June 19, 2025
The period from June 10-19, 2025, featured significant regulatory activity across multiple states in the cannabis and hemp industries, with key developments in licensing frameworks, hemp product regulations, and federal appropriations actions. During this nine-day span, Montana implemented critical licensing deadlines that will cap market expansion, Mississippi's Attorney General issued a major opinion restricting hemp consumables, North Carolina advanced comprehensive hemp regulation legislation, and federal lawmakers moved forward with changes to hemp product definitions. These regulatory changes reflect the ongoing evolution of state cannabis programs and the continued efforts by lawmakers to address regulatory gaps in hemp oversight, while highlighting the persistent differences between state and federal cannabis policy approaches.
Montana: Senate Bill 27 implementation created a definitive "footprint freeze" requiring all new cannabis facility license applications to be complete by June 30, 2025, fundamentally capping market expansion.
Mississippi: Attorney General Lynn Fitch issued a landmark opinion on June 11, 2025, effectively prohibiting the sale of most hemp consumable products without FDA approval, creating immediate market uncertainty.
North Carolina: House Bill 607 and Senate Bill 265 advanced through committees, establishing comprehensive hemp THC product regulation with age restrictions, potency limits, and testing requirements.
California: The state's emergency ban on hemp-derived THC products was extended through June 2025, maintaining prohibition on manufacturing and selling any detectable hemp-derived THC products.
Oregon: Senate Bill 162, a comprehensive cannabis omnibus bill addressing licensing, enforcement, and market access issues, received legislative leadership signatures and awaits gubernatorial approval.
Federal: House Appropriations Committee advanced FY2026 agriculture appropriations language targeting the federal hemp definition to exclude products with "quantifiable amounts" of Total THC.
The period from June 10-19, 2025, marked a significant week of regulatory activity across multiple states in the cannabis and hemp industries. Key developments included Montana's implementation of critical licensing deadlines, Mississippi's Attorney General issuing a landmark opinion on hemp consumables, North Carolina's advancement of comprehensive hemp regulation legislation, and federal congressional committee actions targeting hemp product definitions. These developments reflect the ongoing evolution of state-level cannabis regulation and the increasing urgency among lawmakers to address regulatory gaps in hemp-derived products.
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Montana's Cannabis Control Division implemented the final phase of Senate Bill 27, which takes effect July 1, 2025, creating what regulators term a "footprint freeze" of the legal marijuana industry. The legislation requires all applications for additional licensed locations to be complete by June 30, 2025, with the Cannabis Control Division recommending submission by June 20, 2025, to allow adequate processing time through the TAP system. This represents one of the most significant structural changes to Montana's cannabis market since legalization, effectively capping the number of licensed facilities that can operate in the state.
The regulatory framework established under SB 27 creates a definitive deadline structure that will fundamentally alter market dynamics in Montana. Applications not considered complete by the June 30 deadline will be automatically denied starting July 1, 2025, with no appeals process or extensions available. The Cannabis Control Division has clarified that a complete application must include all required statements, forms, diagrams, operation plans, supporting documents, and the nonrefundable processing fee. This strict interpretation leaves no room for incomplete submissions or pending documentation, creating significant pressure on prospective licensees to ensure full compliance before the deadline.
The long-term implications of Montana's licensing freeze extend beyond immediate market entry barriers to fundamental questions about market competition and consumer access. Industry analysts suggest this regulatory approach may create artificial scarcity that could drive up cannabis prices while potentially limiting innovation and market responsiveness. The freeze also raises questions about how Montana will address future market demands, population growth, or changes in consumption patterns without the ability to license new facilities. Legal challenges to the footprint freeze are anticipated, particularly from prospective licensees who may argue the regulation creates an unconstitutional barrier to market entry or violates interstate commerce principles.
