Regulation of THC Products; Domeier CITY OF HOPKINS
Memorandum
To: Honorable Mayor and Council Members
Mike Mornson, City Manager
From: Amy Domeier, City Clerk
Date: November 9, 2022
Subject: Regulation of THC Products
_____________________________________________________________________
PURPOSE
The City Council directed staff at the August 8 work session to develop an ordinance
and licensing structure for certain edible and beverage infused with
tetrahydrocannabinol (THC) to be sold.
INFORMATION
The draft ordinance includes regulations for the following: testing and labeling
requirements, prohibited sales, signage, age restrictions, hours of sale, compliance
check and violations.
Staff has not proposed any regulations associated with locations in the ordinance. Any
location regulations would be implemented through the Zoning Code. Additionally, staff
had concerns with a 500 or 1,000 square foot limitation causing issues with businesses
on Mainstreet.
Adoption of a licensing ordinance will require additional staff time to develop a license
application, process applications and background checks, and conduct compliance
checks. Because the product s are not state regulated Staff anticipates having more
involvement than we do with tobacco products and sales. The license term would be
July 1 to June 30. Staff proposes adopting a licensing fee of $1,000. Attached is license
fee data from other cities.
FUTURE ACTION
If the zoning ordinance would need to be amended, the Planning & Zoning
Commission would need to hold a public hearing before City Council consideration.
We would look to implement the code and license process in January, 2023.
Administration
LICENSE FEE DATA
Bloomington $175*
Eden Prairie $300*
Golden Valley $450
Minnetonka $500
Princeton $500
St. Cloud $500
Edina $700
Hopkins $1,000
Spring Lake Park $1,000
Oakdale $1,200
Willmar $2,000
Stillwater $4,000
Woodbury $10,200
*Temporary Fees currently in the process of reviewing.
ARTICLE XVII. – CANNABINOID PRODUCTS
Sec. 10-641. – Definitions
The following words, terms and phrases, when used in this article, shall have the
meanings ascribed to them in this section, except where the context clearly indicates a
different meaning:
Cannabinoid product means any product containing nonintoxicating cannabinoids
extracted from hemp, including an edible cannabinoid product that is sold for human or
animal consumption.
Certified hemp means the definition for the same provided in Minn. Stat. Section
151.72, Subd. 1(b), as may be amended.
Compliance checks means the system the City uses to investigate and ensure that
those authorized to sell cannabinoid products are following and complying with the
requirements of state laws and this ordinance. Compliance checks involve the use of
persons under the age of 21 who purchase or attempt to purchase cannabinoid products.
Compliance checks may also be conducted by the City or other units of government for
educational, research, and training purposes or for investigating or enforcing federal,
state, or local laws and regulations relating to cannabinoid products.
Delivery sale means the same of any cannabinoid products to any person for
personal consumption and not for resale when the sale is conducted by any means other
than an in-person, over-the-counter sales transaction in a licensed retail establishment.
Delivery sale includes, but is not limited to, the sale of any cannabinoid products when
the sale is conducted by telephone, other voice transmission, mail, the internet, or app-
based service. Delivery sale includes delivery by licensees or third parties by any means,
including curbside pick-up.
Edible cannabinoid product means any product that is intended to be eaten or
consumed as a beverage by humans, contains a cannabinoid in connection with food
ingredients, and is not a drug.
Hemp or Industrial Hemp means the definition for the same provided in Minn. Stat.
Section 18K.02, Subd. 3, as may be amended.
Label means the definition for the same provided in Minn. Stat. Section 151.01,
Subd. 18, as may be amended.
Labeling means the definition for the same provided in Minn. Stat. Section 151.72,
Subd. 1(g) as may be amended.
Moveable place of business means any form of business that is operated out of a
kiosk, truck, van, automobile or other type of vehicle or transportable shelter and that is
not a fixed address or other permanent type of structure licensed for over-the-counter
sales transactions.
Non-intoxicating cannabinoid means substances extracted from certified hemp
plants that do not produce intoxicating effects when consumed by any route of
administration.
Operator means the person in legal possession and control of a location by reason
of ownership, lease, contract or agreement, for the sale of cannabinoid products at retail.
Retail establishment means any fixed place of business where cannabinoid
products are available for sale to the general public. Retail establishment for purposes
of this ordinance does not include exclusive liquor stores or residences.
