Oregon Cannabis: State of the State (2025) – Canna Law Blog™

Welcome to the tenth annual “State of the State” publish on Oregon hashish. A fantastic many issues have modified over time, and I’m planning to write down one other lookback publish quickly. For now, although, let’s cowl every little thing that occurred in 2025—which is rather a lot.

Gross sales and market knowledge

In response to OLCC knowledge, complete gross sales from January 1 by way of November 30 have been $848 million. That’s a 3.7% dip from the identical interval in 2024, the place we noticed $881 million in complete gross sales. Does this imply that Oregon hashish retailers are promoting much less product? No, it doesn’t. They could be promoting extra, the truth is, at low cost mannequin pricing.

The dismal retail value trendline continued to fall all through 2025. Inside that trendline, the extracts/concentrates class hit a nadir of $15.00/gram (median) within the extracts/concentrates class in April; it once more exhibits $15.00/gram for November. The “usable marijuana” class additionally dropped to a ghastly $3.33/gram (median) in April, and all however flatlined from that time. (Usable marijuana is actually flower, within the OLCC milieu.)

There is no such thing as a foreseeable finish to the worth melancholy: the truth is, it might solely worsen. Croptober 2025 was Oregon’s largest METRC harvest ever, with 6,289,890 kilos reported. This was a major and unwelcome 8.9% improve from the October 2024 harvest, which itself was a document excessive. As I wrote final 12 months:

“I’m certain the illicit market had a bumper 12 months too; climate is similar for everybody and the enforcement paradigm is static… Customers could profit, however that may’t be nice for pricing.”

That proved true in 2025, sadly, and it’ll occur once more in 2026. So far as what persons are truly shopping for in any respect of those OLCC shops, I compiled this desk:

2025
2024
Change +/-

Usable marijuana
43.6%
46.2%
-2.6

Focus/extract
26%
25%
+1.0

Edible/tincture
14.2%
13.7%
+0.5

Inhalable w/non-canna components
10.7%
9.1%
+1.6

“Different”
4.9%
5.4%
-0.5

Industrial hemp
0% (?)
0.6%
-o.6 (?)

Try that drop within the usable marijuana class. In each 2023 and 2024 I famous a “years-long pattern of usable marijuana gross sales lowering per capita in favor of different classes.” We aren’t simply seeing these SKU shifts within the knowledge—we’ve had a collection of farm purchasers lament that retailers are pulling again orders for flower, in response to shopper desire for vape and cartridge merchandise.

Backside line: Persons are shopping for extra Oregon hashish than ever, at decrease costs than ever. There may be additionally extra hashish within the OLCC market than ever. Surveying this abundance, clients aren’t burning flower like they used to, opting as a substitute for packaged merchandise. All of this makes for an especially difficult enterprise atmosphere—particularly for small farms, which proceed to falter and fail.

Oregon hashish licenses and licensing

Oregon’s years-long OLCC licensing moratorium was ratified by the legislature in 2024. We nonetheless have a “one-in, one-out” coverage the place outgoing licensees are allowed to give up (promote) their licenses in favor of latest market entrants, who purchase (purchase) alternative licenses. Outdoors of this purchase/promote paradigm, OLCC is “prohibited from accepting new license purposes just about endlessly, because of restrictive, ratio-based formulation tied to inhabitants,” as I defined again when HB 4121 handed.

In 2025, license numbers declined marginally throughout the board as predicted. This was additionally the case in 2024 and 2023 because of the years-long moratorium, in live performance with enterprise failures. Right here’s a desk exhibiting present license numbers as in comparison with this time final 12 months:

2025
2024
Change +/-

Producers
1,351
1,375
-24

Processors
275
288
-13

Wholesalers
243
257
-14

Retailers
769
789
-20

Labs
10
13
-3

Analysis
1
1
none

Numbers proceed to fall on the sluggish drip we’ve seen for a few years, which is wholesome. Most would agree that we have now too many licenses throughout all classes—besides maybe for labs and analysis. Sadly, we misplaced a few labs this 12 months, presumably tied to fallout from the October 2024 crackdown on THC inflation.

So far as pricing, we helped folks purchase and promote producer licenses at costs between $60K and $85K all year long, with costs rising within the final month or two. Most of those transactions are change-of-location and change-in-ownership situations, and a lot of the consumers are Chinese language. Wholesale and processor licenses commerce much less continuously, and for decrease costs; retail pricing is its personal animal, largely depending on retailer efficiency. That mentioned, we did assist promote a few change-in-location retail licenses within the $100K vary.

OLCC has emphasised transferring purposes by way of the system rapidly, which is welcome information. I met with a couple of OLCC employees final week, who articulated their objective of a “zero wait” time for change-in-ownership purposes, their plans to implement new guidelines requiring polished submissions, and necessities that candidates transfer rapidly by way of the method.

