Four Bills, One Deadline, and an Industry on the Brink: A Practitioner’s Assessment of the Federal Hemp Legislative Landscape
Susan Burns
S Burns Legal PLLC | Top 200 Global Cannabis Lawyer
May 1, 2026
November 12, 2026 is not an abstraction. It is a hard deadline — one that, absent congressional action, will destroy a $28 billion industry, eliminate 328,000 jobs, and erase $13 billion in wages across the United States, according to Whitney Economics’ U.S. National Cannabinoid Report. It will also recriminalize products that millions of Americans use daily for sleep, anxiety, and relaxation — products that are, by any rational measure, safer than a glass of wine.
The industry that built itself on the promise of the 2018 Farm Bill is now navigating a legislative landscape that is as consequential as it is chaotic. Four meaningful options remain on the table. Each has merit. Each has cost. And none of them, standing alone, fully solves the problem.
This article examines those four options with the required candor: what each bill does, what it fails to do, and what practitioners advising clients in this space need to understand right now.
The hemp ban — the term used throughout this article as shorthand for the Section 781 prohibition on hemp-derived consumable products, not a ban on all hemp uses; hempcrete, fiber, and grain remain legal — did not arrive through the Farm Bill. It arrived through the back door of an appropriations package. Section 781 of the FY2026 Agriculture Appropriations Act (Public Law 119-37), signed by President Trump on November 12, 2025, fundamentally rewrote the federal definition of legal hemp. Effective one year from enactment — November 12, 2026 — the law imposes two changes that, in combination, are catastrophic for the consumable hemp market.
First, it replaces the 2018 Farm Bill’s delta-9 THC threshold (0.3% on a dry-weight basis) with a total THC standard that includes tetrahydrocannabinolic acid (THCA). Second, and more devastatingly for finished-product manufacturers, it imposes a cap of 0.4 milligrams of total THC per container. The U.S. Hemp Roundtable estimates this threshold will render 95% of hemp-derived consumable products currently on the market federally unlawful.
To be clear about what 0.4 milligrams means in practice: a single standard-dose CBD gummy containing 10 milligrams of CBD and trace delta-9 THC will likely exceed that threshold. The ban does not target high-dose intoxicating products alone. It targets the low-dose wellness market that has operated responsibly, with state regulatory oversight, for years.
Section 781 did not emerge from a vacuum. It emerged from a competitive market dynamic that the alcohol and marijuana lobbies both had reason to resolve in their favor. The hemp-derived THC beverage market had become a direct and measurable threat to spirits sales — including Kentucky bourbon — as younger Americans increasingly chose regulated, low-dose THC beverages over alcohol. Senator McConnell, who championed hemp legalization in the 2018 Farm Bill as a Kentucky agricultural victory, supported its recriminalization in 2025. The industry calls it a hemp ban. This article it should be called the Bourbon Bash — a provision driven less by public health concern than by market protection. The term is used here not as polemic but as analytical shorthand for a provision whose origins deserve scrutiny equal to its consequences.
The FDA was directed to publish guidance within 90 days of enactment — by February 10, 2026 — clarifying which cannabinoids are naturally occurring, which are THC-class, and which have similar effects to THC. The FDA missed that deadline. Operators are making capital decisions, planting decisions, and inventory decisions in a regulatory vacuum. That is the environment in which the following four legislative vehicles are being debated.
The State Opt-Out Model — Elegant in Theory, Limited in Practice
Introduced on April 16, 2026, by Senators Rand Paul (R-KY), Amy Klobuchar (D-MN), and Joni Ernst (R-IA), the Hemp Safety Enforcement Act takes a federalism-first approach. Any state or Tribal government may notify the federal government that it elects to opt out of the Section 781 ban and assume primary regulatory authority over hemp-derived cannabinoid products within its borders. To do so, the state must implement a minimum purchase age and maintain the ban on synthetic cannabinoids not naturally occurring in the hemp plant. No state may block the transportation or interstate commerce of compliant hemp products moving to or from other opt-out states.
The interstate commerce protection is the bill’s most important contribution — and the one most often misunderstood. After November 12, without legislative relief, states can theoretically maintain their own intrastate hemp markets under the same logic that allows marijuana states to operate under federal prohibition. State law is state law. But the moment a product crosses a state line, it becomes federal drug trafficking, regardless of what is legal in both the origin and destination states. S. 4315 creates the federal carve-out that permits commerce to flow between opt-out states, which is a meaningful, albeit incomplete, fix for multi-state operators.
