The US state of Missouri has legalized the use of marijuana for medicinal purposes and laid the foundation for a state-regulated cannabis market. In this document, we’ll provide some basic information on how to get a marijuana business license in Missouri as well as a comprehensive list of links to forms and applications and additional resources.

Earlier Attempts at Cannabis Reform

Missouri’s cannabis policy reform efforts kicked off in May 2014 with the passage of Senate Bill 491. Although the measure reduced penalties for lesser cannabis offenses and removed jail time for first offenders caught with under 10 grams of marijuana, it did not decriminalize the possession of marijuana. Though the bill passed in 2014, the law did not take effect until January 2017.

The same year the bill passed, however, Governor Jay Nixon signed into law House Bill 2238, the Missouri Medical Marijuana Bill. Lawmakers used the term “medical marijuana,” however, technically, the bill does not legalize the use of marijuana but rather CBD oil made from the extracts of hemp. Furthermore, the only approved use was to treat persistent seizures.

Most notably, the measure did not provide for a state-regulated market but rather tasked the Department of Agriculture with growing industrial hemp and producing hemp extracts.

Under the law, hemp extracts must contain a minimum of 5% CBD and a maximum of 0.3% THC. In 2015 the DOA issued licenses to two non-profit groups to grow CBD-rich hemp.

Given the fact that CBD oil is readily available both online and in stores in many areas of Missouri, the program gained little traction in the state.

Medical cannabis legalization (2018)

Four years after the CBD-only program was instituted, in November 2018, Missouri voters approved Amendment 2, a ballot measure created to legalize medical marijuana and create a state-regulated market. The bill set a 4% tax rate on marijuana sales with proceeds to be earmarked for veterans services.

The law permits doctors to recommend the use of medical marijuana for a list of qualifying medical conditions as well as any "chronic, debilitating or other medical condition," or any terminal illness.

Marijuana Business Daily projects that the program could peak at $175 million-$275 million in annual sales within several years of the launch.

Two competing ballot initiatives also on the 2018 ballot, Amendment 3 and Proposition C, were both defeated.

Implementation

The Missouri Department of Health and Senior Services developed the proposed rules and filed them with the Missouri Secretary of State in May 2019. Those rules, initially implemented as “emergency rules,” went into effect on June 3, 2019, and are now posted on the DHSS website.

The agency began accepting applications for dispensary, manufacturing, testing laboratory and transportation facilities Licenses on August 3, 2019. The application period has since closed.

By the time the application window had closed, the agency had received more than 2,100 applications, 1,200 of which came in the last three days, and 800 of those came in in the final 24 hours.

The state has 150 days from the date of submission to process the applications.

All applications are being blind-scored by a third party — Nevada-based Wise Health Solutions.

DHSS has set the number of licenses at 60 cultivation facilities, 192 dispensaries, 86 medical marijuana-infused manufacturing facilities and 10 testing laboratory facilities.

Dispensary licenses will be divided among eight congressional districts with up to 24 dispensaries per district.

The number of applications submitted for each type of cannabis facility are as follows:

554 applications cultivation facility licenses
1,163 applications for dispensary licenses
415 applications for manufacturing licenses
17 applications for testing lab licenses
14 applications for transport licenses

According to officials, the majority of applications were submitted by large, multistate marijuana operators and wealthy residents.

The St. Louis Post-Dispatch has identified Massachusetts-based Curaleaf, which has licenses in 13 states, as one of the multistate operators. And at least nine out-of-state companies from Arizona, Illinois, Kansas, Pennsylvania, and Tennessee also submitted applications.

Noah’s Arc Foundation and BeLeaf Medical, the two companies licensed to grow hemp for CBD have also applied.

These licenses must be awarded by Dec. 31.

DHHS will not begin accepting applications for facility agents (employees working within medical marijuana facilities) until licenses have been awarded. The application fee will be $75.

The DHSS began processing medical marijuana patient and caregiver applications on June 28 and has since approved more than 6,500 applications.

Missouri Medical Marijuana General License Application Requirements

Please note that the application period for cultivator, manufacturer, dispensary, and testing licenses has closed.