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On June 11, 2025, Mississippi Attorney General Lynn Fitch issued a comprehensive legal opinion addressing the legality of hemp-derived consumable products in response to questions from Representative Lee Yancey. The opinion concluded that Mississippi law prohibits the sale of non-FDA approved hemp-derived products designed for human ingestion or consumption, effectively banning most hemp consumables currently available in the retail market. This interpretation represents a significant shift in Mississippi's approach to hemp regulation and creates immediate compliance challenges for retailers and distributors operating in the state.
The Attorney General's opinion specifically addresses three critical questions: the legality of selling non-FDA approved hemp products for human consumption, the authority of state agencies to regulate such products, and the interaction between state hemp laws and federal regulations. The opinion concludes that while Mississippi law does not explicitly address hemp consumables, the state's Medical Cannabis Act creates a regulatory framework that implicitly prohibits non-medical cannabis products. This interpretation effectively creates a legal gray area where hemp products that were previously considered legal under federal law may now face state-level prohibition, creating significant uncertainty for businesses operating in Mississippi's hemp market.
The practical implications of this opinion extend beyond immediate compliance concerns to broader questions about state authority over federally legal hemp products. The opinion acknowledges its own limitations, noting that it represents legal guidance rather than binding law, but retailers and distributors are likely to treat it as authoritative given the Attorney General's enforcement authority. Industry stakeholders are calling for legislative clarification, particularly given that Representative Yancey's 2025 legislation to regulate intoxicating hemp products died in committee earlier this year. The opinion may prompt renewed legislative efforts in the 2026 session, but until then, Mississippi's hemp industry faces significant regulatory uncertainty that could impact business operations, investment decisions, and consumer access to hemp-derived products.
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North Carolina lawmakers made significant progress on comprehensive hemp regulation during the week of June 10-19, 2025, with both House Bill 607 and Senate Bill 265 advancing through committee processes. These bills represent the state's most comprehensive attempt to regulate hemp-derived consumable products, establishing age restrictions, potency limits, testing requirements, and retail regulations. House Bill 607, titled "Regulate Hemp Consumable Products," sets specific THC limits for different product categories, including a 10-milligram limit per serving for liquid products and 100 milligrams per package, while also establishing comprehensive testing requirements for cannabinoids, pesticides, and other contaminants.
The legislative framework proposed in these bills creates a sophisticated regulatory structure that addresses multiple aspects of hemp product safety and market access. The bills establish 21 as the minimum age for hemp product purchases, create specific penalties for underage possession or consumption, and require comprehensive product testing for a range of substances including various THC isomers, pesticides, and potentially harmful additives like diacetyl. The legislation also addresses retail licensing, product labeling requirements, and establishes enforcement mechanisms through existing state regulatory agencies. This comprehensive approach reflects North Carolina's attempt to balance consumer access with public safety concerns, particularly regarding youth access to intoxicating hemp products.
The advancement of these bills during this reporting period signals North Carolina's commitment to establishing a regulated hemp market rather than pursuing prohibition. The legislation's progress through committee suggests bipartisan support for regulation over prohibition, which could serve as a model for other states grappling with similar hemp regulation challenges. However, the bills still face potential amendments and final passage votes, and industry stakeholders are closely monitoring specific provisions related to testing requirements, potency limits, and retail restrictions. The successful passage of this legislation could position North Carolina as a leader in hemp regulation, potentially influencing regulatory approaches in neighboring states and contributing to the development of national best practices for hemp product oversight.
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During the week of June 10-19, 2025, the House Appropriations Committee advanced the fiscal year 2026 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Bill, which includes significant language changes affecting the federal definition of hemp. The proposed legislation aims to close what lawmakers describe as the "hemp loophole" by refining the federal definition to include only naturally occurring, naturally derived, and non-intoxicating cannabinoids while excluding products with "quantifiable amounts" of Total THC. This represents a significant shift from the current 2018 Farm Bill definition and could have far-reaching implications for the hemp industry nationwide.
