Chances are, one of your first weed purchases was a nickel bag. For just $5, you and your friends could change the course of an afternoon by sharing a joint: painting the town red, watching a movie, cracking jokes. For Manhattan native Nicholas Koury and owner of Nicklz dispensary near Time Square, the nickel bag […]
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Welcome to the 10th annual “State of the State” post on Oregon cannabis. A great many things have changed over the years, and I’m planning to write another lookback post soon. For now, though, let’s cover everything that happened in 2025—which is a lot.
According to OLCC data, total sales from January 1 through November 30 were $848 million. That’s a 3.7% dip from the same period in 2024, where we saw $881 million in total sales. Does this mean that Oregon cannabis retailers are selling less product? No, it doesn’t. They may be selling more, in fact, at discount model pricing.
The miserable retail price trendline continued to fall throughout 2025. Within that trendline, the extracts/concentrates category hit a nadir of $15.00/gram (median) in the extracts/concentrates category in April, and again in November. The “usable marijuana” category also fell to a ghastly $3.33/gram (median) in April, and all but flatlined from that point. (Usable marijuana is essentially flower, in the OLCC milieu.)
There is no foreseeable end to the price depression: in fact, it may only get worse. Croptober 2025 was Oregon’s largest METRC harvest ever, with 6,289,890 pounds reported. This was a significant and unwelcome 8.9% increase from the October 2024 harvest, which itself was a record high. As I wrote last year:
“I’m sure the illicit market had a bumper year too; weather is the same for everyone and the enforcement paradigm is static… Consumers may benefit, but that can’t be great for pricing.”
That proved true in 2025, unfortunately, and it will happen again in 2026. As far as what people are actually buying at all of these OLCC stores, I compiled this table:
| 2025 | 2024 | Change +/- | |
| Usable marijuana | 43.6% | 46.2% | -2.6 |
| Concentrate/extract | 26% | 25% | +1.0 |
| Edible/tincture | 14.2% | 13.7% | +0.5 |
| Inhalable w/non-canna additives | 10.7% | 9.1% | +1.6 |
| “Other” | 4.9% | 5.4% | -0.5 |
| Industrial hemp | 0% (?) | 0.6% | -o.6 (?) |
Check out that drop in the usable marijuana category. In both 2023 and 2024 I noted a “years-long trend of usable marijuana sales decreasing per capita in favor of other categories.” We are not just seeing these SKU shifts in the data—we’ve had a series of farm clients lament that retailers are pulling back orders for flower, in response to consumer preference for vape and cartridge products.
Bottom line: People are buying more Oregon cannabis than ever, at lower prices than ever. There is also more cannabis in the OLCC market than ever. Surveying this abundance, customers aren’t burning flower like they used to, opting instead for packaged products. All of this makes for an extremely challenging business environment—especially for small farms, which continue to falter and fail.
Oregon’s years-long OLCC licensing moratorium was ratified by the legislature in 2024. We still have a “one-in, one-out” policy where outgoing licensees are allowed to surrender (sell) their licenses in favor of new market entrants, who acquire (buy) replacement licenses. Outside of this buy/sell paradigm, OLCC is “prohibited from accepting new license applications pretty much forever, due to restrictive, ratio-based formulas tied to population,” as I explained back when HB 4121 passed.
In 2025, license numbers declined marginally across the board as predicted. This was also the case in 2024 and 2023 due to the years-long moratorium, in concert with business failures. Here’s a table showing current license numbers as compared to this time last year:
| 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 |
| Research | 1 | 1 | none |
Numbers continue to fall at the slow drip we’ve seen for a couple of years, which is healthy. Most would agree that we have too many licenses across all categories—except perhaps for labs and research. Unfortunately, we lost a couple of labs this year, possibly tied to fallout from the October 2024 crackdown on THC inflation.
As far as pricing, we helped people buy and sell producer licenses at prices between $60K and $85K throughout the year, with prices rising in the last month or two. Most of these transactions are change-of-location and change-in-ownership scenarios, and most of the buyers are Chinese. Wholesale and processor licenses trade less frequently, and for lower prices; retail pricing is its own animal, largely dependent on store performance. That said, we did help sell a couple of change-in-location retail licenses in the $100K range.
OLCC has emphasized moving applications through the system quickly, which is welcome news. I met with a few OLCC staff last week, who articulated their goal of a “zero wait” time for change-in-ownership applications, their plans to enforce new rules requiring polished submissions, and requirements that applicants move quickly through the process.
The licensing protocol rules mentioned above come online on January 1, 2026, alongside rules that make some technical updates and implement the 2025 marijuana legislation. I covered these rules in a recent post, and I won’t summarize them further here.
Earlier this year, rules banning sales of most CBN products also took effect. I explained:
Beginning July 1, 2025, products containing artificially derived CBN can no longer be sold in Oregon, either in the OLCC system or in the general (hemp-derived) market, unless the manufacturer has made a “Generally Recognized as Safe” (GRAS) determination, or submitted a New Dietary Ingredient Notification to the FDA and received a “no objections” response.
To my knowledge, no one has acquired GRAS status or submitted a qualifying NDI notification. That’s not unexpected, and it’s also too bad.
