Waiting Game: Tennessee's New Hemp-Derived Cannabinoid Rules Delayed Again

At the end of last year, it seemed like Tennessee's final hemp-derived cannabinoid ("HDC") rules would (finally) take effect as scheduled on December 26, 2024. As we discussed in an earlier blog post, since 2023 when the Tennessee legislature passed state's hemp-derived cannabinoid ("HDC") product law (T.C.A. § 43-27-201 et seq.), the Tennessee Department of Agriculture ("Department") has been working to promulgate final implementing regulations. What perhaps should have been a straightforward notice and comment rulemaking process was complicated by the Department's decision over the summer to push forward with temporary emergency HDC rules after already releasing draft permanent HDC rules for public review and comment. This procedural irregularity introduced a measure of turmoil into the rulemaking process with hemp operators and stakeholders crying foul. Eventually, the formal notice and comment rulemaking process on the final permanent HDC rules concluded on