AHAA Weekly Policy Report: December 31st, 2025
Year-End Regulatory Activity Across Cannabis, Hemp, and Agricultural Policy
The final full week of 2025 brings significant regulatory developments affecting the cannabis and hemp industries nationwide. AHAA tracked 16 policy items across 9 jurisdictions, with states finalizing key regulations before year-end and federal executive action on medical marijuana research. Wyoming implements comprehensive hemp production rules, Michigan advances marijuana retailer licensing caps, and New Jersey creates a federal-aligned framework for hemp-derived cannabinoid products.
Key Highlights
Federal Level:
Presidential Executive Order on Medical Marijuana Research
Hemp-derived Product Market:
Federal executive order expands medical marijuana and CBD research efforts
Wyoming finalizes hemp production and processing regulations
Alabama Restricts Hemp Product Sales to Pharmacies
Medical/Recreational Product Markets:
Michigan introduces cannabis retailer license caps tied to population density
New Jersey aligns hemp product regulations with federal standards
Florida establishes harvest failure protocols for medical marijuana treatment centers
Florida Veterans Medical Marijuana Fee Reduction
Massachusetts Modernizes Cannabis Control Structure
New Jersey Cannabis Regulatory Commission Restructuring
Ohio Comprehensive Cannabis Reform (Awaiting Governor)
District of Columbia Medical Cannabis & Streatery Program
Federal Executive Action
Presidential Executive Order on Medical Marijuana Research
Document: Presidential Document 2025-23846 (Executive Order 14370)
The White House issues an executive order directing expanded research and improved access to medical marijuana and cannabidiol (CBD). The order emphasizes FDA findings supporting marijuana's medical use for chronic pain, chemotherapy-induced nausea, and anorexia associated with wasting diseases. Key provisions include support for HHS recommendations to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act and addressing the regulatory framework for hemp-derived cannabinoid products currently outside controlled substance classification but subject to FDA oversight. The order notes that nearly 15% of seniors use CBD, with many reporting improvements in chronic pain management, highlighting the gap between widespread use and current medical knowledge regarding risks and benefits.
Hemp-Derived Cannabinoid Product Regulatory Updates
Wyoming Establishes Comprehensive Hemp Framework
Regulation: Chapter 61: Rules Pertaining To Hemp (Emergency Notice) - Effective December 23, 2025
Wyoming Department of Agriculture finalizes emergency regulations governing hemp production and processing statewide. Key provisions include:
Licensing Requirements:
License fees determined by application type
Criminal History Reports required for all Key Participants
Licenses valid for calendar year of approval, expiring December 31
2025 licensees may extend expiration to April 15, 2026, by submitting renewal documents before year-end
Processing & Storage Standards:
Each batch must be tested by a Certified Laboratory to ensure THC compliance
Detailed record-keeping required for inspection
Non-compliant cannabis must be disposed of per outlined methods
Storage regulations govern hemp handling and security
Compliance & Enforcement:
Department authority to deny or revoke licenses based on violations
Licensees responsible for non-compliant product disposal costs
Corrective action plans required for regulatory violations
Appeal process available with specified timelines
These regulations impose rigorous requirements on hemp processors, potentially leading to increased operational costs but establishing clear compliance standards for Wyoming's hemp industry.
New Jersey Creates Federal-Aligned Hemp Framework
Bills: NJ A 6295 | NJ S 4509 (Passed Both Houses 57-7-6)
New Jersey enacts comprehensive legislation creating a regulatory framework for hemp-derived cannabinoid products aligned with federal standards. S 4509 passed the Assembly with substitution for A 6295 on December 22, 2025, repealing previous intoxicating hemp laws.