New Oregon hashish guidelines

Marijuana

The licensing protocol guidelines talked about above come on-line on January 1, 2026, alongside guidelines that make some technical updates and implement the 2025 marijuana laws. I lined these guidelines in a current publish, and I received’t summarize them additional right here.

Earlier this 12 months, guidelines banning gross sales of most CBN merchandise additionally took impact. I defined:

Starting July 1, 2025, merchandise containing artificially derived CBN can not be bought in Oregon, both within the OLCC system or within the basic (hemp-derived) market, until the producer has made a “Usually Acknowledged as Protected” (GRAS) willpower, or submitted a New Dietary Ingredient Notification to the FDA and obtained a “no objections” response.

To my data, nobody has acquired GRAS standing or submitted a qualifying NDI notification. That’s not surprising, and it’s additionally too unhealthy.

Hemp

The great hemp registry guidelines will take impact on January 1. These guidelines apply to hemp flower pre-rolls, in addition to hemp drinks and tinctures containing cannabinoids like THC, CBD and others. The foundations don’t apply to hemp gadgets which are: a) bought at OLCC licensed shops, b) missing cannabinoids, c) supposed just for topical use, d) industrial or business feed merchandise, or e) merely passing by way of the state.

A number of labeling and “claims” necessities for hemp merchandise bought in Oregon additionally take impact subsequent 12 months. It stays to be seen if or how any of those new guidelines will work together with the current federal ban on intoxicating hemp merchandise, though I’m not anticipating a lot friction. If the federal ban holds, we’ll possible simply have fewer out-of-state registrants, and fewer inbound merchandise past what’s carved out within the CBD area.

For what it’s value, earlier this 12 months OLCC and different companies printed a report detailing that almost all hemp merchandise in Oregon run scorching. It wasn’t an excellent look, but it surely was no shock.

Oregon hashish litigation

Oregon hashish issues discovered their strategy to the courts in 2025. Our workplace dealt with a collection of enterprise and investor disputes, and there have been some public skirmishes as effectively. Right here is my brief listing:

Pal of the agency Andrew DeWeese filed a notable dormant commerce clause problem to the federal prohibition of interstate marijuana gross sales. We’re cheering him on.
Poll Measure 119 was defeated in Oregon District Court docket. That measure required most Oregon hashish companies to enter into labor peace agreements with accepted unions, as a way to renew or get hold of licensure. The depressing case is now on attraction with the U.S. Court docket of Appeals for the ninth Circuit.
The Oregon Court docket of Appeals dominated towards retailer candidates that didn’t wish to pay their taxes, as a situation precedent to license renewal. No attraction was filed.
Hashish receiverships continued apace, with the biggest being the Tumalo Industries matter. The market remained mushy, with the consumers as soon as once more Chalice insiders.

Federal developments

I ought to embrace a bit on President Trump’s Govt Order of December 18, directing marijuana rescheduling. We’ve lined it comprehensively already, however Oregon hashish companies must be happy.

Relying on the trail Pam Bondi chooses, and the measure of resistance, marijuana may go to Schedule III in 2026. In that case, a lot of our purchasers will notice higher margins in a single day. These companies may additionally see much less competitors from out-of-state hemp operators, because of the federal ban talked about earlier.

Odds and ends

The hemp trade continued to limp alongside. We lastly noticed a rise in planted acreage, regardless of a dwindling variety of farmers. Licensed “distributors” continued to pile into the ODA program, following the 2024 registration requirement.
We proceed to wrestle to repair and to finish hashish trade transactions structured by brokers. No less than one outstanding dealer within the Oregon hashish area has no license by any means, and some others proceed to make messes. There are additionally competent brokers, to make sure—our recommendation is to by no means use authorized agreements supplied by brokers regardless.
OLCC gave the impression to be much less punitive and to pivot again towards educating compliance, notably for smaller operators (together with the labs). I’d prefer to assume we had one thing to do with that method, and I hope it sticks—however who is aware of in both case.
The Hashish Trade Alliance of Oregon (CIAO) performed a central position in 2025 legislative negotiations. CIAO efficiently lobbied for producer switch rights, commerce pattern expansions, and extra sensible enforcement timelines for CBN compliance guidelines talked about above.
Initiative Petition 39, which aimed to legalize hashish cafes, was submitted in February however withdrawn final month, within the face of logistical points.
Emerge Regulation Group, the Measure 91 regulation agency and first Oregon hashish regulation boutique, introduced it might wind down after a stellar 10-year run. Its remaining attorneys are becoming a member of Denver-based Vicente LLP.

Oregon hashish in 2025: that’s a wrap

As at all times, attempting to summarize a 12 months’s value of tales on this small area might be difficult. Let me know within the feedback if I missed something necessary. For prior posts on this collection, take a look at the listing beneath.

Finest needs to the Oregon hashish trade and all of our purchasers in 2026.