Since Sept. 14, Maryland has allowed THC sublingual pouches, capped at 10 mg a serving, with new lab reporting due Nov. 5

Since Sept. 14, 2026, Maryland's regulated cannabis market has allowed a new product type: THC sublingual pouches, small sachets meant to dissolve in the mouth. The Maryland Cannabis Administration (MCA) set the rules for them in a regulation package that caps each pouch product at 10 milligrams of THC per serving and 100 milligrams per package unless the agency expressly authorizes more. A follow-up change for testing labs is scheduled for Nov. 5, according to The Marijuana Herald.

This is an older story, dated plainly: the regulations took effect Sept. 14. It is back in the news because of the new lab reporting requirement, reported Oct. 25.

How the rule was adopted

The MCA proposed the package in the Maryland Register on June 26, 2026, and adopted it on Aug. 13, according to the agency's Notice of Final Action, published in the Sept. 4 issue of the Maryland Register (Volume 53, Issue 18). The notice lists an effective date of Sept. 14, 2026, and is signed by MCA Director Tabatha Robinson.

Under Maryland procedure, the state Attorney General certified that the changes made between the proposed and final versions do not differ substantively from the proposed text. The notice lists those changes as clarifications: tightening the definition of "sublingual pouch," clarifying what documentation shows a conditional licensee's active interest in a premises, using defined terms in the pouch ingredient rule and fixing a numbering typo.

Besides the pouch rules, the package amended MCA regulations on definitions, license issuance, grower operations, dispensary operations, product packaging and hearing procedures, according to the notice.

What counts as a sublingual pouch

The regulation defines a sublingual pouch as "a permeable sachet containing concentrated cannabis product that is intended to be dissolved in the mouth and absorbed buccally or sublingually." Buccal absorption is through the cheek; sublingual is under the tongue.

Under the new regulation, COMAR 14.17.13.13, a sublingual pouch may be sold only to:

• people 21 or older; or
• qualifying medical patients and registered caregivers.

A pouch may contain only a concentrated cannabis product plus fillers, sweeteners and other flavors or preservatives approved by the MCA. Unless the agency expressly authorizes otherwise, a pouch product may not contain more than 10 milligrams of THC per serving or 100 milligrams of THC per package.

Packaging and labeling

A separate new regulation, COMAR 14.17.18.08, covers how pouches are packaged. Maryland's general packaging and labeling rules apply, and each package must carry this warning: "Pouches are not intended to be heated, burned, or swallowed."

Each individual pouch must be marked with the state's universal cannabis symbol. If marking each pouch is impractical, each pouch must instead be individually wrapped, with the universal symbol on the wrapper.

The MCA's updated packaging and labeling guidance, dated Aug. 31, 2026, says all cannabis packaging in Maryland must be tamper-evident, child-resistant and opaque. Multi-serving products must be resealable, clearly show the size of a serving and stay within 10 milligrams per serving and 100 milligrams per package, the guidance says. Packages must also carry the state's standard warnings, including that contents may be lawfully consumed only by adults 21 or older or registered medical patients, that cannabis may impair driving, and that the package should be kept away from children and animals, along with the Maryland Poison Center number.

The guidance also lists sublingual pouches among products that need manual approval from the MCA before they can enter the market, along with edibles, liquids, tinctures and capsules. Licensees may submit digital renderings for that review, the guidance says.

The Nov. 5 lab reporting change

On Oct. 25, The Marijuana Herald reported that Maryland is adding new THC reporting requirements for several product types, including pouches. According to the outlet, an Oct. 22 industry bulletin from Metrc, the state's cannabis inventory tracking provider, issued in coordination with the MCA, requires licensed testing labs to report both delta-9 THC and total THC in milligrams per serving for four categories: infused edibles, infused liquid edible beverages, exempt liquid edibles and sublingual pouches.

Labs will submit those measurements through the statewide tracking system starting Nov. 5, the outlet reported. Delta-9 THC is the main intoxicating compound in cannabis; total THC also accounts for THCA that can convert to THC.

The same bulletin adds six terpenes that labs may voluntarily report through Metrc (para-cymene, ocimene, isopulegol, gamma-terpinene, geraniol and delta-3-carene), according to The Marijuana Herald. That testing stays optional, and businesses that want it must ask their labs. The outlet reported that the bulletin does not set new THC potency limits.

Hemp Law Watch could not independently retrieve the Metrc bulletin, so details of the Nov. 5 change are attributed to The Marijuana Herald's report.

Why it matters

Pouches are a newer format in cannabis markets, and Maryland's rules spell out what a regulated version looks like there: a concentrated cannabis product, a 10-milligram serving cap, a 100-milligram package cap, a specific warning label, a symbol on every pouch or wrapper, and agency approval before sale. For businesses, the Nov. 5 lab change means per-serving THC numbers for pouches will be recorded in the state's tracking system, not just the overall concentration.

The rules apply only to products sold in Maryland's licensed cannabis market. They do not address hemp-derived products sold outside dispensaries.

Current status and later developments

As of Oct. 25, 2026, COMAR 14.17.13.13 and 14.17.18.08 are posted in the state's online regulations library with the Sept. 14, 2026 effective date, and the chapter history lists Regulation .13 as adopted effective Sept. 14. Hemp Law Watch found no later MCA notice changing the pouch limits. The only later development found is the Nov. 5 lab reporting requirement described above.

The pouch rule is the latest addition to Maryland's cannabis product chapter, COMAR 14.17.13. According to the chapter's administrative history, its first regulations were adopted as emergency rules effective July 1, 2023, and made permanent effective July 22, 2024; Regulation .12 was added effective April 14, 2025, and Regulation .05G was amended effective March 16, 2026.

This report summarizes state regulations and news coverage. It is not legal advice.