Labor Peace Agreement Requirements for Minnesota Cannabis Applicants

Summary: Most Minnesota cannabis business license applicants must enter into a labor peace agreement (LPA) with a bona fide labor organization as part of the application process. There are specific exceptions and employee thresholds, especially for microbusinesses.

Who Must Register for a Labor Peace Agreement?

• General Rule: All cannabis business license applicants in Minnesota are required to submit an attestation, signed by a bona fide labor organization, stating that the applicant has entered into a labor peace agreement as part of the application process 65.

• Definition: A labor peace agreement is a contract between a cannabis business and a bona fide labor organization that, at minimum, prohibits the labor organization from engaging in picketing, work stoppages, or boycotts against the business42.

Are There Employee Limits or Exceptions?

• Microbusinesses:

  • Initial Application: Microbusiness applicants are not required to submit a labor peace agreement at the time of initial application36.

  • Renewal: Upon license renewal, if a microbusiness has ten or more full-time equivalent employees, it must submit an attestation signed by a bona fide labor organization stating that it has entered into a labor peace agreement 36.

  • If fewer than ten employees: No labor peace agreement is required at renewal if the microbusiness has fewer than ten full-time equivalent employees 3.

• All Other License Types: All other cannabis business license types (mezzobusiness, cultivator, manufacturer, retailer, wholesaler, transporter, testing facility, delivery service, medical cannabis combination business) must provide a labor peace agreement attestation as part of the application, regardless of employee count 65.

Table: Labor Peace Agreement Requirements by License Type

License Type	LPA Required at Application?	Employee Threshold for LPA at Renewal?
Microbusiness	No	Yes, if 10+ FTE at renewal
Mezzobusiness	Yes	N/A
Cultivator	Yes	N/A
Manufacturer	Yes	N/A
Retailer	Yes	N/A
Wholesaler	Yes	N/A
Transporter	Yes	N/A
Testing Facility	Yes	N/A
Delivery Service	Yes	N/A
Medical Cannabis Combination	Yes	N/A

Key Takeaways

• Most applicants must register for a labor peace agreement as part of the application process.

• Microbusinesses are exempt at initial application but must comply at renewal if they reach 10 or more full-time equivalent employees.

• There are no other employee count thresholds for other license types; the LPA is required regardless of size.

References:

• [OCM Qualified Applicant Guide]6

• [OCM Application Guidance]5

• [Minnesota Statutes 342.28]3

• [Minnesota Statutes 342.01]