The comprehensive hemp registry rules will take effect on January 1. These rules apply to hemp flower pre-rolls, as well as hemp beverages and tinctures containing cannabinoids like THC, CBD and others. The rules don’t apply to hemp items that are: a) sold at OLCC licensed stores, b) lacking cannabinoids, c) intended only for topical use, d) industrial or commercial feed products, or e) merely passing through the state.
A host of labeling and “claims” requirements for hemp products sold in Oregon also take effect next year. It remains to be seen if or how any of these new rules will interact with the recent federal ban on intoxicating hemp products, although I’m not expecting much friction. If the federal ban holds, we’ll likely just have fewer out-of-state registrants, and fewer inbound products beyond what is carved out in the CBD space.
For what it’s worth, earlier this year OLCC and other agencies published a report detailing that most hemp products in Oregon run hot. Not a great look, but not surprising either.
Oregon cannabis matters found their way to the courts in 2025. Our office handled a series of business and investor disputes, and there were some public skirmishes as well. Here is my short list:
I should include a bit on President Trump’s Executive Order of December 18, directing marijuana rescheduling. We’ve covered it comprehensively already, but Oregon cannabis businesses should be pleased.
Depending on the path Pam Bondi chooses, and the measure of resistance, marijuana could go to Schedule III in 2026. If so, many of our clients will realize better margins overnight. These businesses could also see less competition from out-of-state hemp operators, due to the federal ban mentioned earlier.
As always, trying to summarize a year’s worth of stories in this small space can be challenging. Let me know in the comments if I missed anything important. For prior posts in this series, check out the list below.
Best wishes to the Oregon cannabis industry and all of our clients in 2026.
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Wishing all of our readers, along with friends and families, the very best this holiday season.
Whether you celebrate Hanukkah, Christmas, Kwanzaa, Winter Solstice, Festivus, or something else, we hope you can kick back and enjoy this wonderful time of the year.
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Sesh by Sherlocks has grown to North Carolina's top destination for THCA flower after beginning as a glass museum.
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President Trump has just signed an executive order that accelerated rescheduling cannabis from Schedule 1 to Schedule 3.
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On Monday, the U.S. Supreme Court denied certiorari in Canna Provisions, Inc. et al. v. Bondi, a high-profile lawsuit that challenged the constitutionality of intrastate (and not interstate) cannabis activity. The denial offered no reasoning; nor was it accompanied by dissents or concurrences from any of the justices—all of which is typical. The upshot is that petitioner’s loss at the First Circuit Court of Appeals is final. Rest in peace, Canna Provisions.
We have been tracking and writing about this case since it was filed two years ago. We acknowledged the pedigree of David Boies and the lawyers involved, but ultimately, the effort left us uninspired. See:
In the aftermath of the Supreme Court’s denial on Monday, my colleague Jason Adelstone also offered this post mortem on LinkedIn:
This outcome is unfortunate but unsurprising given the fundamentally flawed strategy used to challenge Gonzales v. Raich. There were far more credible avenues for advancing this argument, most notably through sympathetic medical patients, rather than corporate actors operating in the adult-use market. From the outset, this case was designed for Supreme Court review. What the strategy failed to adequately account for, however, is the composition and conservatism of the current Court. Maybe next time the industry will support a case that has an actual chance to prevail.
Whether there is a “next time,” or what that would look like, is an open question—particularly with rumors aswirl about a Trump executive order on rescheduling marijuana. If marijuana lands on Schedule III, cannabis businesses would ultimately get the fair tax treatment sought by Canna Provisions, although banking, SBA loans and other amenities would still be impaired.
It would be somewhat ironic if the Department of Justice ultimately followed a Trump directive to reschedule marijuana at this time, given its posture last month in the Canna Provisions litigation. I explained:
[T]he DOJ declined to file a Supreme Court brief in the Canna Provisions case . . . . The DOJ’s position is curious, given that 1) the case strikes at the heart of the federal government’s ability to enforce federal laws, and 2) the federal government has been keen to weigh in on Supreme Court cannabis litigation, in the context of gun rights. As it stands, the Court will now decide whether to hear this case without executive branch input.
And that’s exactly what happened. It’s now time for everyone to move on to the next thing, which we’re told could be an executive order on rescheduling, announced as soon as tomorrow. As I explained in a Canna Provisions critique:
[M]arijuana reform is squarely a job for Congress or the executive branch. Not the judiciary. We need Congress to act, especially in the context of stalled Schedule III proceedings, and we need broader reforms than what Canna Provisions seeks. Those reforms include not just interstate commerce, but decriminalization and ideally reparations of some sort.
Schedule III will not get us interstate commerce, and it certainly wouldn’t bring decriminalization or reparations. But it’s a step in the right direction—especially while Congress cannot get organized on cannabis reform, aside from hemp. I don’t expect that to change prior to the 2026 midterms, which means the best hope for now is an executive order. Canna Provisions, rest in peace.
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Leafly's list of the top 100 US dispensaries, backed by data and costumer ratings. Find the best dispensaries in your state and beyond.
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