Summary
On January 1, 2026, OLCC’s legislative and technical rule changes related to marijuana will become effective:
Important
Note
The rule links throughout this bulletin will not reflect the updated language until it becomes effective on January 1, 2026. Until that time, use the links above to see the upcoming changes.
The upcoming changes include:
-
Producers/Processors: Annual notarized consent from property owners
-
Producers:
- Privilege updates (transfers; seed and plant samples)
- Removing prohibition on multiple producers under common ownership on a tax lot
-
Retailers: Changes related to proximity to schools
-
All Licensees:
- Trade shows
- Trade samples
- Timeframe to complete applications
- Motion-activated camera systems
- Labeling updates
- Target potency
- “Place of address” requirement
- Authority to operate a license (trustee, receiver, personal representative, security interest)
- Manifest/transfer updates:
- Circular manifests
- Large direct-to-retailer transfers
- CAMP and communication with the Commission
Notarized Property Owner Consent (Producers/Processors)In 2025, the Oregon Legislature passed
Senate Bill 907 (SB 907) which requires an initial or renewal application for a producer or processor to correctly identify the owner of the property. If the applicant is not the owner of the property, the application must also include signed, notarized consent from the property owner for the premises to be used to produce or process marijuana. If an application does not include this, SB 907 requires the OLCC to inactivate the application.
This is an annual requirement. Every producer or processor licensee renewing their license on or after January 1, 2026, must provide this notarized consent (unless the property is owned directly by the licensee of record). A property owner has the option to specify that their consent applies for a period of multiple annual license terms. If they grant their consent for a specific number of license terms, a new consent document is not required until that number of terms has elapsed.
The OLCC is providing a form for the licensee and property owner to fill out:
Producer and Processor Property Owner Informed Consent Form. Unless the property owner is the licensee of record, the notarized consent must be provided on the official OLCC form. This form includes an option to provide consent for a multiple year period.
If a property is owned by more than one person (e.g. if two individuals or two legal entities are named on the property ownership record), each owner must provide notarized consent. If a property is owned by a legal entity, only one individual needs to provide consent on behalf of the entity. OLCC may ask for proof that the person is entitled to give consent on behalf of the entity.
Licensees are encouraged to begin working on meeting this requirement as soon as possible. If there are issues with meeting the requirements, or if there are unusual circumstances where the county recorder’s records do not reflect the correct ownership of the property, licensees are encouraged to work proactively with the OLCC and their county recorder to resolve any issues.
Producer Privilege Updates (Producers)
Multiple producers on a tax lot
These rules remove the prohibition on multiple producers under common ownership being located on the same tax lot. However, the premises security requirements remain the same. Multiple licenses of the same type are still prohibited from utilizing the same or overlapping licensed premises. If a person proposes to hold two or more producer licenses on the same tax lot, each producer must still have a distinct licensed premises that meets all premises security requirements.
Producer-producer transfers
In 2025, the Oregon Legislature passed
Senate Bill 558 (SB 558). Among other changes, SB 558 allows producers to transfer marijuana to other producers, regardless of whether the producers are under common ownership. This includes transfers of usable marijuana, kief, whole harvested plants, and mature plants. Transfers of immature plants and seeds between producers were already permitted.
This privilege does not change the testing requirements, which are set by the Oregon Health Authority (OHA). Marijuana and usable marijuana must still comply with
OAR 333-007-0320.
Seed and plant samples
Additionally, SB 558 allows producers to provide limited amounts of immature plants and seeds to worker permit holders who perform work on their behalf. These limits are established in
OAR 845-025-1330(3):
- Up to four immature marijuana plants per month.
- Up to ten marijuana seeds per month.
These changes
do not allow a worker permit holder to exceed the statutory limits on marijuana possession.
All immature plants and seeds transferred to a worker permit holder must be recorded like a quality control sample (see Tracking samples in the Cannabis Tracking System, below). Any plants that are part of a cultivation batch must be packaged so the package adjustment can be recorded.
Proximity to Schools (Retailers)In 2025, the Oregon Legislature passed
Senate Bill 162 (SB 162) which changed the restrictions around the proximity of retailers to schools. This essentially reverses the changes from 2022
Senate Bill 1522 (SB 1522), which added kindergarten and prekindergarten programs provided by a school district or education service district.
The rules now only limit proximity to public schools for which attendance is compulsory under ORS 339.020 and private or parochial schools as described in ORS 339.030(1)(a). A map of schools can be accessed on OLCC’s website:
Interactive Map of Schools and Retailers.