The appropriations bill language specifically targets hemp-derived products containing THCA (tetrahydrocannabinolic acid), which can convert to psychoactive THC when heated, addressing what regulators consider a regulatory gap in current federal law. Representative Andy Harris (R-MD) led the subcommittee markup on June 5, arguing that the current hemp definition allows for the production and sale of intoxicating products that circumvent state cannabis regulations. The proposed changes would require hemp products to contain no quantifiable amounts of any form of THC, effectively eliminating many hemp-derived products currently available in the market, including popular delta-8 and delta-9 THC products derived from hemp.
The implications of these federal changes extend beyond immediate market impacts to fundamental questions about the future of hemp regulation and interstate commerce. If enacted, the appropriations bill language could override state hemp laws and create a uniform federal standard that eliminates most intoxicating hemp products from the market. Industry groups are mobilizing opposition to these provisions, arguing that they exceed the scope of appropriations legislation and should be addressed through comprehensive Farm Bill reauthorization rather than budget measures. The timing of these federal actions, coinciding with increased state-level hemp regulation efforts, suggests a coordinated approach to addressing perceived regulatory gaps in hemp oversight. However, the ultimate fate of these provisions remains uncertain, as they must survive the full appropriations process and potential legal challenges from affected industry stakeholders.
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California's emergency ban on hemp-derived THC products, originally implemented in 2024, was extended through June 2025 during this reporting period, maintaining the state's prohibition on manufacturing, distributing, and selling products containing any detectable level of hemp-derived THC. This extension continues California's aggressive stance against intoxicating hemp products and reinforces the state's position that such products should be regulated through the licensed cannabis market rather than the unregulated hemp market. The ban affects a wide range of products, including hemp-derived beverages, gummies, vapes, and other edibles containing any measurable amount of THC, regardless of the source plant.
The regulatory framework underlying California's hemp THC ban reflects the state's broader approach to cannabis regulation, which emphasizes comprehensive oversight through licensed operators rather than allowing parallel unregulated markets. State regulators argue that hemp-derived THC products undermine the integrity of California's regulated cannabis market by providing consumers access to intoxicating products without the safety testing, taxation, and oversight required for licensed cannabis products. The ban also addresses concerns about youth access, product safety, and tax revenue protection, as hemp-derived products typically avoid the substantial taxes imposed on licensed cannabis products.
The extension of California's hemp THC ban during this period signals the state's commitment to maintaining strict separation between regulated cannabis and hemp markets, potentially influencing regulatory approaches in other states. Industry stakeholders continue to challenge the ban through legislative and legal channels, arguing that it exceeds state authority over federally legal hemp products and creates unfair market advantages for licensed cannabis operators. The ongoing nature of this regulatory conflict highlights the broader tension between state cannabis regulation and federal hemp law, with California's approach representing one of the most restrictive interpretations of state authority over hemp products. The ban's continuation also creates compliance challenges for multi-state hemp operators who must navigate California's unique regulatory environment while operating in other states with more permissive hemp laws.
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Oregon's cannabis regulatory landscape saw significant development during this period with the advancement of Senate Bill 162, an omnibus cannabis bill that addresses multiple aspects of the state's cannabis regulatory framework. The legislation, which received signatures from both the Senate President and House Speaker during this reporting period, awaits Governor Tina Kotek's signature to become law. The bill includes provisions addressing law enforcement priorities, regulatory streamlining, and market access issues that have been pending resolution since the 2025 legislative session began. The bill's near-certain passage represents a significant update to Oregon's cannabis laws and reflects ongoing efforts to refine the state's regulatory approach based on operational experience since legalization.
The omnibus nature of SB 162 addresses multiple regulatory gaps and operational challenges that have emerged in Oregon's cannabis market over recent years. Key provisions include modifications to licensing requirements, updates to enforcement mechanisms, and clarifications of regulatory authority between state and local jurisdictions. The bill also addresses labor peace agreement requirements, which have been a contentious issue in Oregon's cannabis industry, and includes provisions designed to streamline regulatory processes for existing licensees. These changes reflect Oregon's maturation as a cannabis market and the state's ongoing efforts to balance regulatory oversight with industry operational needs.
