Cannabis Control Division August 2025 Newsletter

Legislative Updates – Reminders

Montana Senate Bill 74 was passed and signed by the Governor of Montana on May 8, 2025. 

Effective October 1, 2025:

• Third-party contracts and required disclosure:
  • 16-12-102 (7)(b) – has been eliminated. Third-party relationship exclusion is no longer applicable; third-party relationships are/can be controlling beneficial owners.
  • 16-12-203 (7)(a-b) – third parties can perform all work types, but the licensee is responsible for compliance and liable for all violations.

  The department requires the disclosure of third-party relationships. Third parties are allowed to perform work on behalf of a licensee, but they must have a valid Montana marijuana worker permit prior to doing so.

• (±)10% variance on delta-9 THC permitted for certain marijuana products:

  This deviation is permitted for marijuana-infused ingestible, non-ingestible marijuana-infused products (e.g., topicals), and marijuana concentrates and extracts.

  This deviation is not permitted for marijuana flower (adult-use marijuana flower is capped at 35% Total Potential Psychoactive THC).

• Department Hotline Complaints:

  Complaints submitted to the department via the Montana Cannabis Control Division Hotline are confidential and not subject to public disclosure unless or until authorized by a district court on a written finding that the demands of individual privacy do not clearly exceed the merits of public disclosure or are confidential criminal justice information pursuant to Title 44, chapter 5.

• Manufacturing Tiers:

  Tiers are based on the total amount of concentrate produced by the licensee; they are not determined by each premise.

  • $5,000 for less than 1 pound of concentrate and up to 10 pounds of concentrate
  • $10,000 between 10 pounds of concentrate and 15 pounds of concentrate
  • $20,000 for 15 pounds or more of concentrate.

Anecdotal Statements - Not Allowed on Electronic Advertising

Reminder re: electronic advertising; 16-12-211(3)(a)(v), MCA states that:

“A licensee may engage in electronic advertising, such as maintaining a website and advertising on web applications, provided that no electronic advertisement produced by the licensee contains a statement or illustration that makes any health, therapeutic, or medicinal claims about marijuana or marijuana products.” (i.e., anecdotal statements).

This includes the utilization of anecdotal statements. Licensees may not use these statements in electronic advertising.

Metrc Sandbox: Ready for Release August 18, 2025

The Metrc Industry Sandbox is a secure, simulated training environment that mirrors the Metrc production system. The Industry Sandbox will offer licensees the ability to safely test workflows, navigate system features, and train staff without impacting live data.

Licensees who adopt and use the Metrc Industry Sandbox can:

• Practice without pressure: Safe for mistakes — users can confidently practice, try new processes, fill out mock data, and explore features without any real-world consequences.  
• More effectively train: Perfect for onboarding and training. learn in a realistic environment with up-to-date demo data. Experiment with different features or scenarios to see how things work before doing them live. Sample demo data is used, so nothing is permanent.  
• Enjoy streamlined access: Easy setup and automatic access through production. 
• Identify clear distinctions between the sandbox and the production environment: Clear indicators and alerts separate the two environments and prevent confusion.
• Experiment more: Users can access license types and permissions that may not be available in the live environment, enabling more comprehensive training and learning opportunities.