Trade Shows (All Licensees)SB 558 also expanded licensee privileges at promotional events and trade shows. Licensees will have the privilege to sell or transfer products to one another and provide trade samples to other licensees and their employees. Trade shows and promotional events still require pre-approval from OLCC. A licensee must submit the Marijuana Promotional Event Application through
CAMP and receive approval prior to holding an event. Only licensees who are specifically approved and agree to the control plan for the event may participate.
Distribution of samples at promotional events are limited to licensees and employees who hold a valid worker permit.
Samples cannot be distributed to members of the general public who do not hold a worker permit. Note that consumption of marijuana items, hemp items, and alcohol is still prohibited in the approved area for a trade show or promotion event, so samples cannot be consumed at the event.
Licensees approved to participate in a promotional event may transport the following amounts of marijuana and marijuana items to the event:
- 25 pounds of usable marijuana
- 4 mature marijuana plants
- 100 immature marijuana plants
- 1,000 seeds
- 16 ounces of cannabinoid concentrates or extracts
- 2,500 units of sale of cannabinoid products
All participating licensees must generate a printed transport manifest in CTS that accompanies all marijuana items or hemp items for the duration of the promotional event. Manifests should include all the information associated with any typical transfer manifest and include the job number assigned to the promotional event in the CAMP system. The job number should be documented in the “Notes:” section of the manifest.
Marijuana or marijuana items, including trade samples, transferred to another license must be removed from the original manifest and immediately added to a new manifest. This means that licensees participating in promotional events with the intent to transfer product while at the event site must have access to their CTS accounts while on-site in order to make the required changes in CTS and to provide a “spin-off” manifest to receiving licensees. Licensees participating in promotional events should plan to have the necessary equipment to accomplish these tasks (e.g. laptop, portable printer).
Trade samples transferred to a worker permittee at a promotional event must be recorded by editing the manifest to remove the package containing the trade sample, recording the package adjustment, then adding the package back to the original manifest if any units remain in inventory. When providing samples to worker permit holders, licensees must record the worker permit number of the worker permit holder receiving the sample and the date and time the sample was provided to the worker permit holder.
Worker permittees receiving trade samples are not required to receive a manifest from the transferring licensee. The transferring licensee is responsible for making all adjustments to their CTS account.
Failure to properly track marijuana items or hemp items is a Category III violation. An intentional violation is a Category II violation.
Licensees participating in an approved Promotional Event are categorized as:
- “Event organizer” – the licensee who submits a promotional event application and serves as the primary contact with the OLCC.
- “Participating licensee” – a licensee who has been named as a participant in a promotional event application.
One participating licensee listed on the application must be identified as the event organizer. Participating licensees and the event organizer may be charged with any violations of Marijuana Promotional Event rules or any other applicable rules while working at a promotional event representing a recreational marijuana license.
Trade Samples (All Licensees)
Typical Trade Samples
SB 558 included some major changes to how trade samples are handled. Rather than being limited to a specific quantity per licensee, the limit is now based on the number of worker permit holders receiving samples. For ordinary trade samples, each worker permit holder can receive up to the following amounts:
- 5 grams of usable marijuana or usable hemp per harvest lot per strain per month.
- 1 unit of packaged cannabinoid concentrates or hemp concentrates per process lot.
- 1 unit of packaged cannabinoid extract or hemp extract per process lot.
- 1 unit of packaged cannabinoid product or hemp cannabinoid product per process lot.
Units of packaged concentrates, extracts, and products must comply with the ordinary limits on the amount of THC per container.
Ordinary trade samples are still required to pass compliance testing in order to be eligible for distribution. The labeling requirements also remain the same: products must include a statement that reads “TRADE SAMPLE NOT FOR RESALE” and include the product identity, UID, and net weight or contents of the sample.
Any producer, processor, wholesaler, or retailer may provide trade samples to a worker permit holder who do work on their behalf, subject to the limits above. Any producer, processor, wholesaler, or retailer may also provide trade samples to another producer, processor, wholesaler, or retailer for the purposes of the receiving licensee providing those trade samples to their employees.
Trade samples for the purpose of quality control or product development
The rules around “quality control samples” have also changed. Going forward, quality control samples are treated as a subset of trade samples in order to implement the language of SB 558. However, licensees who are eligible to distribute these samples can continue to handle them differently than an ordinary trade sample.