All applications for facility licenses or certifications and for renewals of licenses or certifications must include at least the following information:

Name and address of the primary contact for the applicant facility;
Legal name of the facility, including fictitious business names, and a certificate of good standing from the Missouri Office of the Secretary of State;
A completed Ownership Structure Form, included herein, which must show the applicant entity is majority owned by Missouri residents, and a written description or visual representation of the facility’s ownership structure including all entities listed on the Ownership Structure Form;
For each owner claiming Missouri residency for purposes of subsection (C) of this section, a statement that the owner has resided in Missouri for at least one year and does not claim resident privileges in another state or country, as well as proof of current Missouri residency, which shall be shown by:

A copy of a valid Missouri driver’s license, a Missouri Identification Card, a current Missouri motor vehicle registration, or a recent Missouri utility bill; or
If none of these proofs are available, some other evidence of residence in Missouri, which shall be approved or denied at the discretion of the director of the medical marijuana program as sufficient proof of residency;

A list of all facilities licensed or certified or applying for licensure of certification in Missouri to cultivate, manufacture, dispense, or test medical marijuana that are or will be under substantially common control, ownership, or management as the applicant. For each facility listed, a written explanation of how the facility is under substantially common control, ownership, or management as the applicant, with supporting documentation;
Proposed address of the facility and

A map of the surrounding area that shows compliance with the facility location requirements of subsection (4)(B) of this rule or 19 CSR 30-95.100(2)(C); or
Documentation showing a local government requirement different than the requirement in subsection (4)(B) of this rule or 19 CSR 30-95.100(2)(C) and a map of the surrounding area that shows compliance with the facility location requirements of the local government; and
An attestation that the proposed address of the facility complies with the facility location requirements of subsection (4)(B) of this rule or 19 CSR 30-95.100(2)(C);

Descriptions, schematics, or blueprints for the facility;
If the city, town, or county in which the facility will be located has enacted zoning restrictions applicable to the facility, the text of the restrictions and a description of how the facility plans to comply with those restrictions;
An attestation that no individual who owns the facility, in whole or in part, has a disqualifying felony offense;
A statement confirming that all owners who hold any portion of the economic or voting interest of the facility who will also have access to medical marijuana or the medical marijuana facility, and all officers, directors, board members, managers, and employees identified in the application, have submitted fingerprints within the previous six months for a state and federal fingerprint-based criminal background check to be conducted by the Missouri State Highway Patrol;
All facility evaluation information required by 19 CSR 30- 95.025(4); and
All applicable fees or proof that all applicable fees have already been paid.

Missouri cannabis application and license fees are as follows:

LICENSE TYPE APPLICATION FEE LICENSE FEE
Production Facility $10,000 $25,000
Dispensary $6,000 $10,000
Infused-product manufacturing facilities $6,000 $10,000

All application fees are non-refundable.

Missouri Medical Marijuana Cultivation License Regulations

The Missouri Medical Marijuana Cultivation License permits the holder to grow, process, store, transport, and sell marijuana to a Medical Marijuana Dispensary Facility, Testing Facility, or Infused Products Manufacturing Facility.

Each facility is required to hold a separate license. However, applicants are permitted to hold up to three licenses and multiple licenses may be utilized in a single facility.

Once awarded a cultivation license is valid for 3 years after which time it must be renewed.

Cultivation Facility Requirements

In addition to the requirements for cultivation facilities in 19 CSR 30-95.040, cultivation facilities shall also comply with the following:

Cultivation facilities may cultivate medical marijuana in indoor, outdoor, or greenhouse facilities.

Each indoor facility utilizing artificial lighting will be limited to no more than 30,000 square feet of flowering plant canopy space.
Each outdoor facility utilizing natural lighting will be limited to no more than 2,800 flowering plants.
Each greenhouse facility using a combination of natural and artificial lighting will be limited to, at the election of the licensee, either no more than 2,800 flowering plants or no more than 30,000 square feet of flowering plant canopy space.
If a cultivation facility is operating with multiple cultivation licenses in the same location, the size limitations of the cultivation facility will be multiplied by the number of licenses;

Facilities must keep records, by month and by batch, of all pesticides, herbicides, fertilizers, and other agricultural chemicals applied to marijuana plants and growing medium during production and processing at its facility for at least five years;
Facilities, except those in rural, unincorporated agricultural areas, must develop, implement, and maintain an odor control plan, which shall address odor mitigation practices including, but not limited to, engineering controls, such as system design and operational processes, which shall be reviewed and certified by a professional engineer or a certified industrial hygienist as sufficient to effectively mitigate odors for all odor sources;
Cultivation facilities must ensure all facility employees are trained in at least the following:

The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana;
Proper use of the statewide track and trace system;
Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions;
Standards for maintaining the confidentiality of information related to the medical use of marijuana, including, but not limited to, compliance with the Health Insurance Portability and Accountability Act of 1996;
The methods of cultivation used by the facility; and
The facility’s safety and sanitation procedures; (E) Cultivation facilities shall not transfer medical marijuana from the facility, except to a testing facility, until the medical marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and the cultivation facility has received verification from the testing facility that the medical marijuana passed all required testing;

Cultivation facilities may only transport medical marijuana—

That the facility cultivated;
To a dispensary, testing, or manufacturing facility; and
If the facility complies with the requirements of 19 CSR 30- 95.100(2); and

Cultivation facilities shall store all medical marijuana—

At the approved location of the facility; or
In offsite warehouses that comply with the security requirements of 19 CSR 30-95.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C).

