State Enforcement Tracker: Cannabis Manufacturing Rules, State by State

Department of Cannabis Control (DCC)

• Pesticide testing action levels tightened (DCC-2025-03-R): consolidates pesticide tables into one table with numeric action levels for every listed pesticide; labs must hold limits of quantitation (LOQs) at no more than 50% of each action level. Filed July 27, 2026; took effect October 1, 2026.
• Anti-lab-shopping rules proposed (DCC-2026-02-R): all-party approval before shipping manifests, tighter track-and-trace data entry, Certificates of Analysis on request; explicitly targets potency inflation and lab shopping. Proposed only — hearing held July 21, 2026; DCC estimates fall 2026 through fall 2027.
• Lab enforcement ramping up: DCC's Lab Division is beginning on-site lab inspections and re-verifying test results on already-passed products; labs face suspension or revocation for inaccurate results. September 2026 brought a farm license suspension and four products recalled as adulterated.
• AB 1965 signed (Sept 27, 2026): retailers must provide a product's Certificate of Analysis on customer request, and DCC gains authority to pull products off retail shelves for testing; labs face performance and proficiency testing to check consistency across facilities.
• AB 2250 signed (Sept 27, 2026): qualifying CBN isolate (>99% purity, no THC or synthetics) is excluded from the "cannabis concentrate" definition effective January 1, 2028; track-and-trace expanded and seizure authority clarified for products at unlicensed premises.

Sources: DCC rulemaking page · DCC-2025-03-R Initial Statement of Reasons (PDF) · DCC-2026-02-R notice · Marijuana Herald: AB 1965 / AB 2250 signed

Office of Cannabis Management (OCM)

• Revised testing limits (Feb 9, 2026): homogeneity testing now required for final-form concentrates, edibles, infused liquids, vape cartridges, infused non-edibles, and tinctures — 5 samples per lot regardless of lot size, THC/CBD within 25% of the mean across three consecutive batches.
• Escalating enforcement: first 2026 recall covered 55 lots from ~24 companies after a licensed lab falsely reported Aspergillus and cadmium results; an appellate court restored warrantless inspections and seizures; OCM reported its largest-ever illicit-product seizure and added 10 enforcement positions.
• 200+ adult-use rule amendments in development (cultivation, microbusinesses, administration, enforcement) — running through at least end of 2026; proposed, no effective dates set.
• Stop-work-order dispute in court (Oct 1, 2026): Nonna Farms principals appeared before a judge over an OCM stop-work order blocking sale of thousands of pounds of outdoor-grown cannabis; OCM declined comment.

Sources: OCM testing limits, Feb 9, 2026 (PDF) · MJBizDaily: NY recall over unreliable lab results · Utica OD: Nonna Farms hearing

Dept. of Agriculture (IDOA); Dept. of Financial and Professional Regulation (IDFPR)

• CRTA rule amendments (approved April 14, 2026): labels must show Total THC (THC + THCa × 0.877, calculated by the lab on the COA), all COA cannabinoids above 0.3% by weight or 0.4 mg, and a hemp-content indication; each strain/flavor/scent variation now needs a separate product registration. Label changes compliance deadline: November 1, 2026.
• Testing tightened: 7–15 g representative samples per batch, flower batches capped at 20 lbs; a pesticide failure means full batch recall plus destruction.
• New Illinois Hemp Act, effective November 12, 2026: 0.4 mg combined total THC per container cap, no synthetic cannabinoids, no smokable products, food-safe ingredients only, mandatory pre-sale testing with scannable COA on the label.
• Inspection intensity rising: Metrc became the sole seed-to-sale system July 1, 2025; IDFPR conducted 625 dispensary inspections in FY2025 with the program described as actively growing.

Sources: IDOA CRTA rule update bulletin (PDF) · IDOA Illinois Hemp Act overview (PDF)

Cannabis Control Commission (CCC)

• THC potency-inflation audits launched (~May 2026): labeled THC must test within 75%–125% of the label claim (e.g., a 15% label must test 11.25%–18.75%); non-compliant products can be pulled from shelves and reports sent to the state attorney general.
• Testing regulatory overhaul in motion: a new standalone section of 935 CMR consolidating all testing requirements; first package circulated to testing labs March 2026; public comment opened August 5, 2026; public meeting scheduled for early October 2026.
• Secret Shopper program strengthened (March 2026); Ch. 65 of the Acts of 2026 (cannabis modernization law) ended the medical-market vertical-integration requirement and mandates a testing-policy review with greater public visibility into lab results.

