Missouri House Bill 2641 Guidance ” some adjustment for cannabis facilities licensed under Article XIV. While not all of these changes fall under DCR’s regulatory authority, there are some new requirements DCR would like to highlight as licensees prepare for implementation. “
As you know, several changes in law are occurring or are scheduled to occur in the coming months that will require some adjustment for cannabis facilities licensed under Article XIV.
health.mo.gov · · 2 min read
Missouri House Bill 2641 Guidance
Licensee Communications & Guidance
Facility Conversion To Comprehensive License Requests
How to Apply – Facility Information
Failed Mandatory Testing Forms
Documentation for Identifying an Agent While Working Waiver
Guidance Document – September 28, 2026
As you know, several changes in law are occurring or are scheduled to occur in the coming months that will require some adjustment for cannabis facilities licensed under Article XIV. While not all of these changes fall under DCR’s regulatory authority, there are some new requirements DCR would like to highlight as licensees prepare for implementation.
Key provisions of HB 2641
- Prohibits licensed marijuana dispensaries from creating or keeping any record with consumer identifying information without the consumer’s affirmative agreement. Dispensaries that violate this provision will be assessed a $500 fine per occurrence.
- Prohibits state agencies and their employees from disclosing medical marijuana patient information to the federal government absent a subpoena or court order.
- Makes intoxicating hemp-derived cannabinoid products marijuana as defined in Article XIV of the Missouri Constitution, with a limited exception dependent on federal actions not yet settled. The sale or distribution of intoxicating hemp products without a marijuana facility license is prohibited and may result in fines or criminal prosecution.
- Currently, beverages that have naturally occurring cannabinoids and were not synthesized or manufactured outside the plant will not be subject to the authority of Article XIV until December 11, 2026, provided that these products are not sold to individuals under 21 years of age.
- Allows any employee of a cannabis-related business to organize and bargain collectively.
What changes for regulated marijuana products?
- Licensees may acquire, utilize, and sell hemp-derived cannabinoids that contain no more than three-tenths of one percent of total THC and hemp-derived cannabinoid products with no more than 0.4mg of total THC from outside of Missouri’s licensed marijuana facilities. Hemp-derived cannabinoids with higher potency are now considered marijuana and may only be produced by businesses licensed under Article XIV. Synthetic cannabinoids and cannabinoids produced through chemical conversion or modification of other cannabinoids remain prohibited for licensees.
What information can licensees record and share?
- Dispensary licensees may only record a consumer’s identifying information if the consumer has affirmatively agreed to such in writing. Licensees should consider whether any of their current processes or historical records need to be addressed, such as processes for intake of delivery orders and records gathered and retained for rewards programs.
- HB 2641 does not establish any new prohibitions or requirements for licensees regarding qualifying patients and primary caregivers.
- Dispensary licensees are still subject to the data collection and distribution provisions regarding consumers, qualifying patients, and primary caregivers as outlined in Article XIV of the Missouri Constitution and 19 CSR 100-1.
- Dispensary licensees still must follow the track and trace provisions in 19 CSR 100-1.
Official release issued by health.mo.gov: read the original. Found by Cannabis Law Report.
Information, not legal advice. Check the primary source before relying on it.