Key Provisions:
Licensing Categories:
Cannabis cultivators, manufacturers, wholesalers, retailers, delivery services, and testing facilities
Each category requires compliance with specific health and safety standards
Diversity promotion for businesses owned by socially and economically disadvantaged community residents
Clear definitions for hemp-related terms and regulatory requirements
Financial Framework:
Revenue allocation to special fund for social equity investments and underage prevention programs
Licensing fees and cannabis sales taxes generate state revenue
Support for educational initiatives and economic development in designated impact zones
Job creation opportunities within regulated cannabis and hemp industries
Operational Requirements:
Strict advertising restrictions preventing minor-targeted marketing
Security protocols for employee and consumer safety
Comprehensive record-keeping and reporting mandates
Testing and labeling compliance for all hemp-derived products
Market opportunities for compliant agriculture, retail, and manufacturing businesses
Bill Forecast (S 4509): 95% Assembly floor vote, 64% Assembly passage | 95% Senate floor vote, 76% Senate passage
Read NJ A 6295 | Read NJ S 4509
Alabama Restricts Hemp Product Sales to Pharmacies
Bill: AL SB 1 (Read First Time - January 13, 2026)
Alabama introduces legislation restricting sales of nonpsychoactive consumable hemp products to licensed pharmacies certified by the Alabama State Board of Pharmacy. The bill also classifies psychoactive hemp derivatives as Schedule I controlled substances. First reading occurred January 13, 2026, with referral to Senate Committee on Healthcare.
Key Provisions:
Distribution Restrictions:
Consumable hemp product sales limited to licensed pharmacies only
Products must derive from hemp cultivated within Alabama
Laboratory testing and certificate of analysis required prior to sale
Seed-to-sale tracking system for cultivation through retail
Controlled Substance Scheduling:
Psychoactive hemp derivatives classified as Schedule I drugs
Alabama Department of Forensic Sciences determines synthetic controlled substance analogue qualifications
Notifications sent to Alabama Department of Public Health for scheduling
Exceptions for substances with approved new drug applications or investigational use exemptions
Industry Impact:
Increased operational costs for testing and compliance
Market access limited to pharmacy-licensed retailers
Enhanced consumer protection through rigorous oversight
Potential market contraction for non-pharmacy hemp retailers
Effective Date: Upon enactment (prior consumable hemp distribution and sale restrictions repealed)
Bill Forecast: 30% House floor vote likelihood | 29% Senate floor vote likelihood
Cannabis & Marijuana Regulatory Updates
Cannabis Licensing & Market Structure
Michigan Marijuana Retailer License Caps
Bills: MI HB 5442 | MI HB 5443 (Tie Bar Package)
Michigan advances legislation establishing population-based limits on marijuana retailer licenses effective January 1, 2026. The cannabis regulatory agency will cap retailer licenses at one per 5,000 residents in each municipality, although this limitation does not apply to license renewals or transfers of existing licenses.
Key Provisions:
Agency Responsibilities:
Oversee commercial production and distribution oversight
Process license applications for retailers, processors, and growers
Conduct compliance inspections and public engagement
Establish health and safety standards including testing and labeling requirements
Mandate warnings on packaging for pregnant or breastfeeding women
Collect licensure fees and violation fines
Zoning & Ownership Restrictions:
Marijuana establishments prohibited in exclusively residential zones
1,000-foot buffer from schools (reducible by municipal ordinance)
Ownership limitations prevent simultaneous interests in multiple business types
Specific caps on number of growers and microbusinesses per owner
Application Priority:
Initial applications limited to Michigan residents or medical marihuana facilities licensing act holders
Focus on promoting participation from communities disproportionately affected by prohibition
Background checks required for all applicants
Resort District Provisions (HB 5443):
Municipalities may apply for resort district designation
Additional retailer licenses available for qualifying tourism-based areas
Denied applicants in resort districts may seek exemptions with adequate capital demonstration
Applicant information confidential under Freedom of Information Act exemption
Bill Forecast: 35% House floor vote likelihood, 25% House passage | 42% Senate floor vote, 49% Senate passage
Read MI HB 5442 | Read MI HB 5443
Michigan Medical Marijuana Provisioning Center Limits
Bill: MI HB 5444 (Tie Bar with HB 5442, 5443, 5441)
Companion legislation applies similar population-based licensing caps to medical marijuana provisioning centers beginning January 1, 2026. The cannabis regulatory agency will limit new provisioning center licenses to one per 5,000 residents per municipality, with exemptions for resort district applicants demonstrating need for additional centers.