If a producer or processor is providing a trade sample of a marijuana item that they produced or processed to their own worker permit holders for the purpose of quality control and product development:
The limits per worker permit holder are higher:
- Producers:
- 1 ounce of usable marijuana per harvest lot per strain.
- 5 grams of kief or cannabinoid concentrates per process lot.
Cannabinoid concentratesmay only be processed by a micro tier producer with a concentrate endorsement.
- 4 immature marijuana plants per month.
- 10 marijuana seeds per month.
- Processor:
- 5 grams of cannabinoid concentrates or hemp concentrates per process lot.
- 5 grams of cannabinoid extracts or hemp extracts per process lot.
- 12 individual units of cannabinoid products or hemp cannabinoid products per process lot.
- The item is not required to have passed compliance testing.
- The item is not required to comply with trade sample labeling requirements.
Note that in-house testing procedures that result in destruction of product (for example, in-house potency testing for quality control purposes) is not recorded as a trade sample. Trade samples are samples that are provided to a worker permit holder to be removed from the licensed premises. Destruction of in-house test samples should be recorded as an ordinary package adjustment. Samples that are sent out for QC testing should be recorded as a QC sample package in CTS and sent to the laboratory on a manifest.
Tracking samples in the Cannabis Tracking System
Although quality control samples and trade samples are now both considered “trade samples,” the tracking requirements for these samples remains largely unchanged. The only difference is that, beginning January 1, 2026, licensees no longer need to record the name of the permittee receiving a sample. Information on creating and recording trade sample and quality control sample packages can be found at
https://wiki-or.metrc.com/trade-sample-quality-control.
When transferring a sample from the inventory of the license to a worker permit holder, this is recorded as a Package Adjustment with the “reason” of either Trade Sample (for typical trade samples) or Quality Control (for samples provided by producers or processors to their own workers for the purpose of quality control or product development). When recording the transfer, a separate adjustment entry must be made for each worker receiving a sample to include the worker permit number of the person receiving the sample as part of the package adjustment entry.
Only producers may provide samples of immature plant or seeds to worker permit holders who perform work on behalf of the producer. Other license types may not provide samples of immature plants or seeds. No licensee may provide a sample of a mature marijuana plant.
- Immature plants: The plants must first be “packaged” in CTS in order to record the sample adjustment. If the plants are in an immature batch, the plants that will be provided as samples must first be moved to “vegetative” in CTS. A plant tag does not need to be assigned. Once the plant or plants are tracked as “vegetative,” they may then be “packaged” and associated with a package tag. Once packaged, they may be adjusted for the reason of “Quality Control” as described above. Producers should not use the “destroy plants” option to track samples of immature plants, as this misrepresents the information recorded in CTS. A package tag must be used.
- Seeds provided as quality control samples must be packaged as an “each” item prior to distribution to employees.
Transfer and Manifest Updates (All Licensees)
More time
These rules double the amount of time allowed for deliveries. A delivery vehicle can take up to 120 hours to deliver marijuana items to all destinations and return any remaining marijuana items to the premises of origin. The previous limit was 60 hours.
Circular manifests
In 2020, OLCC adopted rules to create a framework for “Circular Manifests” where the ultimate destination is the same as the origin, and the driver makes sales delivery visits at intermediary stops where they may create a new manifest to record any portion of the original manifest that is being delivered to the license at that intermediary location.
These rules make changes to the “circular manifest” privileges and requirements:
-
Larger manifests. A “circular manifest” may now contain up to:
- 75 lbs of usable marijuana (previous limit was 25 lbs)
- 3 lbs of concentrate or extract (previous limit was 1 lbs)
- 10,000 units of sale of any individual cannabinoids product (previous limit was 1,000)
-
Tracking. When generating a new manifest for a delivery at an intermediary stop, the new manifest must reference the manifest number of the original manifest in the Notes field.
Large direct-to-retailer transfers
Direct-to-retailer transfers will now be able to depart as soon as the manifest has been generated. The rules previously required manifests for some direct-to-retailer transfers to be generated 24 hours in advance depending on the quantity of marijuana items being transported. The 24 hour requirement is being removed in these rules.
Labeling Updates (All Licensees)
Target potency
These rules formalize longstanding practices around target potency information on labels. A label may include information about the intended potency of the item (e.g. “100 mg THC” on a marijuana edible label). Listing a target potency is not required, but if one is included, it must be on the principal display panel. Generic labels may not use a target potency. These updated rules apply to all products where a target potency is used. Licensees should carefully evaluate whether to use a target potency.