Further details on Missouri medical marijuana cultivation facility requirements can be found here.

Missouri Medical Marijuana Manufacturing License Regulations

The Missouri Medical Marijuana Manufacturing License permits the holder to store, manufacture, transport, and sell marijuana-infused products to a Medical Marijuana Dispensary Facility, Testing Facility, or to another Medical Marijuana-Infused Products Manufacturing Facility.

Each facility is required to hold a separate license. However, applicants are permitted to hold up to three licenses and multiple licenses may be utilized in a single facility. Once awarded a cultivation license is valid for three years after which time it must be renewed.

Manufacturing Facility Requirements

In addition to the requirements for manufacturing facilities in 19 CSR 30-95.040, manufacturing facilities shall also comply with the following:

Facilities must ensure all facility employees are trained in at least the following:

The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana;
Proper use of the statewide track and trace system;
Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions;
The differences between the types of infused products manufactured at that facility and their methods of production; and
The facility’s safety and sanitation procedures;

Facilities must develop, implement, and maintain an odor control plan, which shall address odor mitigation practices including, but not limited to, engineering controls, such as system design and operational processes, which shall be reviewed and certified by a professional engineer or a certified industrial hygienist as sufficient to effectively mitigate odors for all odor sources;
Manufacturing facilities shall not transfer medical marijuana from the facility, except to a testing facility, until the medical marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and the manufacturing facility has received verification from the testing facility that the medical marijuana passed all required testing;
Manufacturing facilities may only transport medical marijuana—

That the facility manufactured;
To a dispensary, testing, or other manufacturing facility; and
If the facility complies with the requirements of 19 CSR 30- 95.100(2);

Manufacturing facilities that produce ingestible medical marijuana-infused products shall comply with the applicable food safety standards set forth in 19 CSR 20-1.025, 19 CSR 20-1.040, and 19 CSR 20-1.050, as applicable. Such facilities are prohibited from producing frozen desserts, as defined by 19 CSR 20-1.030, or acidified foods, as defined by 19 CSR 20-1.042;
Manufacturing facilities shall store all medical marijuana—

At the approved location of the facility; or
In offsite warehouses that comply with the security requirements of 19 CSR 30-95.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C); and

Manufacturing facilities that use volatile solvents shall install air-handling systems and other controls designed to minimize the risks of explosions and fires. These controls should include systems to prevent ignition; plans for safe storage, use, and disposal of solvents; and policies for continuous staff monitoring of all processes involving volatile solvents.

Further details on Missouri medical marijuana manufacturing facility requirements can be found here.

Missouri Medical Marijuana Dispensary License Regulations

The Missouri Medical Marijuana Dispensary License permits the holder to acquire, store, sell, transport, and deliver marijuana, marijuana-infused products, and drug paraphernalia used to administer marijuana.

Each facility is required to hold a separate license. However, applicants are permitted to hold up to five licenses and multiple licenses may be utilized in a single facility. Once awarded a cultivation license is valid for three years after which time it must be renewed.

The number of dispensary facility licenses will be limited to 192 unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients.

Dispensary facility licenses will be limited to 24 in each of the eight United States congressional districts in the state of Missouri as drawn and in effect on December 6, 2018.

Map of boundary lines of Missouri’s congressional districts.

A facility license will be issued for a single facility in a single location. Combinations of licenses at the same location must be approved pursuant to 19 CSR 30-95.040(4)(C).

Dispensary Facility Requirements

In addition to the requirements of 19 CSR 30-95.040, dispensary facilities shall also comply with the following:

Dispensary facilities must ensure all facility employees are trained in at least the following:

The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana;
Proper use of the statewide track and trace system;
Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions;
Standards for maintaining the confidentiality of information related to the medical use of marijuana, including, but not limited to, compliance with the Health Insurance Portability and Accountability Act;
Procedures for verifying the identity and purchase limitations of qualifying patients and primary caregivers;
The differences in the purported effects and effectiveness of the strains of medical marijuana available for purchase at that dispensary and the methods of their use; and
Recognizing signs of medical marijuana abuse in patients;

Dispensary facilities must make available to all customers patient education materials that include at least the following:

