Registration With OLLC Required January 1, 2026, to Sell Hemp Products to Consumers

The recently enacted Oregon House Bill 4121, which goes into effect on January 1, 2026 (https://olis.oregonlegislature.gov/liz/2024R1/Downloads/MeasureDocument/HB4121/Enrolled), directs the OLCC to establish a registry for hemp products for sale to consumers in Oregon. This legislation requires OLCC to adopt new rules in Division 26 related to:

• Definitions for the registry
• Labeling requirements by product type
• Registration requirements, including fees and annual renewal
• Civil penalties for violations of the law and rules
• Embargo, seizure, and disposal of hemp items

Section 11(3) of House Bill 4121 provides that any person located within or outside this state and that is responsible for the manufacture, packaging or distribution of an industrial hemp product shall, prior to selling, transferring or delivering the industrial hemp product directly to a consumer in this state or selling, transferring or delivering the industrial hemp product to a retailer in this state for the purpose of sale to a consumer in this state submit to the OLCC the following information about an industrial hemp product that contains cannabinoids and is intended for human or animal consumption or use:

(a) The name and type of the product;

(b) The name and physical address of the manufacturer of the product;

(c) The mailing address of the manufacturer of the product;

(d) A certificate of analysis for a batch of the product;

(e) A copy of the label for the product;

(f) A statement about whether the product is an adult use cannabis item; and

(g) Any other information required by the commission by rule.

Section 11(4) requires the labelling of an industrial hemp product that contains cannabinoids and is intended for human or animal consumption or use with a label that contains the following information:

(a) The name and type of the product;

(b) The name and physical address of the manufacturer of the product;

(c) The ingredients of the product;

(d) The net weight or volume of the product;

(e) The serving size and number of servings contained in a package of the product

(f) The potency of the product and a list of the cannabinoid contents of the product;

(g) The address of a publicly accessible website that contains the certificate of analysis for the product;

(h) Health and safety warnings required by law or rule;

(i) If the product is an adult use cannabis item, the following language:

(A) “For use only by adults 21 and older.”; and

(B) “Keep out of reach of children.”;

(j) If the product is a food product, any other information required by law or rule for food products; and

(k) Any other information required by the commission by rule.

Section 11(10) exempts any industrial hemp product from the labelling requirement if it:

(a) does not contain cannabinoids;

(b) Is intended only for topical use;

(c) Is an industrial hemp grain or fiber product that does not contain added cannabinoids;

(d) Is a commercial feed product for animals registered under ORS 633.006 to 633.089; or

(e) Is transported through this state en route to a final destination in another state.

Products requiring registration include hemp products like gummies, beverages, tinctures, capsules, vapes, smokable flower, and other non-topical products that contain cannabinoids like CBD, CBG, or THC.

Registration is not required for cannabinoid hemp items sold by OLCC-licensed marijuana retailers; these products are already required to comply with the OLCC’s labeling requirements.

The OLCC has provided the following chart as a helpful visual guide for determining which products are subject to the new registration requirements on PAge 3 of Bulletin HE2025-01:

https://www.oregon.gov/olcc/marijuana/Documents/Hemp/Bulletins/HE2025-01-Hemp-Registry-Enforcement.pdf

While HB 4121 goes into effect on January 1, 2026, the OLCC is not even authorized to accept registration applications until January 1, 2026. Because the OLCC understands the logistical implication of this, that all affected hemp products will be ineligible for sale or distribution because they will not have had the opportunity to register their products before the requirement takes effect. Consequently, to reduce disruption in the cannabinoid hemp product market, the OLCC will generally not take compliance actions related to the hemp registry until June 1, 2026. Persons subject to the registry’s requirements are encouraged to register their products before this deadline to avoid delays and possible compliance issues. Retailers of hemp products should also be mindful of these requirements as well. By June 1, 2026, all hemp items subject to the registry requirements must be in compliance with all applicable laws and rules. This includes discontinuing sales of any hemp items that are not properly registered with the OLCC and labeled in accordance with the hemp registry’s rules beginning on June 1, 2026. If label changes are required in order to comply with the registry requirements, older batches with noncompliant labels should not be sold or distributed beginning on June 1, 2026.

As always, we are ready to help you understand the new reporting requirements and to help keep you in compliance.  Contact our office through the website or by phone.