To compliantly use a label with a target potency, the actual potency of the item based on laboratory testing must be within 10% of the target potency. If the actual potency is outside this range, the label would be considered misleading and in violation of OLCC packaging and labeling rules. For example, a label that features a target potency of 100mg THC and has actual lab calculated values of 90mg THC would be compliant. In this example, anything less than 90mg would not be complaint. See OARs
845-025-7000 (definition of “target potency”) and
845-025-7030 (principal display panel and misleading).
“Place of address” requirements
These rules remove the requirement to include the “place of address” on labels for cannabinoid products other than cannabinoid edibles, tinctures, or capsules. This change primarily impacts inhalable cannabinoid products like inhalable cannabinoid products with non-cannabis additives (or “flavored vapes”) and infused pre-rolls. See OAR
845-025-7120.
On and after January 1, 2026, removing the place of address on an approved label for products labeled according to OAR
845-025-7120 does not require pre-approval. OAR
845-025-7160(8) allows you to remove non-required information on your pre-approved label without resubmission and pre-approval. On and after January 1, 2026, you may remove this information without requesting a label amendment in CAMP.
Edibles, tinctures, and capsules
are still required to include the place of address for the processor, and for the business that packaged the item if different from the processor. Note that this does not need to be the licensee’s premises address. “Place of address” means the name, mailing address, city, state, and zip code of the business. See OAR
845-025-7000 for the definition of “Place of address.”
Nutrition information formats
Reminder: On and after January 1, 2026, marijuana and hemp edible labels are required to use modern nutrition templates. This is
not a new rule. The rule requiring updated templates was adopted in December 2024. Updating nutrition templates
requires resubmission and pre-approval, which can be done in CAMP via the amendment process. See the nutrition templates
here (starting on page 2).
Motion-Activated Camera Systems (All Licensees)Historically, OLCC has required- licensees to have camera systems that continuously record 24/7. These rules include amendments to OAR
845-025-1450 that will allow licensees to use motion-activated camera systems that only store video for periods of time where motion is detected or while people are present in the areas where camera coverage is required.
In order for a motion-activated camera system to satisfy the video recording requirements, it must record and store all intervals of video where motion is detected, including all times when a person is present within an area where video coverage is required. All areas where video coverage is required must be within the zones of detection where the camera system is capable of recognizing motion. Additionally, the sensitivity and triggering threshold must be kept at a level that will record continuously without interruption any time a person is in view of the camera within the licensed premises.
Any licensee intending to change their security system should submit a premises alteration amendment.
Other Changes (All Licensees)
Timeframe to complete applications
As OLCC has worked to streamline the licensing process, OAR
845-025-1135 has identified clear timeframes to complete the application process. Prior to these rule changes, this has included affording applicants two opportunities to work with a license investigator: if the applicant did not complete the application process within 60 days, they would be placed on hold and later re-assigned for an additional 60 days.
The licensing program has now reached a point where this two-opportunity process is no longer necessary. The OLCC expects applicants who submit an application are ready to complete the application process. Applicants who are unable to do so are free to submit a new application when they are ready to move forward. This process will eliminate the extra administrative work and timeline uncertainty from separately managing first-opportunity and second-opportunity assignments for all license applications.
Authority to operate a license
OAR
845-025-1260 specifies the requirements for trustees, personal representatives, receivers, or secured parties to obtain Temporary Authority to Operate from the Commission. This rule was updated with minor technical changes for clarity, as well as adding a requirement for submission of an email address for communications. Additionally, the rule was updated to permit a personal representative up to 30 days following the death of a licensee to operate the marijuana business (provided that the information needed to obtain a Temporary Authority to Operate has been submitted) - reflecting the Commission’s recognition that obtaining formal appointment of a personal representative often takes longer than the 10 days previously specified in the rule.
CAMP and communication with the Commission
Historically, OAR
845-004-0065 has detailed the requirements for communications between the Commission and alcohol licensees, permittees, and other alcohol-related stakeholders. Now that both marijuana and alcohol stakeholders (licensees, permittees, certificate holders, etc.) use CAMP as the primary method of communicating with the Commission, this rule needed to be updated to reflect that practice. The scope of this rule has been expanded to include both marijuana and alcohol stakeholders to ensure consistency throughout OLCC’s regulatory programs.
These changes complement similar amendments to OAR
845-025-1145 regarding communication with the Commission, however the changes do not generally affect the process for designating authorized representatives that can receive information on or make changes to a license or application.