The short version
- Effective November 1, 2026. The State Licensing Authority adopted the revised rules on September 10, 2026.
- Responsible vendor training did not change. Same two-hour minimum, same 70% passing score, same 90 days for new hires, same two-year cycle, same approved provider requirement.
- Labels list more cannabinoids. On edibles, topicals, transdermals and vaginal or rectal products, any cannabinoid that makes up 10% or more of total cannabinoids must be potency tested and stated on the label.
- Relabeling rules are spelled out. Changing an expiration or use-by date on packaged product was already barred. The revised rules now say it expressly for cultivators and manufacturers too.
- Only licensed people operate in your store. New rules spell out that subleases, white labeling and similar deals with unlicensed operators are not allowed.
- Most fees rise 2.4%, and unpaid annual license fees now carry a late fee.
What this rule package is
The MED's rules live in 1 CCR 212-3. This revision was noticed in July, heard on August 26 and adopted on September 10, 2026, with an Attorney General opinion on September 21 and publication in the Colorado Register on October 10. It is filed with the Secretary of State as tracking number 2026-00310. The MED's rules page says the revised rules "will become effective on November 1, 2026."
The Statement of Adoption names four themes: fees, preventing diversion and inversion, testing consistency, and a set of catch-all clean-ups. It also says it "is not a comprehensive summary of rule revisions," so we read the redline the MED filed with the Secretary of State, rule by rule, for the parts that touch a store.
Responsible vendor training: what stays the same
Of the responsible vendor rules (the 3-500 Series), only Rule 3-520, the core curriculum, is on the amended list, and its edits are a capitalized heading and a punctuation mark. Rules 3-505, 3-510 and 3-515 are untouched. The requirements below work the same after November 1.
| What stays the same | Rule |
|---|---|
| Who trains: owners with day-to-day control, managers over sales or training, and staff who handle marijuana | 3-505(B) |
| New owners, managers and sales or training staff finish within 90 days | 3-505(D)(2) |
| Staff retrain once every two years to keep the designation | 3-505(D)(1) |
| At least two hours of instruction | 3-515(C) |
| Pass with 70% or better | 3-515(F)(1) |
| Online is allowed when the provider verifies each learner's identity | 3-515(D)(1) |
| Core curriculum topics, including ID checks and health effects | 3-520 |
| A designation and the delivery curriculum before a store's first delivery | 3-615(C) |
| Designation records kept for the current year and three prior tax years | 3-905(B.5)(5) |
| A current designation is a mitigating factor in penalties | 8-235(C)(9)(f) |
If you have seen the mitigating factor cited as Rule 8-235(C)(2)(d), that number is out of date. That paragraph now reads "Repealed." The factor is 8-235(C)(9)(f), and this package adds a new factor after it for using a third party to collect testing samples.
Nothing in the package asks staff who already hold a designation to retrain early. Responsible vendor training is still optional for most stores, and still required for stores with a delivery permit and for hospitality businesses.
What changes on the sales floor
Labels: any cannabinoid at 10% or more
Rule 3-1015 now says that, for edibles and other oral products, topicals, transdermals and vaginal or rectal products, any cannabinoid making up 10% or more of a product's total cannabinoids "is subject to potency testing requirements of Rule 4-210 and must be stated in the potency statement." The new text does not appear in the sections for flower, concentrates or vapes. Some labels will name more cannabinoids than before. Budtenders should be ready to explain a minor cannabinoid when a customer asks what it is.
Expiration and use-by dates, spelled out
Rule 3-1015 already barred any licensee from changing an expiration or use-by date on edibles, inhaled products and vapes, and that has not changed. The revised cultivation and manufacturer rules now say it expressly: the Statement of Adoption says they "expressly prohibit relabeling of products already packaged and labeled for sale to consumers, including changing expiration and use by dates." The MED's summary bulletin adds that correcting or replacing a label that is damaged or unreadable before transfer is still allowed. A store must still tell the customer if an edible is past its use-by date.
Only licensed people operate in your store
New Rule 3-110(E) bars licensees from "subcontracting, subleasing, or subletting with an unlicensed individual or entity" for privileges only licensees have. The retail and medical store rules (6-110(Q) and 5-115(N)) apply that to any agreement that lets someone operate in part of your premises other than as a licensed employee, whatever it is called, including subleases, white labeling and independent contractor deals. Ordinary services such as alarm monitoring, security and maintenance are still fine. The Statement of Adoption says these rules "clarify existing restrictions."
Security paperwork
- Premises diagram (3-205). Keep a diagram of limited access areas that identifies point-of-sale areas, shipping and receiving, where test batches are collected, where waste is destroyed, and points of ingress and egress.
- Cameras (3-225). The camera rules now say "points of ingress and egress" instead of "entrances and exits." The existing requirement to record them from both indoor and outdoor vantage points stays.
Fees and employee licenses
Fees rise 2.4% for inflation, except Social Equity license fees, and unpaid annual license fees for business licenses and delivery permits now pick up a late fee. Check the MED fee schedule for exact amounts. Conditional employee license applications no longer have to be submitted in person.
Will your training course change?
It may get small updates. Rule 3-510(B), which did not change, requires approved providers to update their curriculum "within 30 days of any changes to the Marijuana Code, or these rules." The curriculum already covers packaging and labeling, inventory tracking, security and surveillance, and records, so those sections are the ones most likely to pick up the new labeling, relabeling and premises rules. Keeping a course current is the provider's job, and the MED's list of approved providers is the place to confirm a provider is in good standing.
What to do around November 1
- Show counter staff a label that lists a minor cannabinoid and walk through how to explain it.
- Tell receiving and inventory staff that expiration and use-by dates on packaged product stay as they are.
- Look over any agreement that lets someone other than your licensed staff operate in part of the store, such as a white label or sublease deal.
- Update your premises diagram and confirm your cameras record every point of ingress and egress from inside and outside.
- Check your responsible vendor file: completion dates, new hires inside 90 days, and providers on the MED's current list.
- Plan for fees 2.4% higher and pay annual license fees on time to avoid the new late fee.
