Oregon Cannabis: State Of The State (2025)
Our friends at Canna Law Blog take a look at the Oregon market
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.
Sales and market data
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 dismal 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; it again shows $15.00/gram for November. The “usable marijuana” category also dropped 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 cannabis licenses and licensing
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.
New Oregon cannabis rules
Marijuana
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.
Hemp
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. It wasn’t a great look, but it was no surprise.
Oregon cannabis litigation
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:
- Friend of the firm Andrew DeWeese filed a notable dormant commerce clause challenge to the federal prohibition of interstate marijuana sales. We are cheering him on.
- Ballot Measure 119 was defeated in Oregon District Court. That measure required most Oregon cannabis businesses to enter into labor peace agreements with approved unions, in order to renew or obtain licensure. The miserable case is now on appeal with the U.S. Court of Appeals for the 9th Circuit.
- The Oregon Court of Appeals ruled against retailer applicants that didn’t want to pay their taxes, as a condition precedent to license renewal. No appeal was filed.
- Cannabis receiverships continued apace, with the largest being the Tumalo Industries matter. The market remained soft, with the buyers once again Chalice insiders.
Federal developments
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.
Odds and ends
- The hemp industry continued to limp along. We finally saw an increase in planted acreage, despite a dwindling number of farmers. Licensed “vendors” continued to pile into the ODA program, following the 2024 registration requirement.
- We continue to struggle to fix and to complete cannabis industry transactions structured by brokers. At least one prominent broker in the Oregon cannabis space has no license whatsoever, and a few others continue to make messes. There are also competent brokers, to be sure—our advice is to never use legal agreements offered by brokers regardless.
- OLCC appeared to be less punitive and to pivot back toward teaching compliance, particularly for smaller operators (including the labs). I’d like to think we had something to do with that approach, and I hope it sticks—but who knows in either case.
- The Cannabis Industry Alliance of Oregon (CIAO) played a central role in 2025 legislative negotiations. CIAO successfully lobbied for producer transfer rights, trade sample expansions, and more realistic enforcement timelines for CBN compliance rules mentioned above.
- Initiative Petition 39, which aimed to legalize cannabis cafes, was submitted in February but withdrawn last month, in the face of logistical issues.
- Emerge Law Group, the Measure 91 law firm and first Oregon cannabis law boutique, announced it would wind down after a stellar 10-year run. Its remaining attorneys are joining Denver-based Vicente LLP.
Source: Canna Law Blog
