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December 31, 2025

Built by a former cannabis regulator, Policy, Decoded helps operators read the policy terrain before it shifts beneath their feet.

Today’s edition closes out 2025 with the two tracks that will shape 2026: the Schedule III path through process and litigation, and a federal hemp rewrite that forces hard product and channel decisions.

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⚖️ Schedule III clock
🌾 Hemp definition fight
🗺️ State map pressure

Happy New Year. See you in 2026.

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What 2025 Taught Me, And What I’m Bringing Into 2026

❝

I have stared at this blank page longer than I want to admit. End-of-year notes can turn into performance, and nobody reading Policy, Decoded needs another piece of content that exists mainly to fill space. You have inboxes, deadlines, board calls, hearings, families, and a country that still cannot decide whether cannabis policy should move with urgency or be buried in process.

So here is the honest version.

I started THC Group because I missed doing work that has consequences. Consulting keeps me close to the real problems, the kind where the right answer depends on who is in the room, what they need, and what they are quietly afraid of. Policy, Decoded grew out of that same instinct. A daily briefing I would want in front of me if I were still running an agency, or trying to steer a business through a regulatory mess without losing my footing.

When we launched earlier this year, Policy, Decoded was basically my own network. Friends, former colleagues, clients, regulators, and the people who would tell me quickly whether this was worth reading. Through forwards and referrals and a lot of you telling someone else “you should read this,” it has grown to almost 5,000 subscribers. That still feels personal because it is personal. It is trust moving from one inbox to another.

The best part of 2025 has been watching people I care about build and create. I saw clients and friends expand into new markets, bring on new hires, ship products, and take real swings. I saw courage. I also saw some of those same people get dragged through challenges that had nothing to do with effort or intelligence. Money got tight and the rules kept moving, and more than a few teams had to pivot in real-time. If you lived that, you don’t need a pep talk from me of all people. You deserve respect for showing up anyway.

Policy-wise, we ended the year the way we lived it. Rescheduling caught another green light, and it still runs through paper, procedure, and what happens in court after the ink dries. Hemp is headed into another definition fight, and responsible, age-gated low-dose products have work to do to keep themselves distinct from the junk that keeps daring lawmakers to swing a(nother) sledgehammer. States keep improvising. Everyone keeps learning in public. Some are learning faster than others.

Here is what you can expect from me in 2026. I will keep this briefing grounded in what I am seeing through THC Group, not in what is trending. I will tell you what is real, what is still in motion, and what smells like bullshit. I will keep the nuance where the decisions actually live, and I will keep the content tight enough that you can read it fast and trust it.

And I do have one ask. If this briefing has been useful, keep doing what you have been doing. Forward it. Recommend it. Put it in front of the one person on your team who always asks, “What are you hearing?” That is how Policy, Decoded grew this year. One person vouching for it to another person. I don’t have a better growth engine than that, and I don’t know that I want one.

If you are a client, thank you for trusting me. If you are thinking about working with THC Group in 2026, reply and tell me what you’re dealing with. I will tell you if I can help, and I will be straight if I can’t. Odds are, if I can’t, I know somebody that can.

Sincerely, thank you for reading. Happy New Year to you, your team, and your people.

-Shawn

Fast-moving headlines, flagged for what matters.

President Trump’s December executive order put Schedule III back at the front of the federal agenda, and the finish line now runs through DOJ process, publication, and a fast litigation sprint. The same month brought a second jolt when Trump signed a spending bill that narrows the lane for many consumable hemp products, with the restriction date pushed one year out. The U.S. Supreme Court declined to take a major challenge to federal prohibition, while agreeing to hear a case testing the federal gun ban for marijuana users. States kept moving in opposite directions, with legalization momentum in some places and rollback politics sharpening in others. 2026 opens with two live tracks that touch tax posture, enforcement priorities, and which cannabinoid products can stay in lawful national commerce. (Marijuana Moment)

The Dallas Morning News editorial board argues that pushing marijuana to Schedule III can improve research and regulatory consistency while warning against treating rescheduling as a social green light. It leans on a JAMA review it describes as finding weak or inconclusive evidence for many commonly promoted medical claims, and it flags concerns tied to sleep, memory, and cannabis use disorder. The piece also frames Schedule III as a change that could alter tax posture and banking risk more than day-to-day enforcement overnight. Texas’ Compassionate Use Program gets held up as a caution model, paired with skepticism about broadening qualifying conditions like chronic pain. This framing is built for hearings and budget rooms, and it will be reused by opponents seeking tighter product rules across both marijuana and hemp. (The Dallas Morning News)

