Tennessee THC Beverage Laws & Compliance

Tennessee THC beverage compliance snapshot

Who regulates THC beverages in Tennessee?

The Tennessee Alcoholic Beverage Commission took over regulation of hemp-derived cannabinoid product suppliers, wholesalers, and retailers beginning January 1, 2026. Legacy Tennessee Department of Agriculture licenses remained effective through June 30, 2026, but that transition period has now ended.

Tennessee therefore should not be described as a market that is still waiting to move into the TABC system. The supplier, wholesaler, and retailer licensing structure is now the current state system for regulated hemp-derived cannabinoid products.

Tennessee Alcoholic Beverage Commission: Hemp FAQs

What THC limits apply to Tennessee beverages?

TABC says products regulated under the current system must contain no more than 0.3% total THC. TABC describes total THC as (THCA × 0.877) + Delta-9 THC and states that THCp and synthetic cannabinoids are prohibited.

For ingestible HDCPs, Tennessee law limits a serving to no more than 15 mg in the aggregate of one or more hemp-derived cannabinoids. For beverage products, a container generally may not contain more than two servings. The law also contains additional rules for larger containers and specified keg formats.

A beverage intended for Tennessee should therefore be reviewed for both the state's total-THC concentration limit and its serving/container rules before production.

How does Tennessee's supplier, wholesaler, and retailer system work?

Tennessee uses three general HDCP license types: supplier, wholesaler, and retailer. Unlike Tennessee's alcohol system, the state says one person or company may hold interests in more than one of these hemp license types.

The important restriction for beverage distribution is that, beginning July 1, 2026, a TABC-licensed retailer may obtain new HDCP inventory only from a TABC-licensed wholesaler. TABC also states that out-of-state suppliers of HDCPs must obtain a Tennessee supplier license.

Can a Tennessee retailer buy directly from an out-of-state manufacturer?

Not for new inventory under the current TABC retailer system. Since July 1, 2026, licensed retailers may obtain new HDCP inventory only from licensed Tennessee wholesalers.

A business considering an out-of-state manufactured beverage should therefore resolve the supplier and wholesaler roles before assuming the product can be shipped directly to a Tennessee retail location.

Do out-of-state suppliers need a Tennessee license?

Yes, according to current TABC guidance. TABC states that out-of-state suppliers of hemp-derived cannabinoid products are required to obtain a TABC license. Tennessee law also regulates supplying, wholesale distribution, and retail sale of HDCPs.

This is an important distinction for brands using an out-of-state contract manufacturer. The exact licensing result can depend on which company owns the product, which company sells the finished packaged product into Tennessee, and which company acts as the licensed supplier. Those roles should be confirmed before inventory is produced for the Tennessee market.

Does each THC beverage brand have to be registered?

Yes. Beginning January 1, 2026, each hemp-derived cannabinoid product brand distributed in Tennessee must be registered with the Tennessee Department of Revenue before distribution. Suppliers register and renew their brands through Tennessee's tax system.

The current annual brand-registration fee is $300 per brand.

Tennessee Department of Revenue: Approved HDCP Brands

What testing and COA requirements matter?

Tennessee requires testing and product documentation for regulated HDCPs. Current labeling rules require QR-code access to batch and testing information, including the applicable certificate of analysis.

For a beverage brand, the practical questions include whether the finished product was tested under the applicable Tennessee requirements, whether the COA matches the batch being distributed, and whether the package gives the required access to that information.

What does Tennessee require on the package?

Current Tennessee law includes detailed labeling and packaging requirements. The statute addresses ingredients and allergens, Nutrition Facts, warning information, the amount of hemp-derived cannabinoids, net weight, QR-code access to testing information, expiration dating, and other product-specific disclosures.

For beverages, Tennessee also regulates the container and serving structure. Multi-serving beverage containers at or below 750 mL must be resealable, and the law specifies acceptable closure types for other covered beverage containers.

Products may not be marketed using characters, imagery, or other presentation known to appeal primarily to people under 21, and HDCPs may not be mixed with alcoholic beverages.

What taxes apply to Tennessee hemp-derived cannabinoid products?

Tennessee imposes a wholesale tax on HDCPs. The Department of Revenue currently lists a rate of $4.40 per gallon for liquid HDCPs, or a proportional amount when the product is sold or distributed in a different liquid measure. Wholesalers are responsible for the wholesale tax.

Tennessee Department of Revenue: Hemp-Derived Cannabinoid Products Tax

Is Tennessee a standard Next Level Leaf white-label market?

Tennessee is an important regulated THC beverage market, but its current supplier and wholesaler requirements make it different from states where an out-of-state production partner can simply manufacture finished cans and sell them directly to a local brand or retailer under the ordinary production model.

Next Level Leaf therefore treats Tennessee primarily as a compliance-reference market rather than a standard direct-launch market. A business that already has the required Tennessee supplier and wholesale structure should confirm its exact transaction and licensing setup before committing production.

Primary Tennessee sources

• Tennessee Alcoholic Beverage Commission: Hemp FAQs
• TABC: Public Information, current supplier, wholesaler and retailer license lists
• Tennessee Department of Revenue: Hemp-Derived Cannabinoid Products Tax
• Tennessee Department of Revenue: Approved Brands
• Tennessee General Assembly: 2026 Public Chapter 698 changes

Related resources

Frequently asked questions about Tennessee THC beverage laws