Hemp Rule Frequently Asked Questions

1. As an existing operator, what do I need to provide CHB to be in compliance with the new rules?

A. First, updated hemp finished product information (including Attachment A) on page 11 of the current application. Next, updated SOP(s) to show: how you will demonstrate incoming hemp product is hemp-derived, inclusion of pesticide testing of hemp finished products into current testing plan, semi-synthetic or synthetic cannabinoids allowed and used are 98% pure and tested at approved analytical laboratory, for broad spectrum (non-detectable THC), update SOP to ensure analytical laboratories are using .005% to confirm non-detectable THC, manager and training is being done in accordance with the hemp rule, the requirement to obtain a Food Handler Cards is now a part of your SOPs, and training SOPs and records are updated to account for changes, and new corrective actions that will be taken when non-compliance with the new requirements is discovered. Finally, updated product labels.

2. What is the difference between broad spectrum and full spectrum products?

A: Broad spectrum product is product that has had the THC removed from it and now contains non-detectable amounts of THC, while full spectrum product contains the original cannabinoids including THC (allowed up to 0.03% and 2mg per serving).

3. How can I demonstrate hemp ingredients received are hemp-derived?

A: CHB does not require a certain method, but examples of what may be used include a signed letter of guarantee or attestation, or chain of custody documenting the source from field to hemp product.

4. Where can I find approved food handler card programs?

A: Click here and scroll down to “Food Handler Cards” for programs and information. 

5. Does an employee that will be part of making my products need a food handler card before I hire him/her?

A: No, but the employee must receive food safety training applicable to their job duties prior to working. This training must be provided by an employee of the hemp facility where the manufacturing employee is employed.  The person must then have a food handler card within 30 days of employment.

6. How can I tell if hemp product I purchase is semi-synthetic, or synthetic?

A: There are some obvious and not so obvious signs. The following can assist you when trying to make a determination: use of the following terms “synthesized”, “isomerization”, “derivatization”, “transformation”, and “cyclization”; Delta-9 product that has a high Total THC. While this may not always be true, product with a high Total THC (88% for example) would be expensive to process from a legal hemp plant; and perform an independent analytical analysis of the product. Most, if not all labs, can detect synthesized cannabinoids in a sample. Ensure the lab you choose can do so before proceeding.

7. I operate a bakery that infuses pastries with hemp ingredients, do I need a permit?

A: If you are using hemp-derived ingredients that are not hemp seed or hemp seed oil, yes a permit from CHB is required to possess and produce hemp infused products.  Contact us to obtain a permit application.

8. I make cannabis products that include hemp ingredients under my CCD license, do I need any type of permit from CHB?

A: Yes.  You will need a hemp warehouse or hemp manufacturing permit.  Please email us for further info.

9. What do the procedures for vomit and diarrheal event clean-up need to include?

A: At a minimum, all of the elements of the “Clean-up and Disinfection of Vomit or Diarrhea” handout found on the CHB Resources page.  This resource can be incorporated into your policies/procedures/SOPs and be your plan.

10. What are the new hemp finished product requirements?

A: The official requirements can be found in Section 12 of the hemp rule beginning on page 10.  A summary of the changes can be found on slides 23-24 of our hemp rule presentation.

11. What is an example of a hemp intermediate product?

A: A tincture base consisting of hemp distillate and MCT oil in a 5 gallon bucket that is waiting to be flavored and bottled in a one ounce bottle for sale.

12. What happens if I do not send in my renewal application and fee before my permit expires?

A: You will be assessed a $200 fee and will be required to close your operation until your new permit is issued.  All outstanding invoices must be paid prior to the approval of a renewal permit application.

13. I hear there is a 60-day grace period for certain requirements, which requirements are those?

A: See slides 19, 24, 28-29, and 31 of our hemp rule presentation.

14. Can I include things that are not required in the rule on my QR code?

A: Yes, the hemp rule does not prohibit you from providing additional information to consumers that click on your QR code.

15. With the analytical testing requirement changes, what do I now need to test for that I didn’t before?

A: First, pesticides as determined by CHB.  The pesticide panel is still pending and will be released prior to January 28, 2026.  The analytical testing must also now confirm the total THC per serving and per package limits and the CBD content per serving (per package is already required).  Analytical laboratories must also ensure that product determined to contain “nondetectable THC” meets the definition of broad spectrum.

16. If my finished product fails an analytical lab testing requirement, what do I need to do?

A: Have the original re-tested and then you and the analytical laboratory must independently notify CHB of the original and re-test results within 24 hours of the confirming test completion.

17. What should I prepare for before my next inspection?

A: All of the items listed in #1 of this frequently asked questions.

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