The Kentucky Office of Medical Cannabis (OMC) recently issued two technical advisories addressing hard edible stamping requirements and the remediation of harvest and production batches that fail required testing. Technical Advisory 2026-013, issued August 18, 2026, focuses on hard edible medical cannabis products, while Technical Advisory 2026-014, issued August 27, 2026, provides operational guidance for cultivators and processors undertaking remediation. Together, the advisories provide practical direction for licensees reviewing their operations and standard operating procedures (SOPs).
Stamping of Hard Edible Medical Cannabis Products
Technical Advisory 2026-013 explains OMC’s interpretation of the hard edible stamping requirements under KRS 218B.095(2)(b)2 and 915 KAR 1:040, Section 8(3).
Kentucky law limits medical cannabis products intended for oral consumption as edibles to ten (10) milligrams of delta-9 THC per serving. OMC regulations also require each hard edible product to be stamped with the standardized symbol indicating that the product contains medical cannabis, as provided in Appendix A to 915 KAR 1:100.
The advisory confirms that neither Kentucky law nor OMC regulations prohibit hard edible medical cannabis products or products containing multiple servings. A multi-serving hard edible must, however, be scored so that a cardholder can easily separate a single serving from the whole. For example, a 50-milligram gummy may be divided into five clearly separable 10-milligram servings.
The standardized symbol does not need to appear on each individual serving. Instead, the licensee must stamp the symbol clearly and visibly across the surface of the multi-serving hard edible product.
Remediation of Medical Cannabis
Technical Advisory 2026-014 outlines the remediation process for medical cannabis batches that fail required testing under 915 KAR 1:110, Section 5, including which test failures may be remediated and which require destruction of the batch.
When Is Remediation Allowed?
Before non-finished medical cannabis is transferred between licensees, or finished products are transferred to licensed dispensaries, samples from each harvest batch (raw plant material) or production batch (non-final or final medical cannabis products) must undergo the testing required by 915 KAR 1:110. A failed batch may be remediated or sterilized only when permitted under Section 5.
Remediation is permitted for certain failures involving THC content, residual solvents and processing chemicals, microbial impurities, and water activity, subject to the limitations applicable to each category. By contrast, batches that fail testing for residual pesticides, heavy metals, mycotoxins, yeast and mold, or vitamin E acetate must be destroyed as medical cannabis waste.
Where remediation is allowed, a batch may be remediated no more than two (2) times, and the method used may not introduce any toxic or deleterious substance. Medical cannabis from a failed batch also may not be combined with another harvest or production batch. Any resulting mixed product is considered adulterated and may not be sold, transferred, or delivered.
Special Transfer Process for Microbial Impurity Remediation
A harvest batch that fails microbial impurity testing may be transferred to a licensed processor for further processing using a method that effectively sterilizes the batch without introducing harmful substances. Cultivators must record the transfer using the new “Product Remediation” transfer type in Metrc, as described in Metrc Kentucky Bulletin No. 17.
Reporting and Recordkeeping Requirements
Before beginning remediation, a licensee must have detailed written SOPs for each remediation process it uses. Under the advisory, the licensee must provide those SOPs to its assigned OMC investigator before undertaking remediation and must report the remediation activity in Metrc.
After remediation, the batch must be resampled and retested in accordance with 915 KAR 1:110, Sections 2 and 3. Before samples are collected, the licensee that performed the remediation must inform the safety compliance facility that the batch previously failed testing and disclose the remediation or sterilization methods and any solvents used. Licensees must also document all remediation, sterilization, resampling, retesting, and disposal activities involving failed batches.
Key Takeaways for Licensees
Processors producing hard edibles should confirm that multi-serving products are properly scored and stamped. Cultivators and processors considering remediation should first confirm that the failed test category is eligible, ensure the applicable SOP has been provided to the assigned OMC investigator, use the correct Metrc workflow, and maintain complete records through retesting or disposal.
If you have questions about how these advisories affect your operations, aligning your SOPs with applicable regulations, or preparing for inspections or audits, please reach out to a member of the Dentons cannabis group for assistance.