Local resources for concerns about addiction, as well as the phone number for the Substance Abuse and Mental Health Services Administration’s National Helpline;
Information about the different strains of medical marijuana available at that dispensary and the purported effects of the different strains;
Information about the purported effectiveness of various methods, forms, and routes of administering medical marijuana;
Information about potential risks and possible side effects of medical marijuana use, including risk of poisoning and the phone number for the closest poison control center; and
The prohibition on consuming marijuana for medical use in a public place, including the definition of what constitutes a public place pursuant to this rule;

Dispensary facilities must, for every transaction—

Receive the transaction order at the dispensary directly from the qualifying patient or primary caregiver in person, by phone, or via the internet, and not from a third party;
At the time of sale, verify through the statewide track and trace system that the qualifying patient or primary caregiver is currently authorized to purchase the amount of medical marijuana requested and, in the case of a seed purchase, that the patient or primary caregiver is currently authorized to cultivate medical marijuana;
In the case of a delivery order, receive payment before the medical marijuana leaves the dispensary, subject to refund if the delivery cannot be completed; and
At the time of sale or delivery, require production of a qualifying patient or primary caregiver identification card, a government issued photo ID, and in the case of medical marijuana seed purchases, a patient cultivation identification card;

Dispensary facilities must report any incident of theft or attempted theft of medical marijuana to the department within twenty-four (24) hours of the incident;
Dispensary facilities must design their facility and staffing in such a way as to accomplish the following:

The general public, qualifying patients, and primary caregivers may only enter the facility through one access point into an area where facility agents shall screen individuals for qualifying patient or primary caregiver status. No medical marijuana may be accessible in this area;
Only qualifying patients, primary caregivers, and, if requested by a qualifying patient, up to two additional persons to support the qualifying patient, may enter any areas beyond the facility’s access point area; and
In any limited access area where medical marijuana is accessible, the facility shall only allow access at any given time for a number of qualifying patients and/or primary caregivers equal to the number of staff available to serve those individuals at that time;

Dispensary facilities shall not sell medical marijuana until the medical marijuana has been tested by a testing facility, according to the provisions of 19 CSR 30-95.070, and been verified as passing all required testing;
Dispensary facilities may only transport medical marijuana—

To qualifying patients, primary caregivers, testing, manufacturing, and other dispensary facilities; and
If the facility complies with the requirements of 19 CSR 30- 95.100(2);

Dispensary facilities that sell ingestible medical marijuanainfused products shall comply with the applicable food safety standards set forth in 19 CSR 20-1.025;
Dispensary facilities shall store all medical marijuana—

1. At the approved location of the facility; or
2. In offsite warehouses that comply with the security requirements of 19 CSR 30-95.040(4)(H), the location requirements of 19 CSR 30-95.040(4)(B), and that have been approved pursuant to 19 CSR 30-95.040(3)(C);

Dispensary facilities shall only sell medical marijuana seeds acquired from cultivation facilities;
Dispensary facilities shall not sell medical marijuana to a qualifying patient or primary caregiver in amounts greater than what that individual is currently authorized to purchase per the statewide track and trace system;
Dispensary facilities shall not sell medical marijuana seeds to a qualifying patient or primary caregiver who is not currently authorized to cultivate medical marijuana;
Dispensary facilities may accept returns and issue refunds or credits as needed except that medical marijuana that has been removed from the packaging in which it arrived at the dispensary, whether removed before sale by the dispensary or after sale by a patient or caregiver, may not be accepted as a return;
Dispensary facilities shall not disburse medical marijuana as part of a promotional event. If a facility disburses medical marijuana free of charge for any other reason, the facility shall record that disbursement of product in its seed-to-sale system with all relevant entries, including the qualifying patient or primary caregiver information and the amount of medical marijuana disbursed to that qualifying patient or primary caregiver;
Dispensary facilities shall not allow consumption of medical marijuana on their licensed premises; and
Dispensary facilities shall not allow physicians to meet with individuals on the dispensary’s premises for the purpose of certifying them as qualifying patients.

Further details on Missouri medical marijuana dispensary facility requirements can be found here.

Missouri Medical Marijuana Testing License Regulations

The Missouri Medical Marijuana Testing Facility certification permits the holder to acquire, test, certify, and transport marijuana. The state is required to license at least two testing facilities.

Medical Marijuana Testing Facilities may not be owned by an entity under with control, ownership, or management of a Medical Marijuana Cultivation Facility, Medical Marijuana Infused Products Facility, or Medical Marijuana Dispensary Facility.