The incompleteness of that fix indicates that the bill’s limitations deserve honest assessment.
The opt-out model does not restore a national market. It creates a patchwork of opt-out corridors. A brand currently selling into thirty states may find itself legally confined to fifteen — or ten, or eight — depending on which states opt out and the timeline. Operators in non-opt-out states are stranded. For national brands with diversified distribution, the managed contraction this bill produces may be preferable to total prohibition, but it is not a restored market.
The bill also imposes no federal product standards beyond the two baseline requirements noted above. Age restrictions and synthetic cannabinoid bans vary considerably across existing state frameworks. Practitioners in states with robust regulatory structures — Minnesota being one example — will likely find their clients well-positioned. Practitioners in states with minimal or no hemp regulatory infrastructure face a different calculation entirely.
There is also a latent conflict preemption risk that the bill does not fully resolve. Legal analysts at DLA Piper and others have noted that where a state law permits the sale of hemp-derived THC products above the new federal threshold, businesses cannot comply with both laws simultaneously. Federal enforcement — by DOJ or DEA — can target manufacturers, distributors, and retailers even in opt-out states if federal prosecutors take the position that opt-out status does not insulate conduct that violates the underlying federal definition of hemp. S. 4315 reduces that exposure but does not eliminate it. Litigation on this question is likely regardless of whether the bill passes.
Bottom line: as opposed to a hemp ban, S. 4315 substantially improves the legal landscape. The hemp consumable market is significantly contracted. The bill does not provide categorical federal immunity.
The Clean Delay — Necessary but Insufficient
H.R. 7024, the Hemp Planting Predictability Act, is the most structurally simple of the four options. It is a two-page bill that does exactly one thing: extends the Section 781 effective date from November 12, 2026 to November 12, 2028. No new regulatory framework. No definitional changes. No agency assignments. Two years of breathing room.
The bill carries 32 bipartisan co-sponsors in the House, including Rep. Angie Craig (D-MN), Ranking Member of the House Agriculture Committee, who has co-sponsored it from day one. A Senate companion bill has been introduced by Senators Klobuchar, Paul, and Jeff Merkley (D-OR). Notably, Minnesota simultaneously holds the top Democratic Agriculture post in both chambers — Senator Klobuchar as Senate Agriculture Ranking Member, Representative Craig as House Agriculture Ranking Member. That is not coincidence. It reflects a deliberate, coordinated state-level legislative strategy that deserves recognition.
For farmers who planted this spring expecting a legal market to sell into, H.R. 7024 is the difference between a viable crop and a field they cannot monetize. That said, many hemp farmers chose not to plant at all this season, opting for other crops rather than absorb the regulatory risk. No hard statistics exist yet on how many made that shift, but the trend is real and its consequences will compound: a contracted domestic hemp supply, combined with the Barr framework’s domestic-only sourcing requirement as discussed below, creates a supply chain squeeze that has received insufficient attention. For manufacturers sitting on compliant inventory, the bill is the difference between a going concern and an insolvency question. Its simplicity is a feature, not a bug: clean, narrow, and resistant to amendment.
The bill provides a welcome sigh of relief for the hemp industry, but its central weakness is that it does not provide predictability because it solves nothing permanently. The same fight will occur in 2028 — with the same bad actors, the same synthetic cannabinoid concerns, and potentially a less sympathetic Congress. It is worth acknowledging that most responsible operators in this industry do not actually want a pure delay. They want a solid regulatory framework — one that eliminates the bad actors producing synthetics and adulterated product in unregulated states, who are precisely the conduct that gave Congress the political cover to pass Section 781 in the first place. Two years of delay, without a coherent federal regulatory framework emerging in that window, risks validating Congress’s conclusion that the industry cannot police itself.
The procedural reality is also sobering. H.R. 7024 has been introduced but has no committee assignment, no hearing scheduled, and no markup session. Thirty-two co-sponsors represents meaningful political support, but co-sponsorship and floor votes are categorically different things. House Agriculture Committee Chairman Glenn Thompson (R-PA) has made clear he considers regulation of hemp-derived finished goods outside his committee’s jurisdiction — the province of Energy and Commerce and the FDA. The Senate Agriculture Committee has not marked up any farm bill in the 119th Congress. The path to a floor vote on a standalone delay bill, in this legislative environment, is difficult.
