Michigan

Michigan operates one of the country’s earliest-established adult-use cannabis markets (MRTMA, 2018) and has taken an incrementally tightening approach to intoxicating hemp regulation. In October 2021, the Cannabis Regulatory Agency (then Marijuana Regulatory Agency) issued a landmark order classifying delta-8 THC and THC-O-acetate as marijuana subject to MRA licensing — effectively banning their sale in convenience stores, gas stations, tobacco shops, and vape shops overnight. THCA has received similar skepticism: while not the subject of a formal ban, CRA guidance treats potent THCA products as functionally equivalent to marijuana requiring cannabis licensing. In 2024, Public Act 220 (HB 4517) amended Mich. Comp. Laws §333.27953 to establish a 1.75mg total THC per serving threshold for hemp consumable products — under that cap, general retail sale is permitted; above it, products fall into the CRA-regulated cannabis channel. Draft CRA administrative rules from November 2024 further specify 10mg/package limits and a required CBD:THC ratio of at least 15:1 on those consumables. December 2025 brought a legislative push in the Michigan Senate to further formalize the framework — SB 599 (the Consumable Hemp Product Act) would create a CRA-administered licensing regime for consumable hemp with civil fines up to $10,000, and companion bills would add hemp beverage permits under the Liquor Control Code. Federal Section 781 (November 12, 2026) will preempt significant portions of Michigan’s 1.75mg lane — the state framework is likely to formally narrow to align with the federal 0.4mg/container ceiling by early 2027.