New OLCC Compliance Bulletin: Artificially Derived CBN Products Must Meet FDA Standards by July 1, 2025

OLCC Compliance Education Bulletin

The Oregon Liquor and Cannabis Commission (OLCC) has issued Compliance Education Bulletin CE2025-05, outlining critical changes regarding the manufacture, distribution, and sale of hemp and marijuana products containing artificially derived cannabinol (CBN).

Beginning July 1, 2025, products containing artificially derived CBN may no longer be sold to Oregon consumers—either in the OLCC-licensed marijuana market or in the general hemp retail space—unless the manufacturer of the CBN has:

• Completed a “Generally Recognized as Safe” (GRAS) determination, or

• Submitted a New Dietary Ingredient Notification (NDIN) to the FDA and received a “no objections” response.

  
  

What this means for OLCC Marijuana Licensees:

After July 1, 2025:

• Marijuana products with artificially derived CBN cannot be sold to consumers or transferred to other licensees unless they meet the FDA requirements above.

• The OLCC is not currently aware of any CBN products that meet these standards.

• Licensees must plan to remove these products from their inventory before the deadline.

• If returning products to the manufacturer or distributor, complete transfers before July 1 to remain in compliance.

For businesses selling hemp-derived CBN products outside the OLCC system:

• Labeling may not clearly identify artificially derived CBN.

• Retailers must contact manufacturers or distributors directly to determine:

  • Whether the CBN is artificially derived

  • Whether it meets GRAS or NDIN “no objection” requirements

• Products that do not comply must be pulled from shelves by July 1, 2025.

This new rule will impact a wide range of businesses across the hemp and cannabis supply chains. Early action is critical to avoid compliance violations and potential inventory losses.

Have questions about how this bulletin impacts your business?

Contact EARTH Law, LLC today to schedule a compliance consultation: info@earthlawllc.com |

541-632-3946