Welcome to 10^thousand Oregon’s annual State of the Marijuana publication. A lot of things have changed over the years and I plan to write another review post soon. But for now, let’s talk about everything that happened in 2025 — and that’s a lot.

Sales and market data

According to OLCC datatotal sales from January 1 to November 30 were $848 million. This is a 3.7% drop from the same period in 2024, when total sales were $881 million. Does this mean Oregon cannabis retailers are selling less product? No, not like that. Maybe they are selling more for the price of the discounted models.

Sad retail price trend line continued to decline through 2025. Within this trendline, the extracts/concentrates category hit a low of $15.00 per gram (average) in the extracts/concentrates category in April; it again shows $15.00 per gram for November. Edible marijuana also dropped to an awful $3.33 per gram (average) in April, and has been pretty much nonexistent since then. (Useful marijuana is essentially a flower in the OLCC environment.)

There is no foreseeable end to the price depression: it can only get worse. Croptober 2025 was Oregon’s largest METRC crop with 6,289,890 pounds recorded. This was a significant and unwelcome 8.9% increase in the crop compared to the October 2024 crop, which itself was a record. As I wrote last year:

“I’m sure the illegal market has had a great year as well; the weather is the same for everyone and the enforcement paradigm is static… Consumers may win, but it may not be great for pricing.”

Unfortunately, it came true in 2025 and it will happen again in 2026. As for what people actually buy at all these OLCC stores, I’ve compiled the following table:

Check it out the fall in the eligible marijuana category. In both 2023 and 2024, I noted a “multi-year trend of declining per capita marijuana sales in favor of other categories.” We’re not just seeing these SKU changes in the data—we’ve had a series of farm customers complaining that retailers are withdrawing flower orders in response to consumer preference for vapes and cartridges.

Bottom line: People are buying more cannabis in Oregon than ever, at lower prices than ever. There is also more hemp than ever in the OLCC market. Looking at this wealth, customers do not burn flowers, as before, but choose packaged products. All of this creates a very challenging business environment, especially for small farms that continue to falter and fail.

Cannabis Licenses and Licensing in Oregon

A years-long moratorium on OLCC licensing in Oregon was ratified by the Legislature in 2024. We still have a one-in, one-out policy whereby outgoing license holders are allowed to surrender (sell) their licenses in favor of new entrants purchasing (buying) replacement licenses. Outside of this buy/sell paradigm, the OLCC is “prohibited from accepting new license applications almost forever due to restrictive formulas based on population-based ratios,” as I explained ago when HB 4121 passed.

In 2025, as predicted, the number of licenses in all areas decreased slightly. This was also the case in 2024 and 2023 due to a long-term moratorium due to business bankruptcy. Here’s a table showing current license numbers compared to this time last year:

The numbers continue to fall on the slow decline we’ve seen for several years, and that’s a good thing. Most would agree that we have too many licenses in all categories except perhaps labs and research. Unfortunately, we lost a couple of labs this year, possibly due to the October 2024 dropout. suppression of THC inflation.

In terms of pricing, we’ve helped people buy and sell producer licenses for anywhere from $60,000 to $85,000 over the course of a year, with prices rising over the past month or two. Most of the deals are relocation and change-of-owner scenarios, and most of the buyers are Chinese. Wholesale licenses and CPU licenses are sold less frequently and at lower prices; retail pricing is a separate animal that depends heavily on store performance. However, we did help sell a couple of $100K retail licenses.

The OLCC highlighted the rapid movement of applications through the system, which is welcome news. Last week, I met with several OLCC officials who outlined their goal of a “zero wait” for change-of-ownership applications, their plans to comply with the new rules requiring polished submissions, and their demands for fast-track applicants.

Oregon’s New Cannabis Rules

Marijuana

The licensing protocol rules mentioned above will go online on January 1, 2026, along with rules that make some technical updates and implement Marijuana Act of 2025. I considered these rules in a recent postand I will not summarize them here.

