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What You Need to Know About Hemp-Derived Cannabinoid Licensing in Tennessee
Published: Dec 23, 2025
Tennessee’s new law for Hemp-Derived Cannabinoids starts New Year’s Day 2026. Here is the latest.
New Filing System
The Tennessee ABC's online filing system for Hemp-Derived Cannabinoids went live over the weekend. The Tennessee Department of Agriculture has closed its portal to new applications. Going forward, new HDC applications must be filed with the ABC.
The ABC is using Mockingbird for HDC licensing. Here is the ABC link for HDC.
We have not had the pleasure of filing a new application as of this posting. Send us feedback about your experience.
For whatever reason, the ABC has decided not to use RLPS for HDC. It remains to be seen whether license information from RLPS links to Mockingbird, or if the two systems are completely separate.
Lots of abbreviations to learn. The legal form of THC products in Tennessee is Hemp-Derived Cannabinoid – HDC. HDCP is Hemp-Derived Cannabinoid Products. Marijuana continues to be illegal in Tennessee. There is no medical marijuana or other exception.
New Rules
Although the new rules are not officially official, here is a copy of the final ABC rules for HDC. The rules were heard at a public hearing on September 26, 2025, and should be published and become “official” soon.
Grocers, C stores, and other all-age retailers get the green light to sell HDC until June 30, 2026.
The State of Tennessee entered into an Agreed Order that allows businesses that hold HDC licenses issued by the Department of Agriculture to continue to sell HDCP until the licenses expire. The order states that:
“no Legacy Licensee will be subject to Title 57, Chapter 7 of the Tennessee Code Annotated until the expiration or closure of the existing license but will instead remain subject to Title 43, Chapter 27, Part 2 of the Tennessee Code Annotated until its existing license expires."
Confused? Us too. Cuing Led Zeppelin:
Been dazed and confused
For so long, it's not true
Wanted a woman
Never bargained for you
It looks like at least some of the new law will NOT be enforced against businesses that hold HDC licenses issued by the Department of Agriculture. What does this mean? Once again, the batteries in our crystal ball appear to be dead.
According to news reports and our understanding of the order, grocery stores, convenience stores and other all-age retailers can continue to sell HDC under existing Agriculture HDC licenses, until the licenses expire on June 30, 2026.
The new law bans the sale of HDC in a business that allows patrons under the age of 21, except for retail package stores, restaurants, hotels and other liquor-by-the-drink businesses that also hold HDC licenses. Once the existing Agriculture HDC licenses expire on July 1, 2026, no more HDC sales for grocery and convenience stores. Unless the Tennessee Legislature changes the law during the upcoming legislative session.
Attached is a copy of the court order.
We have unanswered questions:
- Can a business that holds an Agriculture HDC license continue to sell HDCP in vending machines after January 1?
- Can a business that holds an Agriculture HDC license sell THCa and other HDC products that are currently legal, but prohibited under the new law? News reports say yes.
- Does a business that holds an Agriculture HDC license not have to card?
- Can a bar, restaurant, hotel or other LBD businesses that hold an Agriculture HDC license sell HDC to go after January 1?
Universal Carding for HDC Sales
The new law requires mandatory carding before every sale. Regardless of the age of the patron. We recommend that businesses selling HDC adopt the policy:
No ID
No HDC
Regardless of the agreed order discussed above, we recommend that businesses that hold ABC liquor licenses start mandatory carding for HDC beginning January 1. There is no reason to risk a citation from the ABC.
Keep in mind that bars, restaurants, hotels, and other LBD businesses are not required to card for sales of alcohol and beer. Although strictly liable for a sale to a minor, each business can establish its own procedures for preventing sales to minors.
Businesses that hold licenses for off-premise sales of alcohol and beer must card before every sale, unless the person appears to be over the age of 50. Mandatory carding applies to retail package stores, grocery stores, and convenience stores.
The new HDC law requires mandatory carding with no exception for individuals that appear to be over the age of 50. No exception.
The failure to card for an HDC sale is a violation of Tennessee law and can result in a citation from the ABC.
No to go sales for HDC at bars, restaurants, hotels and other LBD businesses.
The new law only allows bars, restaurants, hotels, and other LBD businesses to sell HDC for on-premise consumption. No HDCP to go.
We recommend that businesses implement methods to ensure that guests are not leaving the licensed premises with an HDC beverage or other HDC product that they purchase at the bar. Similar to the way that bars are required to prevent guests from leaving with a drink.
We suspect the ABC will issue a citation and impose a fine for a guest that leaves the premises with an HDC gummy, for example.
Stay tuned for more updates as the new law rolls out.