Sources: MJBizDaily: MA potency-inflation checks · CCC testing regulations review

Division of Cannabis Control (DCC)

• Senate Bill 56 enacted, effective March 20, 2026: consolidates adult-use and medical programs; requires DCC to adopt standards for non-marijuana ingredients used in products — and allows prohibiting ingredients that don't meet FDA-style standards.
• Rule Package 7 (testing + product safety) pending: non-marijuana ingredient standards, minimum testing for cannabis intended for further manufacture, expanded batch limits, and reduced testing for plant material destined for processing. DCC guidance from March 2026 anticipated September 2026 effectiveness and urged licensees to stop making non-compliant products now — final adoption unconfirmed as of this writing; treat September 2026 as anticipated, not confirmed.
• Sixth Circuit hemp ruling (Sept 25, 2026): the court partially narrowed the federal injunction in Titan Logistics v. Tischler, reimposing Ohio's DCC licensing requirements on intoxicating-hemp drink and edible sellers under SB 56.
• Packaging limitations rule (1301:18-4-06) took effect October 5, 2026 (secondary source; confirm against Ohio DCC).

Sources: Ohio Rev. Code §3796.09 · Business Impact Analysis, Rule Package 7 (PDF) · THC Farmer: Sixth Circuit hemp ruling

Cannabis Regulatory Commission (NJ-CRC)

• Testing guidelines (approved Feb 2025, in effect since May 2025): maximum test batch cut from 100 lbs to 33.07 lbs; product-type-specific lot sizes; contaminant testing extended to unusable cannabis intended for manufacturing before extraction; anti-lab-shopping rule (same lab and methodology for initial and retention testing); labels must add THCA, CBDA, CBG, CBGA, CBN.
• Intoxicating hemp overhaul: P.L. 2025, c.215 (signed Jan 12, 2026) and P.L. 2026, c.7 (signed Mar 30, 2026) — synthesized cannabinoids prohibited; since April 13, 2026, products above 0.3% total THC or 0.4 mg THC per container are reclassified as cannabis and require a CRC license. Penalties escalate to $10,000.
• Auditor pressure on lab oversight: a 2026 State Auditor performance audit found the CRC "failed to oversee its testing laboratories," recommending independent random-sample verification testing — signaling stricter lab enforcement ahead.

Sources: ROI-NJ: NJ-CRC testing guidelines · Marijuana Moment: NJ hemp restrictions take effect · NJ State Auditor performance audit (PDF)

Cannabis Regulatory Agency (CRA)

• Record enforcement action (Sept 24, 2026): CRA ordered closure and license revocation of Michigan Investments 10 Inc. (Muha Meds manufacturer) plus a record $2 million fine — 31 sustained violations including failure to test product, seed-to-sale tracking failures, missing surveillance cameras, and 16 packages (105.7 lbs) the licensee could not physically locate during an unannounced inspection.
• Active recalls: 786 live rosin units recalled after testing found a banned chemical (Sept 18, 2026); Nuggz Nectar infused drinks recalled over THC over-limit and homogeneity issues (Aug 2026).
• 20 licenses revoked, $2M fine (Sept 29, 2026): CRA revoked 20 medical grower licenses held by GP Holdings LLC (Millie Montana Industries) and imposed a $2 million fine after finding packages manifested as flower contained dirt/mulch-like material, plus untagged inventory, untested transfers, and Metrc violations.
• No new manufacturing/testing rulemaking found in the last 12 months — in Michigan, the story is enforcement intensity, not new rules.

Sources: MJBizDaily: MI record fine and revocation · Michigan Hash Melts recall · CRA: Nuggz Nectar recall advisory · CRA: GP Holdings revocation

Office of Cannabis Management (OCM)

• New adult-use market launching: first state-licensed non-tribal retail sales reached shelves February 2026; all lower-potency hemp edible manufacturers/wholesalers had to be fully licensed by March 31, 2026.
• Manufacturing-process disclosure (SF 2370): manufacturers must disclose all pesticides, fertilizers, solvents, and catalysts — including those used to create artificially derived cannabinoids — to the testing lab. Testing Technical Authority updated July 1, 2026 (trade-press sourced; confirm against OCM's official document).
• Enforcement scaling fast: 15 cannabis inspectors as of Dec 2025 — a >50% increase since 2024 — conducting routine, complaint-driven, and pre-licensure inspections; 120 lbs of illegal flower seized (June 2025); 32,000+ noncompliant edibles (~$811,000) removed from shelves. Out-of-state testing allowed through May 31, 2027.