Regulatory Framework:
Licensing for growers, processors, provisioning centers, secure transporters, and safety compliance facilities
Stringent applicant criteria requiring extensive personal and business information
Background checks and fingerprinting for financial and criminal history compliance
Annual license renewals contingent upon timely applications and fee payment
Public meeting records and annual reporting to governor and legislature
Bill Forecast: 35% House floor vote likelihood, 25% House passage | 42% Senate floor vote, 49% Senate passage
Florida Harvest Failure & Wholesale Transfer Protocols
Regulation: 64ER25-4 MMTC Harvest Failures And Wholesale Transfers - Effective December 22, 2025
Florida Department of Health establishes emergency rules governing wholesale marijuana transfers following harvest failures at medical marijuana treatment centers (MMTCs). The regulation addresses losses from natural disasters, equipment malfunctions, pest infestations, contamination, flooding, or fire.
Certification Requirements:
MMTCs must obtain Department certification for wholesale transfers following harvest failures
Completed form and supporting documentation due within 30 days of incident
One harvest failure certification per cultivation facility per twelve months (natural disaster exceptions apply)
Active dispensing requirement: eight consecutive weeks of marijuana distribution to qualified patients prior to request
Transfer Procedures:
Wholesale transfer request form submission within 30 days of certification
Documentation in MMTC's internal seed-to-sale tracking system
Acquiring MMTCs must comply with all testing and labeling standards
Transfers approved before December 22, 2025, must complete within 90 days
Financial Implications:
MMTCs responsible for managing financial losses
Disposal costs for non-compliant products borne by licensees
Certification and transfer process administrative costs
Florida Veterans Medical Marijuana Fee Reduction
Bill: FL HB 887 (Filed for 2026 Regular Session)
Florida proposes reducing medical marijuana registry identification card fees for qualified veterans from standard rates to $15 for issuance, replacement, or renewal. Effective July 1, 2026.
Eligibility Documentation:
DD-214 discharge form
Department of Veterans Affairs identification card
Uniformed Services identification card with retired status indicator
Florida driver license with veteran designation
Policy Objectives:
Reduce financial barriers for veteran patients
Enhance medical marijuana program participation among veteran population
Recognize military service through healthcare cost reduction
Bill Forecast: 41% floor vote likelihood in both House and Senate chambers
New Jersey Adds Sickle Cell Anemia as Qualifying Condition
Bill: NJ A 913 (Passed Both Houses 37-0)
New Jersey authorizes medical cannabis for treating sickle cell anemia, expanding qualifying medical conditions. The legislation passed the Senate unanimously on December 22, 2025, following earlier Assembly approval.
Industry Impact:
Increased patient eligibility pool
Higher demand for medical cannabis products
Revenue growth for cultivators, manufacturers, and dispensaries
Academic medical center research opportunities on cannabis applications
Bill Forecast: 74% Assembly floor vote, 72% Assembly passage | 88% Senate floor vote, 87% Senate passage
Massachusetts Modernizes Cannabis Control Structure
Bill: MA H 4206 (Conference Committee Appointed December 24, 2025)
Massachusetts advances comprehensive cannabis law modernization establishing a three-member Cannabis Control Commission with enhanced oversight authority. Conference committee appointed to reconcile House and Senate versions.