The number of testing facility certifications will be limited to ten unless the department determines the limit must be increased in order to meet the demand for medical marijuana by qualifying patients.

Testing Facility Requirements. In addition to the requirements of 19 CSR 30-95.040, testing facilities shall also comply with the following:

Testing facilities must ensure all facility employees are trained in at least the following:

The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of marijuana;
Proper use of the statewide track and trace system; and
Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions;

Testing facilities shall comply with International Organization for Standardization (ISO) 17025 standards for personnel at all times;
During any periods of time when a facility no longer complies with ISO 17025 standards for personnel, the facility shall not conduct testing of medical marijuana. Upon return to compliance, the facility shall not resume testing until the department conducts an inspection of the facility;
Testing facilities shall become fully accredited to the standard set forth by ISO 17025 by an International Laboratory Accreditation Cooperation recognized accreditation body. Testing facilities shall achieve such accreditation within one year of the date the facility receives department approval to operate and shall maintain its accreditation as long the facility holds a certification.
Testing facilities shall participate in a proficiency testing program provided by an organization that operates in conformance with the requirements of ISO/IEC 17043 at least twice in a calendar year.
Testing facilities shall install and maintain security equipment designed to prevent unauthorized entrance into limited access areas, which shall include any area where medical marijuana is tested, stored, or disposed, and to prevent diversion and inversion of medical marijuana.
Testing facilities shall maintain all sampling and testing records for five years; and
Testing facilities may only transport medical marijuana—

That the facility intends to test;
From cultivation, dispensary, manufacturing, and other testing facilities;
If the facility complies with the requirements of 19 CSR 30- 95.100(2).

Sampling Requirements

Sampling and testing of medical marijuana shall be done at the lot level.

Sampling and testing of each harvest lot or process lot shall be conducted with representative samples such that there is assurance that all lots are adequately assessed for contaminants and that the cannabinoid profile is consistent throughout.

Refer to the rules for further details on testing requirements.

Missouri Medical Marijuana Transportation License Regulations

The authority to transport from one type of facility to certain other facilities is inherent in each license/certification. The definitions for each facility type indicate to which facilities that facility type may transport marijuana. If a facility wishes to transport to any entity or person not listed in the applicable definition, the facility will need to apply for a transportation certification.

All facilities, whether transporting under a transportation certification or another facility type license/certification, are subject to the operational requirements in the transportation rule.

Transportation certification applicants not holding a cultivation, manufacturing, dispensary or testing license are only required to fill out information on the online registry and do not need to fill out any of the worksheets. However a document must be uploaded in the Documents Tab for Worksheets 1-17 for the on-line system to process an application. Any document including a blank document can be uploaded.

The department will certify all transportation facilities that can demonstrate they meet minimum standards as described in 19 CSR 30-95.025(4)(A).

A facility license will be issued for a single facility with a single, primary place of business. Combinations of licenses at the same location must be approved pursuant to 19 CSR 30-95.040(4)(C).

Transportation Facility Requirements

In addition to the requirements for transportation facilities in 19 CSR 30-95.040, transportation facilities shall also comply with the provisions of this section.

Transportation facilities must ensure all facility employees are trained in at least the following:

The use of security measures and controls that have been adopted by the facility for the prevention of diversion, inversion, theft, or loss of medical marijuana;
Proper use of the statewide track and trace system;
Procedures for responding to an emergency, including severe weather, fire, natural disasters, and unauthorized intrusions; and
Standards for maintaining the confidentiality of information related to the medical use of marijuana, including, but not limited to, compliance with the Health Insurance Portability and Accountability Act of 1996.

Transportation facilities shall transport all medical marijuana from an originating facility to a destination facility within 24 hours. When extenuating circumstances necessitate holding medical marijuana longer than 24 hours, the transportation facility shall notify the department of the circumstances and the location of the medical marijuana.
Unless allowed by the local government, a transportation facility’s primary place of business shall not be sited, at the time of application for certification or for local zoning approval, whichever is earlier, within one thousand feet (1,000') of any then-existing elementary or secondary school, daycare, or church.

In the case of a freestanding facility, the distance between the facility and the school, daycare, or church shall be measured from the property line of the facility to the closest point of the property line of the school, daycare, or church.
In the case of a facility that is part of a larger structure, such as an office building or strip mall, the distance between the facility and the school, daycare, or church shall be measured from the property line of the school, daycare, or church to the facility’s entrance or exit closest in proximity to the school, daycare, or church.
Measurements shall be made along the shortest path between the demarcation points that can be traveled by foot.

