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Prohibited Products

We recommend striking the THC caps for flower and concentrates and increasing the manufactured products per serving limit to 10 mg. A 5 mg serving limit is below the market average serving limit, runs contrary to consumer behavior, is more restrictive than other legal states, will reduce our market standing amongst our neighbors, and will most likely increase packaging waste, particularly plastics.

1. The restrictions on cannabis concentrate laid out in Act 164 (2020) would effectively mandate vaporizer cartridge use, creating a massive amount of avoidable packaging and electronics waste;

2. Most cannabis concentrates have a higher THC content than 60%. Implementing an arbitrary THC limit for concentrates is impractical and disincentives clean extraction processes, potentially leading to the use of adulterants to help producers dilute their concentrates into an acceptable potency range;

3. Additionally, the 5 mg per serving and 50 mg total per product restriction will create undue burdens and obstacles for consumers and product manufacturers, alike. These minimal dosages are the lowest in the country and will ensure consumers will pay more for an effective dosage than they would in other legal states, or even in the local illicit market, reducing Vermont’s overall market competition and the ability for local illicit businesses to transition into the legal market.