July 12, 2025 OMMA Rule Changes 

September 2025

By: John M. Hickey

Transport Licenses & Warehouses

OMMA updated rule 442:10-3-1 to clarify that a medical marijuana business transporter license (not to be confused with a “transporter agent license” which simply allows an individual to transport medical marijuana from one location to another) may maintain and operate one or more warehouses in the state to handle medical marijuana products. The Authority shall issue an annual permit for each warehouse location operated by a license that is tied to the annual medical marijuana transporter license term. There is no limit on the number of permits issued under a single business transporter license.

The holder of the business transporter license may temporarily store medical marijuana products that are tracked and traceable in the seed-to-sale tracking system.  Inventory manifests must show where a product is temporarily being stored.

*NOTE, a business transporter license is a stand-alone license that is subject to the same rules and application process as a processor, cultivation and/or dispensary license.  The only difference is the transporter license is not necessarily attached to a single location.

Additional Filing Fees

Regarding all business licenses that are Tier 2 or higher, beginning November 1, 2025, the applicant has forty-five (45) days from the date the Authority issues an invoice to pay the application fee in full.  Failure to pay the fee timely will result in the denial of the application.

New Packaging Label Guidelines

All packaging must contain a label that reads:

• “Keep out of reach of children."
• “Women should not use marijuana or medical marijuana products during pregnancy because of the risk of birth defects.”
•  “For use by licensed medical marijuana patients only.”

Beginning November 1, 2025, packaging must also contain a label that reads:

•  “It is illegal to drive a motor vehicle while under the influence of marijuana or marijuana products.”

Pre-Packaging Clarification

442:10-7-1 provides clarification regarding pre-packaging requirements. Beginning June 1, 2025, all medical marijuana flower, trim, shake, kief, noninfused pre-rolls, infused pre-rolls, or other flower based product not defined as a concentrate, shall be sold by processors and growers to licensed dispensaries only in pre-packaged form in package sizes weighing not less than one-half (1/2) of one (1) gram to not more than three (3) ounces.  Dispensaries have until November 1, 2025, to sell or waste all current inventory that was received prior to June 1, 2025 and is not in pre-packaged form. By November 1, 2025, all nonconforming product must be sold or transferred to a medical marijuana waste disposal company, and all such sales or transfers should be tracked in the seed-to-sale system.

Product that is sent back to the originating license upon a refusal to accept delivery solely because it is not packaged and labeled in accordance with OMMA rules, shall not be considered medical marijuana waste. If the dispensary cannot refuse to accept the delivery of the nonconforming product or cannot immediately send the product back to the originating licensee, the dispensary shall dispose of the nonconforming product.

If you have any questions or concerns, please feel free to contact a member of our team.