A transportation facility’s primary place of business shall meet the security requirements of 19 CSR 30-95.040(4)(H). In addition to those requirements, transportation facilities shall also comply with the following:

All vehicles used to transport medical marijuana shall not be marked in any way that indicates medical marijuana is being transported by that vehicle and shall be equipped with at least—

A secure lockbox or locking cargo area made of smooth, hard surfaces that are easily cleaned for storing medical marijuana during transit;

A secure lockbox for storing payments and video monitoring recording equipment during transit;
Video monitoring of the driver and passenger compartment in the vehicle and of any space where medical marijuana is stored during transit; and
GPS tracking;

Facility agents transporting medical marijuana shall—

Prior to transporting medical marijuana, print an inventory manifest for the trip generated from the statewide track and trace system and create a trip plan, which shall be provided to the facility from which the medical marijuana is transported, and which shall include:

The name of the facility agent(s) transporting the medical marijuana;
The date and start time of transportation;
The anticipated delivery time; and
The anticipated route of transportation;

During transport—

Have facility agent identification card(s) accessible at all times;
Keep a copy of the applicable inventory manifest and trip plan in the transportation vehicle, which shall be placed under the driver’s seat or in a compartment beside the driver’s seat for the duration of the trip;
Have a means of communication accessible at all times;
Immediately report to law enforcement any vehicle accidents in which the transportation vehicle is involved; and
Immediately report any loss or theft of medical marijuana to a person designated by the transportation facility for this purpose; and

After transport, revise the trip plan to reflect the actual route taken and the end time of transportation and deliver the revised trip plan to a person designated by the transportation facility for this purpose;
Any incident of theft or attempted theft of medical marijuana shall be reported to the department within twenty-four (24) hours of the incident; and
All trip plans and revised trip plans shall be maintained by the transportation facility for at least five years.

Missouri Medical Marijuana Seed-to-Sale Tracking Requirements

All cultivation, manufacturing, dispensary, and testing license holders are required to utilize a state-approved seed-to-sale tracking system.

Seed-to-Sale Tracking System Requirements

All seed-to-sale tracking systems used by cultivation, manufacturing, dispensary, testing, and transportation facilities shall be capable of—

Interfacing with the statewide track and trace system such that a licensed or certificated facility may enter and access information in the statewide track and trace system as required for inventory control and tracking by 19 CSR 30-95.040(4)(G) and for purchase limitations by 19 CSR 30-95.080(2)(D);
Providing the department with access to all information stored in the system’s database;
Maintaining the confidentiality of all patient data and records accessed or stored by the system such that all persons or entities other than the department may only access the information in the system that they are authorized by law to access; and
Producing analytical reports to the department regarding—

Total quantity of daily, monthly, and yearly sales at the facility per product type;
Average prices of daily, monthly, and yearly sales at the facility per product type; and
Total inventory or sales record adjustments at the facility.

Seed-to-Sale Tracking System Rules

METRC was awarded the state’s seed to sale tracking system contract through the Missouri Office of Administration’s competitive bid process. All seed-to-sale tracking systems will need to be compatible with METRC reporting requirements.

Before beginning operations, all certified seed-to-sale tracking system entities shall sign the department’s Medical Marijuana Application Programming Interface User Agreement.

No seed-to-sale tracking system entity may sell seed-to-sale tracking services or services related to compliance with seed-to-sale tracking regulations to a licensed or certified facility if it is owned by or affiliated with an entity that currently holds a contract with the state of Missouri for any product or service related to the department’s medical marijuana program.

Failure to comply with this rule and failure to abide by the department’s Medical Marijuana Application Programming Interface User Agreement may result in revocation of certification.

Missouri Cannabis License Application Worksheets

Please note that the application period for cultivator, manufacturer, dispensary, and testing licenses has closed.

All Facility Types – (worksheets 1-17)

All facility types, with the exception of seed to sale and transportation certifications, will have to complete worksheets 1-17 below. Additional worksheets are required for testing, cultivation, dispensary, and manufacturing facilities. See Below.

Testing Facility – (worksheets 18-38)

If submitting an application for testing, worksheets 18-38 must also be completed and imported into the online registry.

Additional Required Worksheets

If applying for cultivation facility, one must also complete worksheet 39.
If applying for dispensary facility, one must also complete worksheet 40.
If applying for manufacturing facility, one must also complete worksheet 41.