Sale means any transfer of goods for money, trade, barter or other consideration.
Self-service-vending means the display for sale of cannabinoid products that are
accessible to the public without the need of assistance of an employee.
Vending machine means any mechanical, electrical or electronic, or other type of
device that dispenses cannabinoid products upon the insertion of money, tokens, or other
form of payment into or onto the device by the person seeking to purchase cannabinoid
products.
Sec. 10-642. License.
(a) It will be unlawful for any person to sell at retail any cannabinoid products within
the City unless the person holds a retail cannabinoid products license, in full
force and effect.
(b) All licenses issued under this article shall expire on June 30 of each calendar
year.
Sec. 10-643. Procurement of License.
Subd. 1. Any person desiring a retail cannabinoid products license will make and file with
the City Clerk an application, in writing, executed in duplicate. Such application will give
the name and residence address of the applicant, if an individual, will identify the location
at which it is proposed to sell the cannabinoid products at retail, and will provide such
other information as the City Council may require from time to time. The application will
be accompanied by the required fee.
Subd. 2. The City Clerk will immediately transmit a copy of the application to the Chief of
Police who will investigate all facts and information which he/she can reasonably find,
bearing upon the question of the applicant’s fitness to receive the license and to perform
the duties imposed by this ordinance. Upon completing the investigation, the Chief of
Police will report, in writing, her/her findings to the Mayor or designee, together with
her/his recommendation as to the issuance of a license to the applicant. The Mayor or
designee will submit to the City Council the report of the Chief of Police, together with the
recommendation as to the issuance of the license to the applicant.
Subd. 3. The City Council will consider the facts and recommendation of the Chief of
Police and of the Mayor, together with any material facts which it may have or obtain, and
then, by motion, will approve or deny the application to the City Clerk together with a copy
of the motion. If the City Council has approved the application, it is the duty of the City
Clerk to execute and deliver a license to the applicant on a form approved by the City
Attorney.
Sec. 10-644. Basis for Denial of License.
Subd. 1. Grounds for denying the issuance or renewal of a license include, but are limited
to, the following:
(1) The applicant is under 21 years of age.
(2) The applicant has been convicted within the past five years of any violation
of federal, state, or local law, ordinance provision, or other regulation
relating to cannabinoid products.
(3) The applicant has had a license to sell cannabinoid products suspended or
revoked within the preceding 12 months of the date of application.
(4) The applicant fails to provide any of the information required on the licensing
application, or provides false or misleading information.
(5) The applicant is prohibited by federal, state, or other local law, ordinance,
or other regulation from holding a license.
(6) The business for which the license is requested is a moveable place of
business. Only fixed-location retail establishments that are not excluded
under the definition for retail establishments in this ordinance are eligible to
be licensed.
Subd. 2. Location Ineligible. No license will be approved unless the premises proposed
to be licensed complies with all applicable zoning requirements.
Subd. 3. Issued Mistakenly. If a license is mistakenly issued or renewed to a person, the
City will revoke the license upon the discovery that the person was ineligible for the
license under this ordinance. The City will provide the license holder with notice of the
revocation, along with information on the right to appeal.
Sec. 10-645. Sales of Cannabinoids Derived from Hemp.
In accordance with Minn. Stat. Section 151.72, Subd.3, as may be amended:
Subd. 1. A product containing nonintoxicating cannabinoids, including an edible
cannabinoid product, may be sold for human or animal consumption only if all of the
requirements of this section are met, provided that a product sold for human or animal
consumption does not contain more than 0.3 percent of any tetrahydrocannabinol and an
edible cannabinoid product does not contain more than five milligrams of any
tetrahydrocannabinol in a single serving, or more than a total of 50 milligrams of any
tetrahydrocannabinol per package.
Subd. 2. No other substance extracted or otherwise derived from hemp may be sold for
human consumption if the substance is intended:
(1) For external or internal use in the diagnosis, cure, mitigation, treatment, or
prevention of disease in humans or animals; or
(2) To affect the structure or function of the bodies of humans or other animals.
Subd. 3. No product containing any cannabinoid or tetrahydrocannabinol extracted or
otherwise derived from hemp may be sold to any individual who is under the age of 21.