The Comprehensive Democratic Framework — Serious Legislation, Difficult Path
The Cannabinoid Safety and Regulation Act was introduced on December 10, 2025 — eighteen days after Section 781 was signed into law — by Senators Ron Wyden (D-OR) and Jeff Merkley (D-OR). It was the first comprehensive legislative response to the hemp ban and remains the most fully developed regulatory framework yet introduced in either chamber. At 84 pages, it is serious legislation, not a placeholder.
The CSRA’s core architecture deserves careful attention. It would establish federal product standards for hemp-derived consumables that are, in most respects, consistent with what responsible state-level regulatory frameworks — including Minnesota’s original framework under Minnesota Statute § 151.72 — have demonstrated can work. Edible and inhalable hemp products would be limited to 5 milligrams of THC per serving and 50 milligrams per container. Beverages — the fastest-growing segment of the hemp consumable market — would be capped at 10 milligrams per container, a threshold that aligns precisely with Minnesota’s existing regulatory standard and reflects actual consumer use patterns in a well-functioning market. A federal minimum purchase age of 21 would apply nationally. Synthetic cannabinoids would be prohibited. Mandatory testing, labeling, and packaging requirements would establish a federal floor, while states would retain authority to impose stricter standards within their borders.
The CSRA assigns the FDA as the principal regulatory and enforcement agency — a choice that is both logical and, given FDA’s track record in this space, its most significant structural vulnerability. As noted in Part I of this article, FDA was directed under Section 781 to publish cannabinoid classification guidance within 90 days of enactment. It missed that deadline by months, leaving the industry in a regulatory vacuum during precisely the period when operators most needed clarity. FDA has had seven years since the 2018 Farm Bill to establish a regulatory framework for hemp-derived consumables. It has not done so. Assigning FDA primary regulatory authority over a $28 billion market operating under a hard November deadline is an institutional bet that the agency’s recent performance does not fully support. This is not a fatal objection to the CSRA — it is an argument for specifying interim standards in the statute itself rather than leaving them to FDA rulemaking, a recommendation that applies with equal force to the Barr framework discussed in Part V.
Notably, the CSRA contains no domestic sourcing requirement. Hemp ingredients sourced from Canada, Colombia, and European Union member states — which supply a significant portion of the CBD isolate and broad-spectrum extracts used by United States manufacturers — would remain eligible under the CSRA framework. This avoids the supply chain disruption that the Barr framework’s domestic sourcing requirement creates, though it also foregoes the political benefit of domestic farmer support that the sourcing requirement is almost certainly designed to secure.
Senator Merkley’s positioning across the legislative landscape is worth noting explicitly. He is a co-sponsor of both the CSRA and the Senate companion to H.R. 7024 — the delay bill. That is deliberate legislative hedging: run the comprehensive regulation track and the delay track simultaneously, use whichever vehicle moves first, and keep the other in reserve. It is sound strategy and it signals that Senate Democrats are more coordinated on this issue than the public debate sometimes suggests.
The CSRA’s principal weakness is political rather than substantive. It is Democratic-led legislation in a Republican-controlled Congress, introduced in the immediate aftermath of a provision that passed with bipartisan support — including Democratic votes — in a must-pass spending bill. The bill has not received a committee hearing, a markup, or a floor vote in either chamber. S. 3474 was introduced on December 15, 2025 and referred to the Senate Committee on Health, Education, Labor, and Pensions, where it remains in the first stage of the legislative process. Its prospects as a standalone vehicle in the 119th Congress are limited. Its value, however, is not solely measured by whether it passes.
The CSRA establishes the most detailed public template for what a comprehensive hemp regulatory framework looks like. Its beverage standards, its age restriction model, its testing and labeling requirements, and its state preemption structure are all provisions that the Barr framework — and any eventual negotiated solution — will have to engage with. Practitioners advising clients on long-term compliance planning should be reading the CSRA alongside the Barr discussion draft, not instead of it.
The Comprehensive Framework — The Most Promising Path, With Real Trade-offs
The most consequential development in the federal hemp landscape in April 2026 is not yet a bill. It is a letter.
On April 21, 2026, Vince Haley, Director of the White House Domestic Policy Council, and James Braid, Assistant to the President for Legislative Affairs, sent hemp policy guidance directly to Representative Andy Barr (R-KY) — responding to draft legislative language Barr had submitted to the administration for comment. President Trump simultaneously posted on Truth Social calling on Congress to protect access to full-spectrum CBD. These are not routine communications. They signal that the executive branch is now actively engaged in shaping hemp legislation, which raises the political cost of congressional inaction and makes the Barr-White House track the most credible path to a comprehensive solution.