Sources: SF 2370 (official) · OCM 2026 annual report (PDF) · Fox 9: out-of-state testing extended

Maryland Cannabis Administration (MCA)

• Testing Technical Authority updates, effective July 1, 2025: Vitamin E acetate action limit slashed from <7,000 ppm to <100 ppm; new limits of quantitation for pesticides, residual solvents, mycotoxins, and heavy metals; added QC requirements for all assays; new remediation guidance including retest-request procedures.
• Fall 2025 regulatory package (adopted Feb 10, 2026; effective March 16, 2026): new requirements for processors handling failed product tests, codified hemp-acquisition process, limits on licensee co-location at shared premises.
• Enforcement visibly active: statewide recall of Vireo Health edibles after failed total-coliform tests (recall order date unconfirmed — verify against MCA's recall page); coordinated mystery-shopper hemp-retail enforcement; July 2025 law allows product seizure based on labeling; new misdemeanor offenses for THC products over 5 mg/serving or 25 mg/package ($5,000 fines).

Sources: MCA testing requirements bulletin (PDF) · MCA Fall 2025 reg update summary (PDF)

Marijuana Enforcement Division (MED)

• 2025 final adopted rules (1 CCR 212-3), effective January 5, 2026: contaminant-testing standard reworded; businesses with contaminants may now retest/remediate instead of destroy-only; a reduced-testing program (up to 3 years) for businesses that consistently pass; license renewal moved from annual to biennial.
• Proposed end of manufacturer self-sampling (MED policy forum, Feb 6, 2026): MED would require independent labs or third-party samplers to collect test batches — half of 135 final enforcement actions since Jan 2023 involved self-sampling/testing issues. Proposal only, not adopted.
• Hemp-sold-as-marijuana crackdown announced April 13, 2026; MED acknowledged in May 2026 the scale is larger than publicly disclosed.
• StayCon (Craft) recall — 49 vape products (Sept 25, 2026): DOR/MED and CDPHE issued a health & safety advisory after methylene chloride was found in a botanically derived alpha-pinene flavoring ingredient; products sold at ~405 stores. Our Recall Forensics breaks down the supplier-qualification failure behind it.
• Expanded residual-solvent panel in effect (Sept 28, 2026): MED Bulletin 26-09 added methylene chloride and 16 other substances to the required testing panel.

Sources: MED newsroom · ProPublica: Colorado regulators and lab testing · Marijuana Herald: StayCon recall

Cannabis Compliance Board (CCB)

• SB 157 (signed June 5, 2025): requires representative lot sampling aligned with ASTM D8334/D8334M, minimum sample weights, and tighter "lot" definitions (flower ≤15 lbs) — implementing regulations pending; workshop held Nov 2025.
• R152-24 given final legislative approval (~Sept 24, 2026): sweeping package now through the Legislative Commission — higher delivery limits, lab sample minimum raised from 10 g to 20 g, revised microbials/pesticide/heavy-metals rules, reorganized packaging/labeling and advertising rules, and new tools against unlicensed activity (administrative fines to $20,000, civil penalties to $50,000).
• AB 76 (2025): CCB can now pursue unlicensed cannabis activity directly — administrative fines to $20,000, civil penalties to $50,000.

Sources: SB 157 text (PDF) · R152-24RP1 proposed text (PDF) · Marijuana Herald: R152-24 final approval

Dept. of Health Services (ADHS)

• Consolidated adult-use rules (9 A.A.C. 18) effective July 1, 2026 — no publicized summary of substance changes vs. the prior version found; treat specifics as unverified.
• 2026 recalls: Legacy & Co flower (possible Aspergillus, Feb — rescinded after retesting); Legacy & Co Cheech & Chong infused prerolls (possible Aspergillus, March 18).
• Lab crackdown: ADHS fined Kaycha Labs $88,500 for inaccurate test results and cited Level One Labs for inflated potency; Story Cannabis stopped accepting products tested by those labs for COAs dated on or after October 1, 2026 — that cutoff is now in effect.