Subd. 4. Products that meet the requirements of this section are not controlled
substances under Minnesota Stat. Section 152.02.
Sec. 10-646. Testing Requirements.
All testing must comply with the requirements set forth in Minn. Stat. Section 151.72,
Subd. 4, as may be amended.
Sec. 10-647. Labeling Requirements.
All labeling must comply with the requirements set forth in Minn. Stat. Section 151.72,
Subd. 5, as may be amended.
Sec. 10-648. Additional Requirements for Edible Cannabinoid Products.
In accordance with Minn. Stat. Section 151.72, Subd. 5a, as may be amended:
Subd. 1. An edible cannabinoid product must not:
(1) Bear the likeness or contain cartoon-like characteristics of a real or
fictional person, animal or fruit that appeals to children;
(2) Be modeled after a brand of products primarily consumed by or
marketed to children;
(3) Be made by applying an extracted or concentrated hemp-derived
cannabinoid to a commercially available candy or snack food item;
(4) Contain an ingredient, other than hemp-derived cannabinoid, that is not
approved by the United States Food and Drug Administration for use in
food;
(5) Be packaged in a way to resemble the trademarked, characteristic, or
product-specialized packaging of any commercially available food
product; or
(6) Be packaged in a container that includes a statement, artwork, or design
that could reasonable mislead any person to believe that the package
contains anything other than an edible cannabinoid product.
Subd. 2. An edible cannabinoid product must be prepackaged in packaging or a container
that is child-resistant, tamper-evident, and opaque or placed in packaging or a container
that is child-resistant, tamper-evident, and opaque at the final point of sale to a customer.
The requirement that packaging be child-resistant does not apply to an edible
cannabinoid product that is intended to be consumed as a beverage and which contains
no more than a trace amount of any tetrahydrocannabinol.
Subd. 3. If an edible cannabinoid product is intended for more than a single use or
contains multiple servings, each serving must be indicated by scoring, wrapping, or other
indicators designating the individual serving size.
Subd. 4. A label containing at least the following information must be affixed to the
packaging or container of all edible cannabinoid products sold to consumers:
(1) The serving size;
(2) The cannabinoid profile per serving and in total;
(3) A list of ingredients, including identification of any major food allergens
declared by name; and
(4) The following statement: “Keep this product out of reach of children.”
Subd. 5. An edible cannabinoid product must not contain more than five milligrams of
any tetrahydrocannabinol in a single serving, or more than a total of 50 milligrams of any
tetrahydrocannabinol per package.
Sec. 10-649. Prohibited Sales.
Subd. 1. Samples Prohibited. Sampling of cannabinoid products within any retail
establishment licensed under this ordinance is prohibited. No person shall distribute
samples of any cannabinoid products free of charge or at a nominal cost. The distribution
of cannabinoid products as a free donation is prohibited.
Subd. 2. Coupon and Price Promotion. No person shall accept or redeem any coupon,
price promotions, or other instrument or mechanism, whether in paper, digital, electronic,
mobile, or any other form, that provides any cannabinoid products to a consumer at no
cost or at a price that is less than the non-discounted, standard price listed by a retailer
on the item or on any related shelving, posting, advertising, or display at the location
where the item is sold or offered for sale, including all applicable taxes.
Subd. 3. Self-service Displays. All cannabinoid products must be stored behind the sales
counter, in a locked case, in a storage unit, or in another area not freely accessible to the
general public. No person shall allow the sale of cannabinoid products in open displays
that are accessible to the public without the intervention of a store employee. This section
does not apply to a retail establishment, as defined in this ordinance that is continuously
staffed by an employee from which persons under 21 years of age are prohibited from
entering the store.
Subd. 4. Prohibition Against Retail Sales of Cannabinoid Products by Vending Machines.
No person will sell or dispense cannabinoid products through use of a vending machine.
Subd. 5. Delivery Sales. All sales of cannabinoid products must be conducted in person,
in a licensed retail establishment under this ordinance, in over-the-counter sales
transactions.
Sec. 10-650. Adulterated or Misbranded Products.
A cannabinoid product shall be considered adulterated or misbranded under the
provisions set forth in Minn. Stat. Section 151.72, Subd. 6, as may be amended.
Sec. 10-651. Signage.