Representative Barr’s Lawful Hemp Protection Act — not yet formally introduced as of this writing, but circulating in discussion draft form with White House input — would establish the first comprehensive federal regulatory framework for hemp-derived consumer products. Its core provisions merit careful analysis.
What the Bill Gets Right
The bill’s first and most significant structural achievement is the bifurcation of industrial hemp from consumable hemp. For the first time in federal law, hempcrete, fiber, grain, and seed-based products would be treated as categorically distinct from a THC gummy or a CBD tincture — as they should be. This is not a technicality. The current framework’s failure to draw this line has caused enormous collateral damage to the industrial hemp sector and muddied the regulatory debate for years.
The 1% delta-9 THC threshold, measured on the finished product rather than on raw flower or in-process material, is arguably the single most important reform in any of the pending legislative proposals. The current 0.3% threshold, applied to raw plant material, has made compliant manufacturing extraordinarily difficult — because THC concentrations shift during processing and extraction. Testing at the finished-product level aligns the legal standard with manufacturing reality. The 1% threshold also aligns with the United Kingdom standard, above which a product is classified as medical — a convergence that has significant implications for international trade harmonization, discussed below.
The bill creates a protected category for “unfinished hemp ingredients” — oils, extracts, concentrates, and distillates in the manufacturing chain — within which delta-9 THC may temporarily exceed 1% during processing, provided the material does not enter retail commerce. This closes a gap that has created significant legal exposure for processors and manufacturers operating in full compliance with the spirit of the law.
Protecting all naturally occurring cannabinoids while prohibiting synthetics draws the correct line. The genuine public health concern animating Section 781 was not full-spectrum CBD oil. It was semi-synthetic cannabinoids — delta-8 THC, THC-O acetate, THCP, and similar compounds produced through chemical conversion of CBD isolate — marketed as hemp products but operating more like controlled substances. A bill that bans synthetics while protecting the full cannabinoid spectrum of the natural plant is intellectually honest in a way that Section 781 is not.
The assignment of TTB — the Alcohol and Tobacco Tax and Trade Bureau — as the principal licensing and enforcement agency is structurally sound. FDA has demonstrated, across seven years of post-Farm Bill inaction, that it lacks either the will or the institutional capacity to regulate the hemp consumable market. TTB brings 150 years of experience administering analogous markets — alcohol, tobacco — and an existing permit and licensing infrastructure that can be adapted without building a new regulatory agency from scratch. The two-tier distribution system for hemp beverages, modeled on the Federal Alcohol Administration Act, gives the industry the kind of institutional regulatory home it has never had.
Hemp Industry and Farmers of America (HIFA), one of the industry’s principal trade organizations, has publicly identified the core elements of the Barr framework — 21+ age restrictions, mandatory third-party laboratory testing, uniform labeling requirements, and child-resistant packaging standards — as precisely the regulatory structure the industry has been seeking.
Where the Bill Creates New Problems
The domestic sourcing requirement is the provision that deserves the most scrutiny. Under the draft language, a hemp-derived dietary supplement is deemed adulterated if it is not derived exclusively from hemp cultivated in the United States, processed within the United States, and finished, packaged, and labeled within the United States. Every step of the supply chain — from seed to shelf — must occur on American soil.
For manufacturers, the immediate concern is ingredients. A significant portion of the CBD isolate, broad-spectrum extracts, and other hemp-derived inputs currently used in United States consumer products is sourced internationally — from Canada, Colombia, and European Union member states where production costs are considerably lower. The domestic sourcing requirement would close the United States market to these inputs entirely, forcing manufacturers to source domestically at higher cost or exit the market. That pressure is compounded by the contraction already underway in domestic hemp supply: many farmers chose not to plant cannabinoid hemp this season, opting for corn and alfalfa rather than absorb regulatory risk. A mandate to source only domestically, against a backdrop of reduced domestic supply, is a supply chain problem that has not yet been adequately modeled by those drafting this legislation.
