CANNRA’s 2025 Model Policy for Intoxicating Hemp: Which States Will Adopt It and When

The Rise of the CANNRA 2025 Intoxicating Hemp Model Policy

The regulatory terrain for intoxicating hemp-derived cannabinoids is experiencing a fundamental transformation in 2025. The Cannabis Regulators Association (CANNRA) has unveiled its 2025 Model Policy for Intoxicating Hemp, and statehouses across the country are rapidly responding. With over 80 bills touching THC beverages and intoxicating hemp across 27 states this year, the national conversation has pivoted from mere awareness to urgent action on product safety, consumer protection, and market structure.

Industry observers and compliance professionals are tracking this fast-moving landscape, as states look to the CANNRA framework for legislative guidance and policy templates. In this overview, we’ll break down:

• The core elements of the CANNRA 2025 model policy
• The current and projected state adoption activity
• Major takeaways for licensed operators and product innovators
• The intersection with high-profile measures like California’s AB 8

What’s Inside CANNRA’s Intoxicating Hemp Model Policy?

The 2025 model policy confronts the proliferation of intoxicating hemp products—most commonly through synthetic or semi-synthetic cannabinoids such as delta-8 THC, delta-10 THC, and THCa—often marketed in beverages, gummies, and vape products outside of regulated cannabis supply chains.

Key provisions recommended by CANNRA for state action include:

1. Milligram Cap Per Serving and Per Package

• States are urged to set strict THC caps, often recommend 5-10mg per serving and 50-100mg per package/container limits for all hemp products with psychotropic effect, mirroring those in regulated cannabis markets.

2. Bans or Tight Control on Synthetic Cannabinoids

• Model language prohibits artificial synthesis of cannabinoids not naturally occurring in hemp. Delta-8, delta-10, and THCp, unless directly extracted from the plant, are targeted for restriction.

3. Age 21+ Purchase and Possession

• All intoxicating hemp products would be available only to those 21 and over, with specific restrictions for retail, online, and delivery channels.

4. Online Age Verification Requirements

• Enhanced third-party digital age verification (not self-attestation) is required for e-commerce. Compliance tools like biometric ID checks or government-database crosschecks are strongly encouraged.

5. Dispensary-Only or Age-Restricted Channel Sales

• Many states are drawing from CANNRA’s playbook by mandating that sales occur in cannabis dispensaries or licensed, age-restricted specialty retailers—effectively removing intoxicating hemp from unregulated convenience, grocery, and gas station shelves.

6. Child-Resistant Packaging and Appeal Restrictions

• Requires opaque, child-resistant packaging, bans on cartoon or child-friendly branding, and strict limitations on shapes/flavors that mimic snacks or candy.

7. Comprehensive Product Testing & Total-THC Measurement

• Total THC testing methodology is mandated, capturing the sum of all active THC isomers (delta-8, delta-9, delta-10, THCa, etc.). Products are subject to third-party laboratory analysis for potency, synthetic byproducts, heavy metals, pesticides, and other contaminants.

8. Clear CBD:THC Ratio Requirements

• Products may be required to have a minimum CBD:THC ratio (e.g., 20:1, or higher) to reduce the intoxication profile and deter high-potency items.

9. Enforcement Authority and Penalties

• Expanded regulatory oversight, with powers to seize, destroy, and penalize noncompliant hemp products and operators. Penalties can include license revocation, steep fines, and criminal charges in egregious cases.

States Signaling Adoption: Who’s Leading in 2025?

Tracking state legislative activity, it’s clear the CANNRA model is informing a coast-to-coast regulatory shift, but adoption is happening in phases and with modifications to fit local market conditions.

Leading Adopters and New Legislative Activity

• California: Assembly Bill 8 (AB 8) passed in 2025, positioned as the most influential framework for intoxicating hemp regulation (Read more). AB 8 requires all intoxicating hemp products to be sold through licensed cannabis dispensaries, prohibits synthetics, sets strict potency caps, and hands new enforcement power to state agencies (official text).

  • The California Cannabis Operators Association and trade groups have called this a “blueprint” for national alignment.

