Minnesota Marijuana Licensing

What License Types Exist in Minnesota?

Following the legalization of adult-use marijuana in May 2023, Minnesota is currently attempting to establish a new licensure structure for both its medical marijuana program and recreational marijuana industry. While recreational marijuana becomes effectively legal in the state on August 1, 2023, retail sales are not expected to begin until the first quarter of 2025. In the intervening period, Minnesota hopes to license new cannabis businesses and bring both its medical cannabis program as well as the regulation of low-potency hemp edibles under the oversight of the newly established Office of Cannabis Management (OCM).

According to Chapter 342 of the Minnesota Statutes, the OCM will establish these 16 cannabis business licenses:

• cannabis microbusiness
• cannabis mezzobusiness
• cannabis cultivator
• cannabis manufacturer
• cannabis retailer
• cannabis wholesaler
• cannabis transporter
• cannabis testing facility
• cannabis event organizer
• cannabis delivery service
• lower-potency hemp edible manufacturer
• lower-potency hemp edible retailer
• medical cannabis cultivator
• medical cannabis processor
• medical cannabis retailer
• medical cannabis combination business

While, as of July 2023, the OCM is yet to call for applications for these licenses, Minnesota Statutes already defined the scopes of the licenses, established their requirements, and set their application, initial license, and renewal fees.

Cannabis Microbusiness

This license authorizes the holder to grow marijuana plants as well as buy cannabis seedlings and immature plants and hemp plant parts from licensed cannabis microbusinesses, mezzobusinesses, manufacturers and wholesalers. The license limits the plant canopy allowed to a microbusiness to 5,000 square feet for an indoor grow site or half an acre for an outdoor cultivation location.

The licensee can also purchase and buy hemp and cannabis concentrates as well as make synthetic cannabinoids and adult-use cannabis products. The license also allows the holder to buy, package, and sell adult-use cannabis flower, lower-potency hemp edibles and hemp-derived consumer products. Lastly, a cannabis microbusiness can establish a venue where edible cannabis products and lower-potency hemp edibles are consumed onsite. With the right endorsement, a licensed microbusiness can operate one retail location in Minnesota.

Cannabis Mezzobusiness

This license authorizes the holder to conduct the same cannabis activities as a microbusiness but on a larger scale. Therefore, a mezzobusiness license holder can grow marijuana for adult-use cannabis products as well as buy hemp plant parts. Beside cultivation, the licensee can also buy, make, package, and sell hemp and cannabis concentrates, artificially derived cannabinoids, lower-potency hemp edibles, and edible cannabis products.

The mezzobusiness license allows the holder to grow up to 15,000 square feet of plant canopy in an indoor facility or up to one acre in an outdoor location. The license also allows for up to three retail locations. However, a cannabis mezzobusiness licensee cannot operate a venue approved for on-site consumption of cannabis and lower-potency hemp edibles.

Cannabis Cultivator

A Minnesota cannabis cultivator license authorizes the holder to grow marijuana plants as well as package and label cannabis seedlings, immature plants, and flower for sale to other licensed cannabis businesses. The license allows a cannabis grower to cultivate up to 30,000 square feet of plant canopy in an indoor location or up to 2 acres in an outdoor location.

Cannabis Manufacturer

This license entitles the holder to buy cannabis and hemp plant parts and concentrate; cannabis and hemp edibles; and artificially derived cannabinoids from licensed microbusinesses, mezzobusinesses, cultivators, wholesales, and other manufacturers. The license also authorizes the holder to manufacture these cannabis and hemp products as well as package and sell them to other cannabis businesses.

Cannabis Retailer

A cannabis retailer license holder can buy cannabis plant parts, cannabis products, lower-potency hemp edibles, and hemp-derived products from licensed cannabis and hemp businesses for the sole purpose of selling these to the final consumers. In Minnesota, a licensed retailer can have up to five locations.

Cannabis Wholesaler

This license entitles the holder to buy immature cannabis plants and seedlings, cannabis flower, cannabis products, lower-potency hemp edibles, and hemp-derived consumer products from, and sell to, licensed cannabis microbusinesses, cannabis mezzobusinesses, cannabis cultivators, cannabis manufacturers, and cannabis microbusinesses. A cannabis wholesale license also allows the holder to buy hemp concentrate as well as hemp plant parts and propagules from industrial hemp growers and processes.

Cannabis Transporter

A cannabis transporter license is required to move cannabis and hemp plant parts as well as cannabis and hemp products between licensed marijuana businesses in Minnesota. This license authorizes the holder to transport both medical and adult-use cannabis products.

Cannabis Testing Facility

A testing facility license is required for an independent third-party laboratory to obtain and test cannabis and hemp products grown or manufactured by licensed cannabis businesses in Minnesota.

Cannabis Event Organizer

This license authorizes the holder to organize a temporary cannabis event lasting up to 4 days.

Cannabis Delivery Service

A cannabis delivery service license is required by any entity intending to deliver cannabis and hemp products, sold by licensed retailers, to consumers.

Lower-Potency Hemp Edible Manufacturer

This license allows the holder to purchase hemp plant and plant parts as well as hemp concentrate and artificially derived cannabinoids from licensed cannabis and hemp businesses. Licensees can also manufacture hemp concentrate, artificially derived cannabinoids, and lower-potency hemp edibles and sell these to hemp and cannabis businesses in the state.

Lower-Potency Hemp Edible Retailer

Retailers with this license can buy lower-potency hemp edible obtained from licensed cannabis and hemp businesses allowed to manufacture them. Licensees can also sell lower-potency hemp edible to adults aged 21 or older.

Medical Cannabis Cultivator

A medical cannabis cultivator license allows the license holder to grow cannabis plants with a total canopy size of 60,000 square feet and sell the harvest plant parts to licensed medical cannabis processors and retailers in the state.

Medical Cannabis Processor

This license allows the holder to buy hemp plant parts, hemp concentrate as well as medical cannabis flower and concentrate from licensed medical cannabis cultivators and other medical cannabis processors. The licensee can also manufacture hemp concentrate and medical cannabis products to sell to medical cannabis retailers and other medical cannabis processors.

Medical Cannabis Retailer

A medical cannabis retailer license holder can buy medical cannabis flower and medical cannabis products from licensed cannabis businesses in the state and sell these to registered medical cannabis patients at their dispensary location.

Medical Cannabis Combination Business

Licensed medical cannabis combination businesses can grow and buy cannabis plants for medical and adult-use cannabis purposes. They can also manufacture medical and adult-use cannabis products and sell these directly to consumers. This broad license is a cultivator, processor, and retailer license for medical and adult-use markets. A business with this license can only cultivate medical cannabis plants with a maximum plant canopy of 60,000 square feet. A separate area must be designed for cultivating cannabis meant for the adult-use market. This area can be no larger than half of the area reserved for cultivating medical cannabis in the preceding year.