The timing of SB 162's advancement during this reporting period coincides with broader discussions about cannabis market sustainability and regulatory efficiency in mature cannabis markets. Oregon's approach to omnibus cannabis legislation could serve as a model for other states seeking to address multiple regulatory issues through comprehensive legislative packages rather than piecemeal reforms. The bill's expected passage also demonstrates continued bipartisan support for cannabis market refinement in Oregon, suggesting that the state's cannabis industry has achieved sufficient political stability to support ongoing regulatory improvements. Industry stakeholders are closely monitoring the final implementation of SB 162's provisions, as they could influence operational strategies and compliance requirements across Oregon's cannabis supply chain.
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The regulatory developments from June 10-19, 2025, reveal several significant trends in cannabis and hemp regulation across the United States. Most notably, there is an increasing divergence between state approaches to hemp-derived products, with some states like California and Mississippi moving toward prohibition or strict limitation, while others like North Carolina are developing comprehensive regulatory frameworks. This divergence reflects the absence of clear federal guidance on hemp-derived intoxicating products and the varying political and economic considerations affecting state-level policy decisions. The trend toward state-specific regulation creates significant compliance challenges for multi-state operators and suggests the need for federal clarification or intervention.
The period also demonstrated the increasing sophistication of state cannabis regulation, with states like Montana implementing complex licensing frameworks and Oregon advancing comprehensive omnibus legislation. These developments suggest that cannabis regulation is moving beyond basic legalization frameworks toward more nuanced approaches that address market maturation, competitive dynamics, and operational efficiency. The regulatory sophistication evident in these recent developments indicates that cannabis law is becoming a specialized area of regulatory practice, requiring detailed knowledge of both federal and state frameworks as well as industry-specific operational considerations.
The regulatory changes implemented during this period create significant operational and strategic challenges for cannabis and hemp businesses operating across multiple jurisdictions. Montana's licensing freeze fundamentally alters market entry strategies and could affect property values, investment decisions, and competitive positioning in that state's cannabis market. Mississippi's Attorney General opinion creates immediate compliance uncertainty for hemp retailers and distributors, potentially requiring rapid inventory adjustments and operational changes. North Carolina's advancing hemp legislation offers potential market opportunities but also requires preparation for new compliance requirements and regulatory oversight.
The federal appropriations committee actions targeting hemp definitions represent perhaps the most significant potential impact, as they could affect hemp operations nationwide and override state-level regulatory frameworks. Industry stakeholders must prepare for potential federal changes while navigating existing state-level requirements, creating complex compliance scenarios that require sophisticated legal and regulatory expertise. The cumulative effect of these changes suggests that the cannabis and hemp industries are entering a period of increased regulatory complexity that will require enhanced compliance capabilities and strategic flexibility to navigate successfully.
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The regulatory developments from June 10-19, 2025, demonstrate the dynamic and increasingly complex nature of cannabis and hemp regulation in the United States. The period saw significant state-level actions that will affect market access, product availability, and compliance requirements across multiple jurisdictions. These developments underscore the ongoing evolution of cannabis law and the need for industry stakeholders to maintain sophisticated regulatory monitoring and compliance capabilities.
The divergent approaches taken by different states during this period highlight the continued absence of comprehensive federal guidance on cannabis and hemp regulation, creating a patchwork of state-level requirements that challenge multi-state operators and create consumer confusion. The federal appropriations committee actions suggest potential future federal intervention, but the timing and scope of such intervention remain uncertain.
Industry stakeholders should closely monitor ongoing regulatory developments and prepare for continued regulatory evolution across multiple jurisdictions. The sophistication and complexity of recent regulatory changes suggest that cannabis and hemp law will continue to require specialized expertise and strategic planning to navigate successfully. The period from June 10-19, 2025, will likely be remembered as a significant moment in the ongoing evolution of cannabis and hemp regulation in the United States.