A related question that practitioners are already fielding from clients: does “packaged within the United States” mean the act of packaging — filling, sealing, and labeling — must occur on United States soil, or does it also require that the packaging materials themselves be domestically manufactured? The draft language does not define “packaged,” and this ambiguity matters enormously. Most United States hemp manufacturers source their containers, pouches, bottles, and labels from China, where the packaging supply chain for this industry is concentrated.
The better reading, consistent with how TTB administers analogous requirements in the alcohol and spirits industries, is that the act of packaging — not the provenance of the packaging materials — is what the requirement governs. TTB’s longstanding precedent is that packaging materials such as bottles, corks, capsules, and labels may be sourced internationally without affecting a product’s domestic status; what matters is where the filling and sealing operation occurs. TTB’s assignment as the principal agency under the Barr framework makes that interpretive precedent the most natural guide. Practitioners should monitor the rulemaking process closely for confirmation.
The international trade implications extend further. For international producers exploring United States partnerships, the domestic sourcing requirement effectively closes the United States market to foreign-sourced hemp ingredients. This cuts in multiple directions: it prevents the low-cost import flooding that European trade organizations have flagged as a concern, but it also constrains the ability of high-quality international producers to participate in the United States market on the merits. Whether that trade-off is worth the political benefit of securing domestic farmer support — which is almost certainly why the provision exists — is a question on which the industry should engage directly in the legislative process. The provision as written may also raise issues under existing United States trade agreement obligations, a dimension that, to this author’s knowledge, has not even entered the public debate.
The 18-month FDA rulemaking window to establish maximum allowable cannabinoid levels per serving creates a period of regulatory uncertainty that operators will find impossible to manage. The bill does not specify interim standards. Businesses trying to formulate products, secure financing, and make capital investments cannot wait 18 months for the rules to be written. Congress should consider whether interim safe harbor standards — keyed to existing state frameworks that have operated successfully — should be specified in the statute rather than left entirely to rulemaking. Minnesota’s former Minnesota Statute § 151.72 is instructive: a workable, purpose-built hemp framework that predated the state’s adult-use legalization and functioned well precisely because it treated hemp as hemp, not as a subset of cannabis. What followed — the progressive layering of cannabis regulatory requirements onto a hemp market for which they were never designed — is a cautionary tale in regulatory category error. A square peg forced into a round hole. Congress has the opportunity to avoid repeating that mistake at the federal level by specifying interim standards in the statute itself rather than leaving operators in an 18-month vacuum while FDA conducts rulemaking.
The 5% TTB user fee on retail sales is an additional cost burden on an industry operating on thin margins. Whether it is worth paying for regulatory legitimacy is a genuine debate — the alcohol industry has operated under TTB oversight and excise taxation for a century and has not been destroyed by it. But the fee, combined with the domestic sourcing cost premium, the 18-month rulemaking gap, and the TTB permitting requirements, creates a cumulative compliance burden that will disproportionately affect small and mid-sized operators. It is also worth saying plainly that this burden does not fall only on businesses. It will ultimately be felt by the consumers who rely on these products — including older adults on fixed incomes who have found effective, relatively affordable relief for sleep, aches, and anxiety in hemp-derived wellness products. Regulatory legitimacy has a price. That price is eventually passed to the consumer.
No assessment of the current legislative landscape is complete without acknowledging what colleagues like James Thorburn have raised publicly: at what point does an industry simply refuse to comply?
The litigation question has two dimensions. The first is constitutional: there are credible arguments that Section 781’s 0.4 milligram per-container threshold is arbitrary and capricious, that the FDA’s failure to meet its 90-day guidance deadline creates an enforceable procedural defect, and that the application of the total THC standard to naturally occurring, non-intoxicating cannabinoids raises substantive due process concerns. These are not the only viable legal theories in play. Other substantive challenges are being developed by practitioners in this space — arguments that, for strategic reasons, have not yet been made public. These arguments have not yet been tested in court. That is a problem. November 12 is the enforcement date, not the damage date. The industry is already experiencing the economic consequences of the ban — in planting decisions foregone, capital withdrawn, supply chains unwound, and inventory that cannot be moved. Waiting for the deadline to litigate means waiting until the patient has already bled out.
The second dimension is practical: federal enforcement of a ban that would recriminalize products currently sold in thousands of retail locations across 40+ states, and used by one in five American adults — a figure confirmed by the 2022 National Survey on Drug Use and Health — is an enormous undertaking for agencies that have historically lacked the appetite for it. Whether DOJ and DEA will aggressively enforce the November 12 deadline — or whether they will exercise prosecutorial discretion while the legislative process continues — is a question that no one can answer with confidence today. The Trump administration’s own Executive Order 14370 and the Truth Social post suggest the executive branch does not want to be in the business of arresting CBD users. But executive branch preference and federal law are different things.