Earlier this year, rules a ban on the sale of most CBN products also came into effect. i explained:

Beginning July 1, 2025, products containing artificially derived CBN can no longer be sold in Oregon under either the OLCC system or the general (hemp) market unless the manufacturer has determined to be Generally Recognized as Safe (GRAS) or submitted a New Dietary Ingredient Notification to the FDA and received a “no objection” response.

To my knowledge, no one has acquired GRAS status and submitted a corresponding notification to NDI. This is not unexpected, and it is also very bad.

Hemp

Complex hemp registry rules will take effect on January 1. These rules apply to hemp flower pre-rolls, as well as hemp beverages and tinctures that contain cannabinoids such as THC, CBD, and others. The regulations do not apply to hemp products that: a) are sold in stores licensed by the OLCC, b) do not contain cannabinoids, c) are intended for local use only, d) are industrial or commercial feed products, or e) simply pass through the state.

A slew of labeling requirements and “claims” for hemp products sold in Oregon will also go into effect next year. It remains to be seen whether any of these new rules will interact with the recent federal ban on intoxicating hemp products, although I don’t expect much friction. If the federal ban remains, we will likely have fewer out-of-state registrations and fewer products coming in, other than what is allocated to the CBD space.

For what it’s worth, the OLCC and other agencies made public earlier this year report details that most hemp products in Oregon are hot. It wasn’t a great look, but yes was not a surprise.

Oregon Cannabis Litigation

Oregon hemp cases go to court in 2025. Our office has handled a number of business and investor disputes, and there have also been some public skirmishes. Here is my short list:

• A friend of the firm, Andrew DeWeese, filed a notable statement challenging the dormant commerce clause to the federal ban on the interstate sale of marijuana. We root for him.
• Ballot 119 was defeated in the District Court of Oregon. The measure required most Oregon hemp businesses to enter into labor settlement agreements with approved unions in order to be reinstated or licensed. The unfortunate case is currently pending before the 9th US Circuit Court of Appeals^thousand Scheme.
• Oregon Court of Appeals ruled against retail applicants unwilling to pay taxes as a condition precedent to license renewal. No appeal was filed.
• Cannabis continued to grow rapidly, with Tumalo Industries being the biggest. Market remained soft, buyers again Chasha insiders.

Federal developments

I should add a little bit about President Trump Disposition of December 18, which regulates the transportation of marijuana. We have illuminated him from all sides already, but Oregon cannabis businesses should be happy.

Depending on the path Pam Bondi chooses and the resistance, marijuana could end up on Schedule III in 2026. If that’s the case, many of our customers will get better margins right away. These businesses may also experience less competition from out-of-state hemp operators due to the federal ban mentioned earlier.

Odds and ends

• The hemp industry continued to limp along. Finally we saw increase in cultivated areas, despite the declining number of farmers. Licensed “providers” continued to accumulate in the ODA program toward the 2024 enrollment requirement.
• We continue to fight to fix and end the cannabis industry transactions structured by brokers. At least one prominent cannabis broker in Oregon has no license, and several others continue to run riot. Of course there are also competent brokers – our advice is never to use legal agreements offered by brokers.
• The OLCC appeared to be less strict and returning to compliance training, especially for smaller operators (including laboratories). I would like to think we had something to do this approach and I hope it sticks, but who knows anyway.
• The Hemp Alliance of Oregon (CIAO) played a leading role in the 2025 legislative negotiations. CIAO has successfully lobbied for producer transfer rights, expanded trading patterns and more realistic timelines for the CBN compliance regulations mentioned above.
• Initiative Petition 39, which aims to legalize cannabis cafes, was filed in February, but withdrawn last month, due to logistical problems.
• Emerge Law Group, the Measure 91 law firm and Oregon’s first boutique cannabis law firm, has announced its retirement after a stellar 10-year run. His remaining attorneys to join Denver-based Vicente LLP.

Source: Legal Canna Blog