Commission Structure:
Three appointed commissioners overseeing cannabis regulatory compliance
Social equity promotion within industry operations
Medical marijuana establishment licensing and regulation
Consumable CBD product sale management
Advisory Framework:
Cannabis advisory board with stakeholder representation from cultivation, manufacturing, retail, social justice, and public health sectors
Independent testing laboratory requirements for product safety compliance
Code of ethics preventing commissioner conflicts of interest
Regulatory Oversight:
Hemp beverage and consumable CBD product licensing for manufacturers and retailers
Product registration processes and financial operations oversight
Compliance measures including enforcement actions and penalties
Ongoing studies assessing cannabis use financial impacts on healthcare system
Bill Forecast: 95% House floor vote, 64% House passage | 95% Senate floor vote, 85% Senate passage
New Jersey Cannabis Regulatory Commission Restructuring
Bill: NJ S 4847 (Senate Amendment December 22, 2025)
New Jersey reforms Cannabis Regulatory Commission membership and marketplace regulations. Senate amended the bill by voice vote on December 22, 2025.
Commission Reforms:
Five-member commission appointed by Governor, Senate President, and Assembly Speaker
Members required to have relevant experience in law, business, public health, or social justice
Strict Code of Ethics prohibiting conflicts of interest
Employment restrictions for commission members and staff
Licensing Framework:
Detailed operating plans required from all license applicants
Community impact and social responsibility considerations
Priority for residents of designated "impact zones"
Reserved license portion for microbusinesses
Initial 24-month limitations on cultivator, manufacturer, wholesaler, distributor, and retailer licenses (alternative treatment center exemptions)
Municipal Authority:
Local governments empowered to regulate establishment numbers and locations
Existing medical cannabis dispensaries may apply for retail licenses without additional municipal approval if co-located with compliant dispensaries
Cannabis Delivery Services:
Permitted under specific conditions including municipal approval
Certification requirements for individuals handling, transporting, and delivering cannabis
Social Equity Provisions:
Support for minority, women-owned, and disabled-veteran businesses
Significant investor interest allowances in Class 5 cannabis retailers
Non-discrimination protections for employees' lawful cannabis use (employers retain drug testing rights under specific circumstances)
Bill Forecast: 80% Assembly floor vote, 72% Assembly passage | 78% Senate floor vote, 85% Senate passage
Ohio Comprehensive Cannabis Reform (Awaiting Governor)
Adult-Use and Medical Marijuana Comprehensive Revisions
Bill: OH SB 56 (Line Item Veto Receipt - December 23, 2025)
Ohio's comprehensive marijuana legislation revises both medical and adult-use cannabis laws while levying new marijuana taxes. The bill received line item veto receipt on December 23, 2025, and awaits final gubernatorial action.
Division of Cannabis Control:
New division within Department of Commerce
Licensing oversight for cultivators, processors, and retail dispensaries
Local zoning law compliance enforcement
Age restriction compliance (21+)
Testing & Product Safety:
Drinkable cannabinoid product testing requirements
Safety and quality assurance protocols
Student-athlete ethical considerations addressed
Legal Reforms:
Expungement process for certain drug-related offenses
Clear guidelines for medical and adult-use marijuana possession and distribution
Licensed dispensary requirements for consumer verification and product labeling
Housing & Employment:
Housing rights protections for registered patients
Employer regulations regarding marijuana use and workplace policies
Financial institution guidance for servicing licensed marijuana businesses
Local Government Authority:
Municipal control over licensed business numbers
Zoning and location regulations
Host Community Cannabis Payments distribution
Revenue Framework:
Excise tax on adult-use marijuana sales
Community fund support from tax revenue
Financial allocation for municipalities and regulatory operations
Bill Forecast: 62% House floor vote, 38% House passage | 87% Senate floor vote, 84% Senate passage
District of Columbia Medical Cannabis & Streatery Program
Location Restrictions and Program Extensions
Bill: DC B 26-0300 (Law L26-0058) - Effective December 11, 2025, Expires July 24, 2026
District of Columbia enacts temporary amendments extending Streatery Program endorsements and clarifying medical cannabis location restrictions. Published in DC Register Volume 72, Page 013999.
