IDOA adopts rules for cannabis plant monitoring and fees
The Illinois Department of Agriculture (IDOA) announced today newly adopted rules for the Cannabis Regulation and Tax Act. As detailed in today’s Illinois Register and Flinn Report, the rulemaking extends DOA licensing and regulation, which originally applied only to cultivation centers, to craft growers, infusers, processors (facilities that extract chemicals or compounds from cannabis to produce cannabis concentrate), and community college cannabis vocational pilot programs; reduces or pauses various fees; and establishes a statewide cannabis plant monitoring system through which DOA will track all movements of cannabis or cannabis-derived products.
Plant Monitoring System
A new Subpart outlines the operation of the IDOA-designated cannabis plant monitoring system, within which all cannabis business establishments must create and maintain accounts.
- All cannabis and cannabis products in Department-licensed cannabis business establishments must be accounted for in the system at all times and kept in enclosed, locked facilities.
- Establishments must only use plant tags distributed by the Department or its designee and assigned in the monitoring system to that establishment.
- Tags cannot be transferred to another licensee or entity.
- Immature plants of a single strain or cultivar may be grouped together under a single plant batch tag; once plants are at least 16 inches tall, each plant will receive its own tag.
- Harvested plants will be assigned a unique harvest batch name and a package tag after the drying and curing process is complete.
- All cultivation and production activities, including receipt or rejection of transferred cannabis or cannabis product, planting, harvest, movement of cannabis or cannabis product, extraction, distillation, infusion, destruction or waste of product, and sale of product must be recorded in the monitoring system.
- When cannabis or cannabis product is ready to be transferred to another establishment, a manifest must be created in the monitoring system.
- If an establishment loses access to the system, it must record all activities by another means and enter them into the system once access is regained.
- Cannabis business establishments shall not accept or use any cannabis, hemp or cannabis- or hemp-derived input that is not from a licensed Illinois cannabis business establishment.
- Since 1st Notice, DOA has specified that effective 7/1/26, licensed cannabis business establishments cannot incorporate, manufacture or transport any product containing cannabis, hemp, industrial hemp or any cannabis plant material not cultivated by a licensed Illinois cannabis business establishment.
- Before accepting any input, a business licensed under this Part must request Department permission through the cannabis plant monitoring system and must receive the input during the Department-approved timeframe.
- Cultivation centers and craft growers also must have approval from the Department to obtain seeds, clones or new genetics from an entity other than a cannabis business establishment. (Since 1st Notice, DOA has agreed to approve or deny these requests within 5 calendar days.)
The rulemaking also reduces the minimum storage period for security camera footage from 180 to 90 days. Other changes since 1st Notice clarify various definitions and statutory text; specify in greater detail how batches shall be labeled; and specify the locations where cultivation centers, infusers, and transporters must use security cameras that capture continuous recorded images (motion-activated cameras can be used in other locations).
Fees
Application fees for approval of major modifications to a cannabis business establishment are reduced as follows: cultivation centers, $4,000 (previously, $5,000 due at application and $3,000 upon approval); craft growers, $2,000 (previously, $2,500 at application and $1,500 upon approval); infusers, $1,000 (previously, $1,250 at application and $750 upon approval). For less extensive alterations, application fees are reduced to $500 (previously $1,000) for cultivation centers, $250 (previously $500) for craft growers, and $125 (previously $250) for infusers.
A $1,000 fee for changing the principal officer of any licensed cannabis business or organization has been eliminated. The product, registration fee is reduced from $100 to $25. No annual renewal fee will be charged to craft growers and infusers for the two annual license renewal periods that begin after May 1, 2026; these fees will resume with the third annual renewal following that date. Changes since 1st Notice state that if a craft grower’s or infuser’s license is revoked or relinquished, the licensee will no longer owe any past due licensing or license renewal fees.
For questions or requests for copies, contact Sam McGee at IDOA, State Fairgrounds, P.O.
Box 19281, Springfield, IL 62794-9281, by phone at 217-558-3741, or by email at Samuel.McGee@illinois.gov.
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