Cannabis Control Division September 2025 Newsletter

Cannabis and Alcohol Regulation Division

The Cannabis Control Division and the Alcoholic Beverage Control Division have merged to become the Cannabis and Alcohol Regulation Division, or CARD. Not much will change at first. However, as changes happen, we will communicate those to ensure transparency throughout the process.

Please feel free to contact us with any questions:

• For alcohol related questions, please call (406) 444-6900 or email DORAlcoholicBeverageControl@mt.gov.
• For cannabis related questions, please call (406) 444-0596 or email DORCCD@mt.gov.

Third-Party Relationships

Senate Bill 74 was passed during the 2025 legislative session, effective October 1, 2025. The bill contains the following language in Section 5 (7):

“A licensee may contract or otherwise engage a third party to perform work on behalf of any aspect of a marijuana business. All third-party relationships must be disclosed to the department before a third party can begin performing work on behalf of any aspect of the marijuana business. An individual performing work for any aspect of a marijuana business must secure a worker permit pursuant to 16-12-226. A licensee is responsible for ensuring a third party is compliant with marijuana laws and is liable for any violations.”

All licensees must disclose the status of any third-party relationships (business and/or individual) associated with their licensed business.

Please note: If no such relationships exist, the licensee must attest accordingly.

All disclosures and attestations must be submitted through our secure TransAction Portal and received no later than October 1, 2025. With the launch of this new online feature, licensees may not only submit the required disclosure but can also view or update third-party relationship information at any time.

Product Sampling

After cannabis has been harvested and separated into 5-pound test batches, a sample from the source (parent) package is collected and transported to a licensed testing facility.

Product lab sampling must be conducted before subpackaging.

Subpackages (or child packages) should not be created until the lab results have been recorded in Metrc with a “Test Passed” status. These new packages will automatically inherit the test results of their compliant parent package.