Sen. Amy Klobuchar says senators are working on a federal path that prevents looming hemp THC restrictions from wiping out state-built markets, with budget vehicles and the next farm bill as the fastest lanes. She pointed to Minnesota’s framework as a template, with 21-plus limits, licensing, labeling, and manufacturing controls that give enforcement a clean target. A Minnesota beverage maker told WDIO the November 2026 effective date already changes planning because the federal limits would eliminate about half its inventory and complicate common production processes. The pressure is national, but Minnesota’s stake is immediate because thousands of licensed retailers sell hemp-derived edibles and beverages and many distribute beyond state lines. The clock is short, and the only durable solution is statutory language that protects disciplined low-dose channels while cutting off synthetics and junk retail. (WDIO)

A government-funded study warns that per se and zero-tolerance THC driving laws in roughly 20 states can criminalize people who show no signs of impairment. Researchers found that frequent cannabis users can exceed common blood THC cutoffs days after last use, even after a 48-hour abstinence period, because THC and metabolites persist far longer than alcohol. The study, published in Clinical Chemistry and funded in part by NIH and California, concludes blood-limit approaches lack scientific credibility as a proxy for impairment. The authors point toward a combined model that prioritizes observed driving behavior in the field plus toxicology, instead of a single number. States that keep leaning on bright-line cutoffs should plan for more courtroom pressure, more legislative fixes, and more training demands for officers and prosecutors. (Marijuana Moment)

A New York Times investigation traced several Oklahoma cannabis farms to people connected to New York City Chinese diaspora hometown associations, including a case involving Wyan Wang, a cannabis worker killed during a robbery in Edmond, Oklahoma. The reporting describes obscured ownership, alleged labor abuses, and licensing violations in a state where cultivation scale expanded quickly and cash remains common. Oklahoma rules require cultivation operations to be at least 75% owned by Oklahoma residents and to fully disclose ownership, yet officials and court records cited in the story describe straw ownership and paperwork schemes as recurring tools. The Times reports it found no evidence that Chinese government officials operated or supported the farms, even as some lawmakers and law enforcement voices push a national security frame. The next regulatory move here is not rhetoric, it is verification: beneficial ownership review, financing transparency, and enforcement that targets concealment without turning ethnicity into a proxy for wrongdoing. (New York Times)

Smart & Safe Florida is back in Leon County court, alleging the state improperly directed the invalidation of about 71,000 petition signatures as the February 1, 2026 deadline approaches. The suit targets two buckets, signatures from voters marked inactive and petitions collected by out-of-state gatherers during the period when a federal injunction temporarily blocked enforcement of Florida’s residency ban. This comes on top of the earlier ruling that allowed the state to toss roughly 200,000 signatures tied to a petition form dispute, a decision the campaign chose not to appeal. The state’s public tally sits at 675,307 validated signatures against a requirement of 880,062, and the campaign argues supervisors have more signatures still in the pipeline. Every directive that knocks petitions out becomes outcome-determinative, because courts and supervisors do not move on the same calendar the election does. (CBS12 News)

Washington’s new cannabis advertising law takes effect January 1st, expanding exterior visibility for licensed retailers. The law raises the limit to four cannabis-related advertising signs outside the licensed premises, allowed on the building face with the main entrance or hanging in windows. It also creates a carveout for small signs under 512 square inches that avoid brand names, trade names, and cannabis imagery, and stick to limited information like open or closed. Supporters frame it as modernization that helps licensed stores compete, while public health critics warn it increases normalization and youth exposure along commercial corridors. The practical result will be more storefront marketing and more local politics, with cities under pressure to tighten sign ordinances where neighborhood pushback is organized. (Seattle Red)

A New Jersey appellate panel ruled that Nature’s Touch can proceed with its lawsuit against Hoboken and former Mayor Ravi Bhalla over the city’s refusal to advance its medical dispensary application. The company received a favorable recommendation from Hoboken’s Cannabis Review Board in January 2022, then says the mayor declined to sign the required support letter and gave no explanation at the time. Nature’s Touch argues it only learned a potential tort basis in May 2024 after allegations surfaced in separate litigation claiming the decision was tied to a quid pro quo, allegations Hoboken and Bhalla dispute. The court agreed the Tort Claims Act clock can run from when the plaintiff learns of the alleged malicious motive, and it narrowed the case on remand to tortious interference unless the trial court allows additional theories. Discovery will test how municipal discretion is documented, and it will raise the stakes for cities that keep consequential licensing decisions off paper. (Hudson County View)

