New Maryland law limits board action against veterinarians who discuss cannabis and CBD

A Maryland law that took effect October 1, 2026, bars the State Board of Veterinary Medical Examiners from suspending or revoking a license, reprimanding or censuring a licensee, or placing a licensee on probation solely because the licensee discussed or recommended cannabis or a cannabidiol (CBD)-containing product for an animal for "potential therapeutic effect or health supplementation purposes."¹

Gov. Wes Moore signed the measure, House Bill 452, on April 14, 2026.¹ A companion Senate bill was sponsored by Sen. Clarence Lam, and both bills passed each chamber unanimously, according to Marijuana Moment.² The change arrives as federal policies on marijuana and hemp continue to shift.

What Maryland's law covers and what it does not

The law covers 2 categories of products. The first is cannabis as defined under Maryland law: Cannabis sativa L. and its derivatives and extracts with a delta-9 tetrahydrocannabinol (THC) concentration greater than 0.3% on a dry weight basis. That definition excludes hemp and hemp products. The second category is any product that contains CBD, which brings hemp-derived CBD products within the scope of the protection.¹

The protection applies only when the discussion or recommendation is the sole basis for one of the listed disciplinary actions, and the board's other grounds for action remain in place. The law amends only the board's disciplinary provisions. It does not address prescribing, dispensing, or approval of cannabis or CBD products for animals.¹

According to the state's fiscal and policy note, as of March 2026, the board had not taken any formal action that the bill would prohibit. The board regulates more than 3300 veterinarians.³

Related: FDA clears pathway for conditional approval of cannabinoid drug for canine bone cancer pain

Why lawmakers said veterinarians needed the protection

At a February hearing before the Senate Education, Energy, and the Environment Committee, Lam said a letter the board had sent a few years ago made veterinarians cautious about discussing cannabis for animals, Marijuana Moment reported. He described the bill as a baseline protection so veterinarians could answer clients' questions with evidence-based information.²

A representative of the Maryland Veterinary Medical Association testified that clients frequently ask about over-the-counter CBD products they are already giving their pets and that many veterinarians felt constrained in discussing those products, knowing the state could take punitive action against their licenses.²

Federal marijuana rescheduling remains partial

On April 22, 2026, a final order moved 2 categories of marijuana from Schedule I to Schedule III: FDA-approved drug products containing marijuana and marijuana covered by a qualifying state medical marijuana license. Hemp was not affected because federal law does not classify it as marijuana.⁴

A separate Drug Enforcement Administration (DEA) proceeding is considering whether to move the remaining marijuana to Schedule III. An evidentiary hearing was held in June and July.⁵ On September 29, the DEA's chief administrative law judge stayed that proceeding while considering a request to add a new Government Accountability Office report to the record.⁶ The stay applies to the broader proceeding, not to the April order.

A tighter federal hemp definition is scheduled for December 11

A federal law enacted in November 2025 amended the definition of hemp to exclude final hemp-derived cannabinoid products containing more than 0.4 mg per container of total THC, a count that includes tetrahydrocannabinolic acid and other cannabinoids with similar effects, or marketed as having similar effects, on humans or animals.⁷

A continuing resolution enacted in September 2026 delayed most of those changes, including the 0.4-mg-per-container threshold, until December 11, 2026. One part was not delayed: products containing cannabinoids that cannot be naturally produced by the cannabis plant are to be classified as marijuana beginning November 12, 2026.⁸

Some industry stakeholders have estimated that 90% or more of non-intoxicating, full-spectrum CBD products would fall outside the amended definition, according to a summary by the law firm Frier Levitt. The estimate is not a government projection.⁹

No FDA-approved cannabis drugs exist for animals

The FDA has approved 1 cannabis-derived human drug, Epidiolex, and 3 cannabis-related human drugs: Marinol, Syndros, and Cesamet. The agency states that it has not approved cannabis for any use in animals and cannot ensure the safety or effectiveness of cannabis products marketed for them, and it recommends that pet owners talk with their veterinarian.¹⁰

Federal extralabel drug use rules allow veterinarians to prescribe approved human and animal drugs under specific conditions, but those rules apply only to approved drugs.¹⁰

In January 2023, the FDA concluded that its existing regulatory frameworks for foods and dietary supplements were not appropriate for CBD and said a new regulatory pathway was needed.¹¹ In January 2025, the FDA Center for Veterinary Medicine asked veterinarians to share their experience with cannabis-derived products in animals, including adverse events and drug interactions.¹²

What recent studies in dogs show

A double-blinded, placebo-controlled crossover study enrolled 51 dogs with drug-resistant idiopathic epilepsy. A CBD dosage of 5 mg/kg per day met futility requirements after 12 dogs, and the remaining 39 received 9 mg/kg per day. At that dosage, total seizure frequency decreased significantly compared with placebo, and seizure days fell 24.1% with CBD while rising 5.8% with placebo. The number of dogs with at least a 50% decrease in total seizures or seizure days did not differ significantly between treatments. The authors recommended monitoring liver enzymes when CBD is administered.¹³

