On Dec 11, 2026, the federal definition of hemp switches to total THC, and finished products are capped at 0.4 mg of total THC per container. The date was Nov 12 until the September funding bill moved it. It can move again, because it's tied to the same funding deadline. Plan as if it holds, and treat any delay as extra time, not a reprieve.
This is the list we're working through in our own stores. It's in the order that matters.
This month
- Know your state's line. Some states are already stricter than the federal rule. Virginia's Consumer Protection Act exposure starts Nov 1. Read your state playbook first.
- Map every SKU. One sheet: product, total THC per container, COA date, quantity on hand, quantity on order. Anything over 0.4 mg per container gets a sell-through date.
- Stop reordering what you can't sell by Dec 10. The biggest losses we've seen in banned states weren't fines. They were pallets that arrived after the line.
- Pull every COA. Current, matched to the batch on your shelf, printed, in a binder at the counter.
- Card everyone 21+. Even where it isn't required yet. It's what every pending bill asks for, and it's what an inspector notices first.
Before Thanksgiving
- Line up replacement products. Non-intoxicating CBD, compliant low-dose items, accessories, whatever fits your customers. Supplier lead times won't be shorter in December.
- Start capturing your customers. A counter QR and a text sign-up. The store that can reach its people after the rules change is the store that keeps them. See building a list from zero.
- Brief your staff. What changes, what to say to customers, and what to do if someone official walks in. See at the counter.
The first week of December
- Plan the last week. Pricing for sell-through, what comes off the shelf on Dec 10, where compliant stock goes.
- Have a lawyer's number on paper. Not to call today. To have when you need it.
None of this is legal advice. It's what operators are doing. If you want the version for your state and your shelf, ask the Desk.