Streatery Program Extension:
Endorsements continue through December 31, 2025
Benefits food and beverage businesses with outdoor dining spaces
Fee payment deadlines: April 1, 2025 (certain licensees) and September 30, 2025 (others)
Marijuana Retailer Location Restrictions:
New prohibition: 400 feet from educational and recreational facilities
Exception: Licensees applying prior to Medical Cannabis Clarification and Program Enforcement Amendment Act of 2024 face 300-foot restriction
Significant compliance impact for cannabis industry location planning
Previous Law Repeal:
Streatery Program Endorsement Extension Temporary Amendment Act of 2024 repealed
NJ Agricultural Support Program
New Jersey Farm Pesticide Collection and Disposal Program
Bill: NJ S 1576 (Passed Senate 37-0 - December 22, 2025)
New Jersey establishes a voluntary farm pesticide, herbicide, and fertilizer collection and disposal program with $1 million appropriation. The bill passed the Senate unanimously and advances to the Assembly.
Program Structure:
Voluntary participation for commercial farms
Department of Environmental Protection (DEP) management in collaboration with Department of Agriculture
Safe collection, transport, and disposal of unused pesticides and fertilizers
Pesticide container recycling services
Implementation Details:
Strategically placed collection sites statewide
Minimum two collection events annually per site
Local agents appointed to inventory materials and report to DEP
Public education campaign by Department of Agriculture on collection site locations, accepted materials, and environmental benefits
Objectives:
Promote environmentally responsible agricultural practices
Reduce improper pesticide and fertilizer disposal
Support commercial farming operations with proper waste management resources
Effective Date: 180 days after enactment
Bill Forecast: 95% Assembly floor vote, 63% Assembly passage | 95% Senate floor vote, 75% Senate passage
Key Compliance Considerations
Hemp Industry Compliance
Wyoming Hemp Licensees:
Submit renewal documents before December 31, 2025, to extend license expiration to April 15, 2026
Ensure Criminal History Reports current for all Key Participants
Implement certified laboratory testing for all batches
Establish compliant disposal protocols for non-compliant cannabis
New Jersey Hemp & Cannabis Operators:
Review S 4509 hemp-derived cannabinoid product requirements
Ensure advertising compliance (no minor targeting)
Implement comprehensive security protocols
Update record-keeping systems for regulatory reporting
License applicants: prepare detailed operating plans with community impact assessments
Alabama Hemp Businesses:
Monitor SB 1 progress through Senate Committee on Healthcare
Prepare for potential pharmacy-only distribution model
Evaluate Alabama-sourced hemp cultivation requirements
Budget for laboratory testing and certification costs
Cannabis & Marijuana Industry Compliance
Michigan Cannabis Businesses:
Prepare for January 1, 2026, retailer and provisioning center license caps
Calculate municipality population ratios (1 license per 5,000 residents)
Existing licensees: renewal and transfer provisions do not apply to population caps
Resort district applicants: prepare tourism-related criteria documentation
Florida MMTCs:
Harvest failure incidents: submit certification documentation within 30 days
Maintain eight consecutive weeks of active dispensing before wholesale transfer requests
Update seed-to-sale tracking systems for wholesale transfer documentation
Budget for potential harvest failure-related costs
Important Policy Deadlines
December 31, 2025:
Wyoming: 2025 hemp license renewal deadline for April 15, 2026 extension
District of Columbia: Streatery Program endorsements expire
January 1, 2026:
Michigan: Marijuana retailer and provisioning center license caps effective
January 13, 2026:
Alabama: SB 1 first reading and Senate Healthcare Committee referral
July 1, 2026:
Florida: Veteran medical marijuana registry card fee reduction effective ($15)
July 24, 2026:
District of Columbia: B 26-0300 temporary amendments expire
Policy Trends & Outlook
Market Access Controls: The trend toward population-based licensing caps in Michigan reflects growing sophistication in cannabis market management. States increasingly balance access expansion with market saturation concerns, particularly in retail sectors.
Federal-State Alignment: New Jersey's hemp-derived cannabinoid framework demonstrates states proactively aligning with federal standards while maintaining robust consumer protection measures. This approach may become a model for other jurisdictions navigating complex hemp product regulation.