Evaluation Scoring Criteria

All license applications for cultivation, dispensary, manufacturing, testing, or transportation will be evaluated for whether they meet these minimum standards:

The minimum standards for licenses and certifications:

Authorization to operate as a business in Missouri;
That the entity is majority owned by natural persons who have been residents of Missouri for at least one year;
That the entity is not under substantially common control as another entity or a combination of other entities in violation of 19 CSR 20-95.040(3)(C)-(D);
That the entity is not within 1,000 feet of an existing elementary or secondary school, daycare, or church, or, if a local government allows for closer proximity to schools, daycares, and churches, that the entity complies with the local government’s requirements;
Eligibility to operate in a local jurisdiction; and
That the entity will not be owned, in whole or in part, or have as an officer, director, board member, or manager, any individual with a disqualifying felony offense.

The additional evaluation criteria, which will be numerically scored:

The character, veracity, background, qualifications, and relevant experience of principal officers or managers;
The business plan proposed by the applicant, which in the case of cultivation facilities and dispensaries shall include the ability to maintain an adequate supply of medical marijuana, plans to ensure safety and security of qualifying patients and the community, procedures to be used to prevent diversion, and any plan for making medical marijuana available to low-income qualifying patients;
Site security;
Experience in a legal cannabis market;
In the case of testing facilities, the experience of the facility’s personnel with the health care industry and with testing marijuana, food, or drugs for toxins and/or potency;
The potential for the facility to have a positive economic impact in the site community;
In the case of cultivation facilities, capacity or experience with agriculture, horticulture, and health care;
In the case of dispensary facilities, capacity or experience with health care, the suitability of the proposed location, and its accessibility for patients;
In the case of infused products manufacturing facilities, capacity or experience with food and beverage manufacturing; and
Maintaining competitiveness in the medical marijuana marketplace.

After evaluation criteria questions have been initially scored, and in order to award points to applicants that seek to locate in economically distressed areas, thereby supporting a potential for positive economic impact in the site community, the rankings of such facilities will be further adjusted by awarding additional points as follows:

Any facility seeking a license to locate within a zip code area that has an employment rate of eighty-five percent to eighty-nine and nine tenths percent (85-89.9%) will receive a scoring increase of 30 percent of the average initial score of all applicants of the same facility type within the evaluation criteria topic regarding potential for positive economic impact in the site community; and
Any facility seeking a license to locate within a zip code area that has an employment rate of zero to eighty-four and nine tenths percent (0-84.9%) will receive a scoring increase of 40 percent of the average initial score of all applicants of the same facility type within the evaluation criteria topic regarding potential for positive economic impact in the site community.

When the numerical scoring system is used, the highest ranked facilities for each type of facility and, for dispensaries, in each congressional district, will receive licenses or certifications, except in cases where an entity under substantially common control, ownership, or management has applied for more than three cultivation, three manufacturing, or five dispensary licenses.

In those cases, the department will only issue licenses to the highest ranked facilities associated with that entity, up to the maximum number allowable in each category of license.

When the numerical scoring system is not used, all facilities that meet the minimum standards for licenses or certifications will be issued licenses or certifications, except in cases where an entity under substantially common control, ownership, or management has applied for more than five dispensary licenses and some of those dispensaries are located in congressional districts that were numerically scored. In those cases, the department will first issue licenses to the dispensaries associated with that entity in congressional districts that were not numerically scored. Any remaining dispensaries associated with that entity will be issued licenses according to that dispensary’s rank and score.

Facility License Application Questions and Scoring Criteria is the guidance document containing the Evaluation Criteria Questions and Points table, the Evaluation Criteria Scoring table, and the Evaluation Criteria Topics and Values table, which are referenced in 19 CSR 30-95.025.

Inspections, Violations, Penalties

Inspections

The department will inspect at least annually, with or without notice, to ensure compliance.

Submission of an application for a facility license or certification constitutes consent to inspection by the department. A department inspector conducting an inspection need not give prior notice of the inspection and, during the inspection, must be given access to all areas and property of the facility, including vehicles, wherever located, without delay.

The department may also, at any time it determines an inspection is needed, conduct an inspection, including an inspection of any part of the premises, qualifications of personnel, methods of operation, records, and policies and procedures of a licensed or certified facility.

Once a licensed or certified facility believes it will, within a month, be ready to begin operations and meet all state and local requirements for its facility, it shall request that the department conduct a commencement inspection to confirm the facility is in compliance with all requirements of this chapter.

Compliance Violations

If the department determines, during an inspection or otherwise, that a facility is not in compliance with the department’s regulations, the department will issue an Initial Notice of Violation to the facility that explains how the facility has violated the department’s regulations and what remedial actions the department expects the facility to take to correct the violation(s).

Once a facility has been notified of violation(s), the facility shall correct the violations within 15 days, and the department will conduct a follow-up inspection within 15 to 30 days to confirm the facility has corrected the violation(s). The facility shall notify the department if it believes it needs additional time to correct the violation(s), which the department may grant for good cause.

