Cannabis Compliance Changes in Montana: What Dispensaries and Labs Need to Know Before July 1, 2026

The Montana Cannabis Control Division has issued a regulatory update establishing new compliance requirements for licensed dispensaries and testing laboratories effective July 1, 2026.

On June 11, 2026, the Montana Cannabis Control Division issued a regulatory update addressing changes to dispensary operations, ingestible cannabis product standards, and laboratory licensing procedures. MAR Notice No. 2026-93.1 remains subject to rulemaking requirements under the Montana Administrative Procedure Act (MAPA), which governs administrative rule adoption in Montana.

Dispensary Exit Packaging Requirements

Licensed dispensaries must implement revised exit packaging requirements reflecting updated statutory warning language and mandatory consumer resource disclosures.

The revised requirements include placement of updated warning statements adjacent to the universal marijuana symbol, inclusion of an addiction resource QR code, verbatim reproduction of statutory warning language, and printing in black ink on a white background.

The warnings under 16-12-215, MCA address risks associated with marijuana consumption, including anxiety, agitation, paranoia, psychosis, vomiting, pregnancy-related complications, and impaired driving.

Each exit package must include the required statutory warning statements and a quick response code linking to a consumer resource for marijuana-related addiction support. Dispensaries must also display updated consumer education posters at each point of sale, which must include the same statutory warnings, the universal marijuana symbol, and corresponding resource information.

Exit packaging is not subject to resubmission for approval under current law, though compliance will be verified through inspection.

Ingestible Marijuana Products: THC Serving Limit Reduction

Effective July 1, 2026, the maximum THC per serving for ingestible marijuana products will be reduced from 10 milligrams to 5 milligrams under 16-12-224(8)(iv), MCA.

Under the revised standard, no edible or ingestible marijuana product may exceed 5 mg of THC per serving. Products exceeding this limit may not be sold after the effective date, regardless of production date. Compliance applies to all inventory in circulation.

Licensees remain responsible for ensuring all products meet the revised threshold prior to enforcement. Montana law continues to cap edible products at 100 mg of THC per package, subject to statutory variance provisions and medical-use exceptions.

Marijuana Testing Laboratory Licensing

Applicants for marijuana testing laboratory licenses must continue to apply through the Department’s licensing system under “Apply for or Manage a Cannabis Business License,” selecting the Testing Laboratory License option.

No procedural changes affecting laboratory applicants were included in this update.

Key Compliance Requirements (Effective July 1, 2026)

Licensees must ensure the following prior to the effective date:

• All exit packaging reflects revised statutory warning language and includes required QR code placement
• Consumer education posters are displayed at all points of sale in compliance with statutory requirements
• All ingestible marijuana products exceeding 5 mg THC per serving are removed from sale, unless permitted under applicable medical-use exceptions
• Inventory compliance is verified prior to July 1, 2026 enforcement
• Testing laboratories are not subject to new operational changes under this update and should continue existing compliance and licensing procedures.

MAR Notice No. 2026-93.1 and MAPA Rulemaking Framework

MAR Notice No. 2026-93.1 is governed by the Montana Administrative Procedure Act (MAPA), which establishes procedural requirements for agency rulemaking under Title 2, Chapter 4 of the Montana Code Annotated.

Under MAPA, administrative rules are not valid unless adopted through required notice, participation, and publication procedures. Prior to adoption, an agency must publish notice in the Montana Administrative Register, file the notice with the Secretary of State, post the notice on a public electronic access system, notify legislative rule review committees, and provide notice to registered interested persons within statutory timelines.

All written and oral comments must be considered by the agency. Where a proposal involves significant public interest, an oral hearing must be held or granted upon proper request. A rule is not valid unless it is reasonably necessary to implement statutory authority and consistent with the governing statute, and the agency must affirmatively articulate that necessity in the rulemaking record. A description of the rule alone is insufficient to establish compliance.

Upon final adoption, the agency must summarize substantive comments, respond to objections, and explain any rejection of material concerns, including differences between proposed and final rule language. No rule may be enforced prior to its effective date.

Legal Status of MAR Notice 2026-93.1

Although MAR Notice No. 2026-93.1 establishes a July 1, 2026 compliance timeline, it remains subject to MAPA procedural requirements, including public comment, review, and final adoption.

Until those requirements are completed, the notice remains in proposed status and may be revised prior to enforceability.

Conclusion

Cannabis regulation in Montana continues to operate through two parallel mechanisms: operational compliance requirements with fixed enforcement dates, and administrative rulemaking under MAPA that governs final legal validity.

July 1, 2026 represents the enforcement date for dispensary and product-level changes, while MAR Notice No. 2026-93.1 remains in the procedural stage governing its final adoption.

Source: Montana Department of Revenue, Cannabis June 2026 Newsletter