Research Expansion: The federal executive order on medical marijuana and CBD research signals potential shifts in federal policy, particularly regarding Schedule III rescheduling. States should monitor federal developments as they may influence state-level cannabis and hemp regulations.
Pharmacy Distribution Models: Alabama's pharmacy-only distribution proposal for hemp products represents a conservative regulatory approach prioritizing traditional healthcare distribution channels. While unlikely to become widespread, this model illustrates the diversity of state approaches to hemp product safety.
Agricultural Support Integration: New Jersey's pesticide collection program demonstrates states supporting sustainable agricultural practices across all sectors, including emerging hemp and cannabis cultivation operations.
AHAA Action Items
For Hemp Businesses:
Wyoming licensees: submit renewal documentation before December 31, 2025
New Jersey operators: audit operations for S 4509 hemp product framework compliance
Alabama businesses: monitor SB 1 pharmacy distribution model legislation
All hemp businesses: verify product testing certificates and laboratory compliance
Prepare for increased operational costs related to testing and compliance requirements
For Cannabis & Marijuana Businesses:
Michigan retailers: analyze municipality population ratios for license cap compliance
Florida MMTCs: review harvest failure protocols and wholesale transfer procedures
New Jersey operators: engage with S 4847 Cannabis Regulatory Commission reform
Ohio licensees: monitor SB 56 implementation and governor action
All cannabis businesses: prepare for Division of Cannabis Control oversight requirements
For Healthcare Providers:
Review expanded qualifying conditions (New Jersey sickle cell anemia)
Understand Florida veteran fee reduction eligibility and documentation requirements
Monitor federal research initiatives and potential Schedule III rescheduling impacts
Update patient education materials regarding program changes
For Patients & Consumers:
New Jersey sickle cell anemia patients: explore medical cannabis program eligibility
Florida veterans: prepare documentation for $15 registry card fee (effective July 1, 2026)
All consumers: verify product testing certificates and laboratory compliance
Stay informed on state-specific location restrictions and access points
For Industry Advocates:
Engage with Alabama SB 1 Senate Healthcare Committee review process (hemp)
Monitor Michigan retailer license cap implementation for market impact (cannabis)
Support New Jersey S 4847 Cannabis Regulatory Commission reform efforts (cannabis)
Advocate for federal Schedule III rescheduling and research expansion (both markets)
Participate in state regulatory comment periods as announced (both markets)
Support evidence-based hemp product safety standards
Promote equitable cannabis licensing frameworks
Conclusion
The week of December 29, 2025, marks a significant transition period as states finalize year-end regulations and prepare for 2026 implementation deadlines. Wyoming's comprehensive hemp framework establishes clear production standards, Michigan introduces sophisticated market controls through population-based licensing caps, and New Jersey advances federal-aligned hemp product regulation while reforming its Cannabis Regulatory Commission structure.
The federal executive order on medical marijuana research represents a pivotal moment in national cannabis policy, supporting Schedule III rescheduling and emphasizing evidence-based approaches to cannabinoid medicine. This federal momentum, combined with state-level regulatory maturation, positions 2026 as a transformative year for cannabis and hemp policy nationwide.
Florida's harvest failure protocols demonstrate regulatory recognition of agricultural realities facing cannabis cultivators, while New Jersey's addition of sickle cell anemia to qualifying conditions and veteran fee reductions reflect patient-centered program expansion. Alabama's pharmacy-only distribution proposal illustrates ongoing debates about appropriate hemp product retail channels and consumer safety frameworks.
AHAA continues monitoring these developments and advocating for science-based, equitable cannabis and hemp policies that prioritize consumer safety, industry sustainability, and patient access. As regulatory frameworks mature across jurisdictions, industry stakeholders must remain vigilant regarding compliance requirements and emerging best practices.
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This report was compiled by the American Health Alternatives Association (AHAA) team. For questions or additional information, please contact us.
