MAY 2025 | 7 THE OKLAHOMA BAR JOURNAL Cannabis Law Navigating Compliance Challenges: Addressing Oklahoma’s Legislative Gaps in Cannabis Processing By Rachel O. Klubeck OKLAHOMA’S LACK OF LEGISLATIVE CLARITY and regulatory definitions surrounding cannabis processing has led to compliance challenges, inconsistent labeling and enforcement difficulties within the industry. INTRODUCTION Oklahoma’s cannabis industry has experienced unprecedented growth – and obstacles – since medical marijuana was legalized in 2018. With just over 900 active Oklahoma medical marijuana processing licenses,1 this evolving sector presents both opportunities and significant regulatory challenges. Unlike cultivators and dispensaries, processors operate in a uniquely complex space, necessitating clear guidelines on manufacturing, safety and compliance. However, Oklahoma’s regulatory framework fails to understand and define key industry terms, leading to inconsistent enforcement, compliance confusion and industry uncertainty. This article examines the gaps in Oklahoma’s cannabis processing laws, clarifies licensing classifications and proposes reforms to promote industry stability as well as consumer safety. DEFINING PROCESSING AND CLASSIFYING HAZARDOUS AND NONHAZARDOUS LICENSING The current licensing structure in Oklahoma allows for a broad definition of cannabis processors, leading to variations in compliance requirements. While some processors engage in the direct manufacturing of cannabis products – extracting, refining and infusing raw cannabis into oils, concentrates, edibles and topicals – other business models operate primarily as intermediaries. These processors act as distributors, facilitating and brokering the transfer of cannabis products from cultivators to dispensaries or other licensed businesses without engaging in the actual manufacturing process. Because their role is distinct from traditional processing, their compliance obligations differ, focusing more on inventory tracking, transportation and quality assurance rather than extraction and solvent safety protocols. Cannabis processing refers to the transformation of raw cannabis flower into a variety of products, including oils, concentrates, edibles and topicals.2 The Oklahoma Medical Marijuana Authority (OMMA) defines processing as the distillation, extraction, manufacturing, preparation or production of a medical marijuana product.3 However, this definition lacks specificity regarding the different methods and risk factors associated with various processing techniques. Under Oklahoma law, processing is categorized as either hazardous or nonhazardous, depending Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.
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