Colorado is closing 2025 with legal marijuana sales near $1 billion and nearly $200 million in tax and fee revenue, and Gov. Jared Polis is using the milestone as proof the market still funds public priorities. State revenue officials expect the sales total to clear $1 billion by year’s end, with final 2025 reporting expected after the last monthly data publishes. Polis paired the numbers with familiar arguments about displacement of illicit activity and job support. The receipts also give state leaders clean political ammunition as federal Schedule III and national hemp fights reshape the category in 2026. In the next budget cycle, these figures will keep showing up as both shield and sword, depending on who is trying to tax, regulate, or expand the market. (Marijuana Moment)

THC beverages are scaling fast because nano-emulsions have made dosing and onset more predictable, pulling in mainstream beverage playbooks around taste, branding, and distribution. That momentum has produced a crowded shelf, with seltzers, teas, shots, and mixes competing on effects, flavor, and portability. Whitney Economics pegs legal THC beverage sales around $1.0 to $1.3 billion, with substantial headroom if the lane stays open. Hemp-derived drinks face a looming federal cap of 0.4 mg total THC per container with a one-year compliance runway, plus a synthetic cannabinoid ban that would erase most current formulations. The immediate business consequence is triage, with reformulation planning, tighter channel discipline, and sharper differentiation between age-gated low-dose models and the products that keep pulling lawmakers toward blunt crackdowns. (FoodBev)

California’s Department of Cannabis Control awarded nearly $30 million in cannabis tax funded research grants, the third round in a program that now totals about $80 million. A flagship UC San Francisco project will measure THC absorption, onset, and duration across commercially available infused beverage formulations under real-world conditions. Other awards target terpene-driven flavor effects, older-adult use patterns, crop yield estimation, environmental impacts, and models for tribal market participation. DCC says it received 149 proposals and plans to publish findings at no cost to the public. This work will become a policy record, and regulators will use it to justify beverage labeling, impairment guidance, and clearer boundaries around additives and marketing claims. (Marijuana Moment)

Kentucky’s first medical cannabis dispensary, The Post in Beaver Dam, temporarily closed after selling through its inventory within a week of opening. Patients lined up before dawn on day one, and the reporting captures the relief that comes with finally buying regulated product after years of improvisation. The dispensary says it plans to reopen in mid-January once new deliveries arrive from in-state cultivators, with more dispensaries expected to open in January as the supply chain ramps. Kentucky’s in-state cultivation requirement keeps the early market tight, and demand is colliding with harvest cycles and testing throughput. A card program becomes an access program only when cultivation, labs, and retail capacity scale at the same speed. (Spectrum News 1)

Retailers are treating New Year’s Eve as a demand spike for low-dose THC beverages, with mg Magazine reporting Gen Z and millennials increasingly swapping some alcohol occasions for cannabinoid drinks. The category’s pitch is social ritual without the next-day drag, and the most common entry lane sits around 2 to 5 mg per serving. Merchandising is the easy part, but education is the hard part, because onset timing and pacing are not intuitive for first-time buyers. Holiday promos also bring placement scrutiny, especially when products drift too close to mainstream beverage aisles without clear age gating. The sales opportunity is real, and the regulatory consequence follows quickly if visibility outruns controls. (mg Magazine)

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From the hearing room to the comment section — we’re watching it all.

🧴 Premium CBD is getting packaged as a luxury wellness ritual, with buyers treating third-party testing, provenance, and sensory experience as part of the product, not an add-on. The policy risk is that lifestyle marketing keeps outrunning the evidence base, and that gap invites blunt restrictions that can sweep responsible full-spectrum CBD alongside the worst products in the category. (Luxury Lifestyle Magazine)

🧱 2025 forced cannabis businesses to trade improvisation for process, with price compression and tight capital pushing cost control, SKU discipline, and repeatable quality back to the center of the business. The winners of the next cycle will look boring on purpose, and that is the point, because stability is turning into a competitive advantage while federal uncertainty keeps punishing fragile balance sheets. (mg Magazine)

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