At each location where cannabinoid products are sold, the licensee shall display a sign in
plain view to provide public notice that selling any of these products to any person under
the age of 21 is illegal and subject to penalties. The notice shall be placed in a
conspicuous location in the licensed establishment and shall be readily visible to any
person who is purchasing or attempting to purchase these products. The sign shall
provide notice that all persons responsible for selling these products must verify, by
means of photographic identification containing the bearer’s date of birth, the age of any
person under 30 years of age.
Sec. 10-652. Age Verification.
At each location where edible cannabinoid products are sold, the licensee shall verify, by
means of government-issued photographic identification containing the bearer’s date of
birth, that the purchaser or person attempting to make the purchase is at least 21 years
of age. Verification is not required if the purchaser or person attempting to make the
purchase is 30 years of age or older. It shall not constitute a defense to a violation of this
Section that the person appeared to be 30 years of age or older.
Sec. 10-653. Responsibility.
All licensees are responsible for the actions of their employees regarding the sale, offer
to sell, and furnishing of cannabinoid products on the licensed premises. The sale, offer
to sell or furnishing of any cannabinoid product by an employee shall be considered an
act of the licensee.
Sec. 10-654. Hours of Sales.
No sales of cannabinoid products will be allowed at the licensed premises after 10:00
p.m. and before 8:00 a.m. daily.
Sec. 10-655. Compliance Checks and Inspections.
All licensed premises must be open to inspections by law enforcement or other authorized
city officials during regular business hours. From time to time, but at least once per year,
the City will conduct compliance checks. The City will conduct a compliance check that
involves the participation of a person at least 17 years of age, but under the age of 21 to
enter the licensed premises to attempt to purchase cannabinoid products. Prior written
consent from a parent or guardian is required for any person under the age of 18 to
participate in a compliance check. Persons used for the purpose of compliance checks
will be supervised by law enforcement or other designated personnel.
Sec. 10-656. Civil Penalty, Suspension or Revocation of Licenses.
Subd. 1. The City Council will follow the provisions of this section of the ordinance on `the
suspension, revocation or imposition of a civil penalty against any license granted under
this ordinance.
Subd. 2. Notice of Violation. The Chief of Police will provide, in writing, to the licensee
either personally or by mail, notice of any alleged violation of the provisions of this
ordinance or Minnesota States Chapter 151, committed in the operation of the licensee’s
business, and provide notice to the City Attorney’s Office. If the City Attorney’s Office
determines from the facts and circumstances reported, together with any other facts and
circumstances known to it, that the violation may warrant a civil penalty, suspension or
revocation of the license held by the licensee, it will notify the licensee, and set a time
and place for a hearing sufficiently in advance to provide ten days written notice of the
time, place and purpose of such hearing to the licensee.
Subd. 3. Hearing on Alleged Violations. The hearing will be held before an independent
hearing officer. At the time of the hearing, the licensee may appear and present any
evidence which is material to the investigation. The hearing officer will make findings of
fact as to whether a violation of the provisions of this ordinance or Minnesota Statutes
Chapter 151 have been committed in the operation of the licensee’s business and
whether the violation was willful in nature. The hearing officer will also make a
recommendation as to what penalty, if any, will be applied. The City Council will adopt
the hearing officer’s findings of fact that the licensee has violated any of the provisions of
this ordinance or State law, and may impose a civil fine, suspend or revoke the license in
accordance with the schedule in Section 430:90 of this ordinance.
Subd. 4. Mandatory Revocation. The Council will revoke the license of any licensee under
this ordinance if the licensee willfully violates any provision of state law regulating the sale
of cannabinoid products, or failing to comply with any other requirements of Minn. Stat.
Section 151.72, the City Council may impose a fine, suspend or revoke the license in
accordance with the following schedule:
First violation $500 fine
Second violation within 36 months $1,000 fine plus 1-day suspension
Third violation within 36 months $2,000 fine plus 5-day suspension
Fourth violation within 36 months Revocation
Subd. 5. Any civil fine assessed against a licensee pursuant to this section must be paid
in full within 30 days from receipt of written notification of the City Council’s imposition of
the civil fine. Failure to pay the fine within that time period will result in a ten-day license
suspension. Licensees whose licenses have been revoked may not be issued a new
license within six months from the effective date of such revocation.