Sources: 9 A.A.C. 18 effective rules (PDF) · Arizona preroll recall report

Dept. of Consumer Protection (DCP)

• PA 26-8 (HB 5350) signed May 4, 2026 (+ "fixer" HB 5222, legislature-approved May 6 — governor's signature unconfirmed at time of writing): infused-beverage THC limits rise to 5 mg/container at package stores and up to 10 mg at cannabis retailers, ±10% testing variance allowed, qualified out-of-state labs permitted, ASTM D8441 container symbol — took effect October 1, 2026.
• Cannabis/hemp omnibus (PA 26-100) took effect October 1, 2026; the Sept 29 Putnam smoke-shop seizure (cannabis products, kratom, and cash seized by DCP's Cannabis Control Division with local police) shows active pursuit of unlicensed sales.
• New "Intermediate Hemp Derivative" category: hemp processors may sell high-THC extracts to cannabis and beverage manufacturers beginning 12/1/2026; packaging restrictions reinstated (3-color logos, black-and-white edibles packaging).
• Concentrate potency-cap changes reported inconsistently across secondary sources — verify against the final act text before relying on a number. A dedicated cannabis division was created within DCP in April 2025.

Sources: Shipman & Goodwin analysis (JD Supra) · CT official bill analysis (PDF) · Putnam smoke-shop seizure report

Oklahoma Medical Marijuana Authority (OMMA)

• Permanent rules effective July 11, 2026 (superseded by Aug 28, 2026 emergency rules): prepackaging required for all medical marijuana sold at retail; lab clarifications — labs must follow the current version of manufacturer instructions for use (prompted by a recall where a lab's outdated procedure produced false "passes"), LQC samples each testing day, defined peak-integration rules.
• Enforcement-driven contraction: OMMA attributes a ~2,000-grower license decline to increased enforcement and stricter licensing; the state runs a reference/QA lab and a secret-shopper program for testing-lab oversight.

Sources: OMMA rules page · OMMA 2026 agency rule report (PDF)

Division of Cannabis Regulation (DCR)

• Final-form testing enforcement: May 2026 recall of Local Cannabis Co. live resin/rosin vape cartridges — the concentrates were tested as bulk THC, not in finished form. DCR clarified final-form testing guidance April 30, 2026.
• September 2026: infused pre-rolls recalled after state testing found Aspergillus mold.
• Hemp-derived THC legislation (SB 518 / beverage compromise) remains proposed only, not enacted.

Sources: MoGreenway: final-form testing recall · Missouri pre-roll recall

Oregon Liquor and Cannabis Commission (OLCC); Oregon Dept. of Agriculture (ODA)

• Permanent Order 6-2025, effective January 1, 2026: notarized property-owner consent now required for producer and processor premises (OLCC independently verifies ownership); OLCC's CAMP platform becomes the primary channel for required communications.
• Cannabinoid Hemp Product Registry (HB 4121), effective January 1, 2026, enforcement from June 1, 2026: all hemp products sold to Oregon consumers must be registered, test results accessible to consumers, edible labels follow food-style requirements; expanded inspection powers and license caps (1 per 7,500 residents production/retail; 1 per 12,500 processor/wholesale).

Sources: OLCC Permanent Order 6-2025 (PDF) · ODA hemp registry release (PDF)

Dept. of Health (DOH), medical program

• Adult-use still not enacted (medical-only market); SB 49 (Cannabis Control Board + hemp regulation) was defeated 29–21 in the Senate in June 2026. No draft adult-use manufacturing rules exist.
• Lab data-integrity upgrade: DOH brought an automated LIMS-to-tracking-system test-result upload interface live in August 2025, eliminating manual entry of lab results.
• Sept 9, 2026 Auditor General audit (first-ever review of the medical program's inspections since 2016) found serious gaps — 35 of 103 inspection checklists unretained, delayed enforcement, inadequate corrective-plan review. DOH agreed to all nine recommendations: expect tighter inspection documentation and enforcement.
• 46 businesses charged (Sept 30, 2026): the Montgomery County DA filed felony charges against 46 businesses in 26 municipalities for selling allegedly illegal THC products at smoke shops, convenience stores, and gas stations; a grand-jury report found false lab documents on some products' ingredients.
• Two bills advancing (Sept 29, 2026): Ryan's Law (hospital/hospice medical-cannabis access) cleared a Senate committee unanimously, and the PA Hemp and Cannabinoid Act (hemp THC registration, independent testing, labeling, 21+ sales) is moving.

Sources: Duquesne Law: PA legalization efforts · PA audit findings report · Igniteit: Montco DA charges · Beard Bros: PA bills advance

Liquor and Cannabis Board (LCB)

• Heavy-metals testing expansion to ALL cannabis products is in rulemaking — but still at the preproposal (CR-101) stage as of September 24, 2026, filed June 25, 2025. No effective date.
• R&D testing, batch tracking, COA expiration dates, and harvest-date rules are also all at CR-101 stage only. Nothing in-window has taken effect for manufacturing.

Sources: LCB current rulemaking activity