• Minnesota, New York, and Maryland: All have moved to restrict intoxicating hemp products to dispensaries or age-restricted specialty channels; bills introduced in 2025 feature THC caps and robust testing mandates.

• Louisiana and Kentucky: Rapidly adopted portions of the CANNRA model after legislative pressure from medical cannabis operators and local law enforcement calling for a clampdown on unregulated hemp beverages and edibles.

• Florida, Texas, and Virginia: Multiple bills in 2025 signal a move toward requiring online age checks and seizing unregistered hemp products under new police powers, with language echoing the CANNRA playbook.

Forthcoming Activity: Special Sessions and Early 2026 Waves

• More than a dozen states—primarily in the South and Midwest—are scheduled for special sessions in Fall 2025 or are expected to carry over bills into early 2026, as opposition and industry pushback slow full-scale adoption of CANNRA provisions. Policy watchers expect these states to reference California’s new law as justification for stricter controls.

• Beverage industry hotspots (notably Michigan, Illinois, and Colorado) are debating separate milligram caps or outright bans on intoxicating hemp beverages, spurred in part by alcohol industry lobbying and concerns over youth access. Proposals mirror the 10mg/serving, 150mg/container standards recommended by CANNRA and adopted in AB 8.

Old Hemp Statutes vs. New Intoxicating Hemp Laws: The State Conflict

The CANNRA model and recent state bills often directly conflict with earlier hemp legalization statutes, which tended to:

• Permit hemp products so long as they were under 0.3% delta-9 THC by “dry weight,”
• Place little or no controls on isomerized or synthetic cannabinoids,
• Allow open online and in-store sales with minimal testing or age-checks.

States now face statutory friction, requiring amendment of existing hemp codes, reconciliation of conflicting testing standards, and creation of uniform enforcement protocols. Stakeholders should anticipate a bumpy transitional period where certain products (e.g., delta-8 vapes, high-THC seltzers) are barred in some states, allowed in others, and in legal limbo where statutes are unclear or under challenge.

The California AB 8 Effect: Bellwether for Major Markets

California’s AB 8 stands as a national reference. The bill not only bans intoxicating hemp products from mainstream retail but also synchronizes hemp regulation with the state’s existing cannabis compliance infrastructure (more on CA AB 8). Key features:

• Retail ban for all intoxicating hemp outside of cannabis shops
• Potency and serving cap enforcement
• Prohibition of synthetic cannabinoids
• Testing requirements that match or exceed those for legal cannabis products

Many anticipate large population states—like New York, Illinois, and Florida—will follow suit in late 2025 or early 2026, citing both public health and market fairness. AB 8 is widely cited in policy circles as the “end of the loophole” for intoxicating hemp.

The Road Ahead — Major Takeaways for Operators and Consumers

• Prepare for Patchwork Regulation: State adoption of CANNRA guidelines is uneven and facing political/industry headwinds. Assume shifting requirements for product formulation, labeling, and distribution.
• Testing and Documentation: Upgraded laboratory testing, total-THC protocols, and precise recordkeeping are now essential for sellers across state lines.
• Channel Controls: National trend is away from unregulated retail; expect more mandatory use of dispensary or verified age-gated online channels.
• Enforcement Is Ramping Up: Many states are granting sweeping new powers to seize illegal product and sanction noncompliance, with criminal penalties possible for willful violations.
• Consumers should expect reduced availability of intoxicating hemp in mainstream retail, more age checks, and product choices that more closely resemble regulated cannabis.

Stay Ahead of CANNRA’s Model and the New Regulatory Climate

The CANNRA 2025 intoxicating hemp model policy is already reshaping the compliance landscape. Businesses, investors, and compliance officers must stay alert to rapid developments, especially as states mobilize for fall special sessions and 2026 carryover bills. With ongoing conflicts between legacy hemp statutes and new intoxicating-product laws, real-time tracking and adaptive compliance are non-negotiable.

For the latest multi-state regulatory tracking, detailed compliance tools, and tailored business insights, visit CannabisRegulations.ai — your partner for mastering the complexities of the post-hemp loophole era.