If the department’s follow-up inspection reveals the violation(s) have not been corrected, the department will issue a Final Notice of Violation to the facility explaining how the facility continues to violate the department’s regulations, what remedial actions the department expects the facility to take, and notifying the facility that its license or certifications will be suspended if the specified remedial action is not taken and the violation(s) corrected within 30 days.

If the violation(s) have not been corrected 30 days after a Final Notice of Violation and no extension of this deadline has been granted by the department, the facility’s license or certification will be suspended, the facility will be required to cease operations, and the facility must sign a corrective action plan designed to bring the facility into compliance.

Upon receipt of complaint against a facility, the department will determine whether an inspection is warranted to investigate the allegations in the complaint, and, if so, the department will, at the time of inspection, provide the facility with a copy of the complaint and an opportunity to respond to the complaint. Employees of a facility who report potential violations by a facility to the department may not be subjected to retaliation of any kind, including termination, because of their report.

If, at any time, the department determines a facility presents an immediate and serious threat to the health and safety of the public or of the facility’s employees, the department may order the facility to immediately suspend all or a part of its operations until the threat has been eliminated.

License Suspension, Denial and Revocation

Licenses and certification for facilities may be suspended, denied, or revoked.

If a facility provides false or misleading information in an application, its application may be denied or, if the information is later discovered to have been false or misleading, its license or certification may be revoked. Plans, assurances, and projections offered in answers to 19 CSR 30-95.025(4) evaluation criteria questions may be considered false or misleading if, upon application for license renewal, the department determines the facility has not made a reasonable effort to implement or follow-through on those plans, assurances, or projections.
If a facility violates any provision in this chapter or fails to comply with a corrective action plan, its license or certification may be suspended or revoked.
If an applicant fails to provide a complete application within seven days of being notified that an application is incomplete, the license or certification for which the applicant is applying will be denied.
If a facility is granted a license or certification but has not passed a commencement inspection within one year of the department issuing the license or certification, the license or certification may be revoked.
If a facility fails to comply with a department order to immediately suspend all or a part of its operations, the license or certification shall be revoked.
If an application does not meet the minimum standards for licenses and certifications pursuant to 19 CSR 30-95.025(4), the license or certification for which the applicant is applying will be denied.
If a facility uses combustible gases or other dangerous materials to extract resins from marijuana without a manufacturing facility license, the facility’s license may be suspended for up to one year.
If a facility packages medical marijuana in a false or misleading manner, or in any manner designed to cause confusion between a marijuana product and any product not containing marijuana, the facility’s license may be suspended or revoked.
If a facility or a facility employee fails to comply with seed-to-sale tracking requirements or intentionally misuses or falsifies seed-to-sale tracking data, the facility’s license may be revoked.

Penalties and Fines

The department will impose penalties as follows:

For possessing marijuana in amounts between the possessor’s legal limit and twice the legal limit, in addition to revocation of identification card(s) pursuant to 19 CSR 30-95.030(3)(B)1.D., the possessor will incur a penalty of two hundred dollars ($200);
For failure to package medical marijuana consistent with 19 CSR 30-95.040(4)(K), a facility will incur a penalty of five thousand dollars ($5,000) for each category of improperly packaged product, and the improperly packaged medical marijuana will be recalled for repackaging or disposal, at the department’s discretion; and
Any person or facility that extracts resins from marijuana using combustible gases or other dangerous materials without a manufacturing facility license, shall incur a penalty. In addition to suspension of license pursuant to 19 CSR 30- 95.040(1)(E)7., facilities that extract resins in this manner will incur a penalty of ten thousand dollars ($10,000).

Appeals

The following department decisions shall be appealable to the administrative hearing commission:

Denial, revocation, or suspension of licenses or certifications; and
Denial or revocation of patient, primary caregiver, patient cultivation, or facility agent identification cards.

Any person or entity entitled to appeal to the administrative hearing commission under this rule must file a petition with the administrative hearing commission within thirty days after the date the department decision is sent to the person or entity.

Additional Resources

Hemp (Department of Agriculture)

Helpful Tutorials

Contact Information

Section for Medical Marijuana Regulation
PO Box 570
Jefferson City, MO 65102-0570
Toll-Free Access Line: 866-219-0165 (8:30 am – 3:30 pm CST Monday-Friday)
Email for general inquiries:
medicalmarijuanainfo@health.mo.gov
E-mail for medical marijuana facility:
mmfacilities@health.mo.gov

Missouri Cannabis Regulations: License Applications, Forms, Links, and Other Resources