants, and other cannabis plant sources intended for propagation in the statewide monitoring system (Metrc). After December 1, 2025, cannabis cultivators must use propagative materials from a source authorized by the office.

Metrc Support Bulletin MN_IB_0001 (see Metrc Beginning Inventory Guide) provides guidance on how new license holders should begin to tag and report their inventory. In order to bring in inventory, license holders must get credentialed in Metrc and then use an external incoming transfer. External transfers generally require approval by the office; however, after getting credentialed in Metrc, newly licensed/endorsed cultivators will have a 30-day external transfer window to add genetics on hand and previously acquired from authorized sources. After 30 days have elapsed, this window will close. Once the window is closed, a business must either: (1) use their own internal genetics, (2) purchase clones from a business as referenced below, or (3) purchase seeds from a commercial seed seller. The 30-day external transfer window for license holders authorized or endorsed to cultivate who were credentialed in Metrc on or prior to November 30, 2025, will begin on December 1, 2025.

Definitions

Cannabis clones: Cannabis clones shall have the meaning provided in Minnesota Rules, part 9810.0200, subpart 6.

Cannabis seed: Cannabis seed shall have the meaning provided in Minnesota Statutes, section 342.01, subdivision 22.

Farmer-saved cannabis seeds: Farmer-saved cannabis seeds are harvested and replanted from a cannabis cultivator’s own crop for the next growth cycle.

Propagule: Propagule shall have the meaning provided in Minnesota Statutes, section 342.01, subdivision 62.

Guidance for sourcing cannabis clones from authorized sources

A cannabis business purchasing cannabis clones must purchase them from a Minnesota-licensed cannabis cultivator, cannabis microbusiness, cannabis mezzobusiness, cannabis retailer, medical combination cannabis business, or a Tribal cannabis business operating according to an executed Tribal-state cannabis compact.

Cannabis clones may not be imported from other states as “hemp.” Hemp clones are regulated by the Minnesota Department of Agriculture (MDA) Hemp Program under Minnesota Statutes, chapter 18K. Hemp clones are considered propagules. Sale of hemp propagules are regulated by Minnesota Rules, part 1565.1000. Any person selling hemp propagules that do not meet the requirements under the rule cannot claim that the propagules are hemp. Any propagule originating from a parental source that exceeds 0.3% total THC (as defined in Minnesota Rules, part 1565.0200, subpart 48; and 7 CFR Part 990.1) cannot be sold or labeled as hemp. All propagules of hemp must be supported by a certificate of analysis (COA) from an accredited laboratory showing the THCA, delta-9 THC, and the total THC concentration of the parental sources. Any questions about hemp clones should be directed to the Minnesota Department of Agriculture (MDA).

Guidance for sourcing cannabis seeds from authorized sources

Cannabis seeds offered for sale in Minnesota must be properly labeled to meet the requirements of the Minnesota Seed Law (Minnesota Statutes, sections 21.80-21.92). Any person or firm that labels seed for sale in Minnesota must have a Minnesota seed permit and maintain required records for all seed lots. Commercial seeds and seeds for home use are regulated by the MDA Seed Regulatory Program. Any questions about commercial seed should be directed to the MDA. In order to be from an authorized source, seeds purchased from sellers in other states must be compliant with that state’s laws and regulations.

If you have questions regarding cannabis seeds, please contact seed.mda@state.mn.us.

Farmer-saved cannabis seeds that will not be commercially sold as propagative seed are not subject to the Minnesota Seed Law, which means labeling and seed permitting are not required. Farmer-saved seeds are considered approved sources for the purpose of Minnesota Rules, part 9810.2000, subpart 9.

Entering source material in Metrc

Once credentialed, a newly licensed/endorsed cultivators will have 30 days to enter all inventory into Metrc.

There are two types of tagged inventory in Metrc: plants and packages. All plants must enter the system as immature plant batches, whether sourced from clones or seeds.

To add new seed genetics after the 30-day window elapses, cultivators must follow the forthcoming “new genetics” Metrc workflow (once available, the bulletin will be linked in this guidance memo and on Metrc’s Minnesota partnership site). These requests must be approved by OCM.

Once genetic material reaches 8 inches (tall or wide) it must be tagged. Please note that this requirement does not mean that immature plants are not required to be entered into the Metrc; rather, this only determines when the tracked plants must be tagged. Any plant less than 8 inches tall or wide must still be fully accounted for in the Plant Batches section of the inventory tracking system, in accordance with the rules.

Additional resources

• Beginning Inventory Guidelines (MN_IB_0001)
• Enhancements for Cultivators (MN_IB_0031)
• Mother Plants tab – New feature (MN_IB_0043)