Minnesota marijuana regulators have released a detailed list of medical marijuana products that qualifying dispensaries will be required to carry beginning January 1, 2027, including CBD-only formulations, balanced THC and CBD products, and products containing at least 20 milligrams of THC per serving.
The Minnesota Office of Cannabis Management published the requirements Monday in Guidance Memo GM-2026-08, identifying four categories of products considered to have a “high medical need” under legislation approved earlier this year.
Businesses holding a medical cannabis retail endorsement must stock products in each designated category, while manufacturers with medical endorsements will be required to produce high-medical-need products.
The first category covers CBD-only formulations. Dispensaries must carry both products intended to be swallowed, such as water-soluble cannabinoid preparations or oral solutions, and products absorbed through the mouth, including tinctures and orally dissolvable products.
The second category requires high-CBD formulations containing a THC-to-CBD ratio of at least 1:15. These must also be available in both swallowed and orally absorbed forms.
A third category covers balanced formulations containing a 1:1 ratio of THC to CBD. Retailers must offer these products in three forms: pills, water-soluble preparations or oral solutions, and tinctures or orally dissolvable products.
The fourth category requires at least one high-THC product containing 20 milligrams or more of THC per serving. These products may contain CBD, but the CBD concentration cannot exceed the amount of THC. Retailers can satisfy this requirement by carrying an eligible pill, oral preparation, tincture or dissolvable product.
According to the agency, the list was developed using feedback from medical marijuana patients, caregivers, health care practitioners and marijuana businesses. Regulators also reviewed patient purchasing patterns, medical marijuana research and complaints about product availability.
The office said some products were deliberately excluded because they are expected to remain readily available through Minnesota’s increasingly integrated recreational and medical marijuana market. The designated products are those regulators believe patients depend on but that businesses might otherwise have insufficient incentive to produce.
The agency also noted that none of the designated product types are currently approved for recreational sales, meaning they can only be manufactured and sold by businesses holding the appropriate medical endorsements.
The requirements are part of broader changes taking effect January 1 that will streamline Minnesota’s medical and recreational marijuana supply chains while preserving protections for registered patients.
Under the new law, regulators can take enforcement action against businesses that fail to make required products available within 24 hours of a patient’s request. Penalties can include civil fines, administrative orders and the suspension or revocation of medical marijuana endorsements.
The Office of Cannabis Management says it will continue reviewing patient access and product availability to determine whether businesses are meeting the new requirements.