That said, no one can rely on enforcement discretion as a compliance strategy. The risk profile of that approach is asymmetric: the downside is federal prosecution; the upside is temporary continued operation. Clients who choose to operate after November 12 without legislative relief should do so with full awareness of that risk.
The honest answer is that none of the four bills, standing alone, is sufficient.
S. 4315 solves the interstate commerce problem for opt-out states but produces a patchwork national market and leaves conflict preemption issues unresolved. H.R. 7024 buys two years but solves nothing permanently and faces a difficult legislative path. The CSRA is the most fully developed regulatory framework in either chamber but faces an uphill political path in a Republican-controlled Congress. The Barr-White House track offers the most durable and politically viable solution but contains a domestic sourcing requirement that will impose real costs on manufacturers, leaves an 18-month regulatory vacuum while FDA conducts rulemaking, and raises unresolved international trade questions.
The optimal outcome, the legislative process being what it is, would be H.R. 7024 as a bridge and the Barr framework as the destination — informed by the CSRA’s more detailed product standards, particularly on beverage THC limits, and with the domestic sourcing requirement refined to address the packaging materials ambiguity, existing treaty obligations — including potential conflicts with WTO national treatment rules and USMCA — and the broader international trade implications, and with interim safe harbor standards specified in statute rather than deferred to an 18-month rulemaking.
The White House engagement changes the calculus significantly. An executive branch on record — with a detailed policy framework in hand, transmitted formally to a congressional sponsor — is a different political actor than an executive branch that signed a ban and moved on. The cost of inaction has risen for congressional leadership. The Barr-White House track, even without formal introduction, has created a focal point around which a legislative solution can coalesce.
What the industry must do in the meantime is what it has too often failed to do: demonstrate that it can self-regulate. The operators who maintain rigorous testing protocols, accurate labeling, age verification, and product quality standards are the industry’s best argument to Congress. The operators who do not are the industry’s biggest liability. The difference between a regulated $28 billion industry and a prohibited one may ultimately come down to whether the former can make the case that it deserves to exist — not just economically, but as a matter of public health and consumer protection.
That case rests on what the data actually shows. Pediatric cannabis incidents reported to poison control centers have risen in recent years — but that data requires context. Research published in the Journal of Medical Toxicology found that exposure rates were significantly lower in states where cannabis was legal and regulated, and significantly higher in unregulated states. The incidents cluster where there is no regulatory framework, not where responsible operators are selling age-verified, properly labeled, low-dose products through licensed channels. The industry’s strongest argument is not that incidents do not happen — it is that regulation is precisely the tool to prevent them. On lethality, the comparison is stark: cannabis has no documented fatalities as a sole cause. Alcohol causes approximately 178,000 deaths annually, including roughly 4,000 among people under 21, according to CDC data. Common OTC medications, including acetaminophen, are among the leading causes of pediatric poisoning fatalities. The relative risk profile of hemp-derived consumables is not even in the same universe. That case has to be made clearly, consistently, and by voices with credibility — including practitioners.
November 12, 2026 is approximately five months away. The Farm Bill has moved forward without hemp relief. The Comer amendment was withdrawn. Four vehicles remain: S. 4315, H.R. 7024, the CSRA, and the Barr-White House track. None is perfect. All are worth fighting for.
Practitioners advising clients in this space should be doing four things right now: auditing supply chains for domestic sourcing compliance in anticipation of the Barr framework; documenting state regulatory compliance meticulously for S. 4315 purposes; advising clients on inventory and capital decisions in light of the November 12 deadline; and engaging — directly, through trade associations, and through public comment — in the legislative and regulatory process.
The clock is still running. November 12 has not moved.
Susan Burns is a Top 200 Global Cannabis Lawyer and founding partner of S Burns Legal PLLC, a St. Paul-based firm specializing in hemp and cannabis law. She is a Council Member of the Minnesota State Bar Association Section of Rural and Agricultural Law, a member of the International Cannabis Bar Association, and Founder of the Food, Agriculture, and Cannabis Committee of the ABA Section of International Law. She has published previously in the Cannabis Law Journal and writes the newsletter Hemp, Law & Luxury: Beyond the Minibar.