In a 6-month randomized, placebo-controlled, blinded study of 40 healthy dogs, a once-daily 4 mg/kg dose of a THC-free CBD distillate was well tolerated. Just over half of the 20 dogs receiving CBD had a transient increase in alkaline phosphatase without concurrent increases in other liver parameters.¹⁴

In Canada, the animal health subcommittee of Health Canada's Science Advisory Committee on Health Products Containing Cannabis reported in 2022 that pain associated with osteoarthritis in dogs was the only condition with sufficient evidence of CBD efficacy, and that the available information was insufficient to recommend a dose. The subcommittee recommended that CBD products intended for dogs be accompanied by a veterinarian-confirmed osteoarthritis diagnosis and suggested that they be sold only in veterinary clinics.¹⁵

The supplement industry is seeking its own federal category

The National Animal Supplement Council (NASC) unveiled a proposed Animal Health Supplement Act in April. It would create a legal category for animal health supplements limited to structure and function claims, with product listing, manufacturing standards, and adverse event reporting overseen by the FDA Center for Veterinary Medicine. NASC President Bill Bookout said the legislation will likely be introduced when the next Congress is seated in January 2027.¹⁶

What the law changes for Maryland practitioners

For Maryland veterinarians, the law removes discussion or recommendation alone as a basis for the listed disciplinary actions. It does not make any product an approved animal drug, determine which products may legally be sold, or establish that any product is safe or effective.

References

1. Maryland General Assembly. Chapter 47 (House Bill 452): State Board of Veterinary Medical Examiners – Grounds for Disciplinary Action – Restrictions. Approved April 14, 2026. Accessed October 8, 2026. https://mgaleg.maryland.gov/2026RS/chapters_noln/Ch_47_hb0452T.pdf

2. Angell T. Maryland law protecting veterinarians who recommend medical marijuana for animals takes effect this week. Marijuana Moment. September 29, 2026. Accessed October 8, 2026. https://www.marijuanamoment.net/maryland-law-protecting-veterinarians-who-recommend-medical-marijuana-for-animals-takes-effect-this-week/

3. Department of Legislative Services. Fiscal and policy note: Senate Bill 54, third reader. Maryland General Assembly. March 20, 2026. Accessed October 8, 2026. https://mgaleg.maryland.gov/2026RS/fnotes/bil_0004/sb0054.pdf

4. DEA reschedules FDA-approved and state-licensed medical marijuana to Schedule III. Taft Stettinius & Hollister LLP. Accessed October 8, 2026. https://www.taftlaw.com/news-events/law-bulletins/dea-reschedules-fda-approved-and-state-licensed-medical-marijuana-to-schedule-iii/

5. High time for a change: post–DEA hearing, broader marijuana rescheduling questions remain. Morgan Lewis. September 2026. Accessed October 8, 2026. https://www.morganlewis.com/pubs/2026/09/high-time-for-a-change-post-dea-hearing-broader-marijuana-rescheduling-questions-remain

6. Julius DC. Stay and briefing order. Proposed marijuana rescheduling, DEA Docket No. 1362. Drug Enforcement Administration. September 29, 2026. Accessed October 8, 2026. https://www.dea.gov/sites/default/files/2026-09/Proposed%20Marijuana%20Rescheduling_Stay%20and%20Briefing%20Order.pdf

7. Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026, Pub L No. 119-37, §781 (2025). Accessed October 8, 2026. https://www.congress.gov/bill/119th-congress/house-bill/5371

8. Congressional Research Service. Changes to the statutory definition of hemp and implications for agricultural policy. IF13136. Updated September 28, 2026. Accessed October 8, 2026. https://www.congress.gov/crs-product/IF13136

9. The redefinition of "hemp" under federal law: regulatory status, legislative developments, and pending industry challenges. Frier Levitt. Accessed October 8, 2026. https://www.frierlevitt.com/articles/federal-hemp-redefinition-2026-thc-limits-compliance/

10. FDA regulation of cannabis and cannabis-derived products, including cannabidiol (CBD). US Food and Drug Administration. Accessed October 8, 2026. https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-cannabis-derived-products-including-cannabidiol-cbd

11. FDA concludes that existing regulatory frameworks for foods and supplements are not appropriate for cannabidiol, will work with Congress on a new way forward. US Food and Drug Administration. January 26, 2023. Accessed October 8, 2026. https://www.fda.gov/news-events/press-announcements/fda-concludes-existing-regulatory-frameworks-foods-and-supplements-are-not-appropriate-cannabidiol

12. FDA solicits public comments on use of cannabis-derived products in veterinary medicine. US Food and Drug Administration. January 15, 2025. Accessed October 8, 2026. https://www.fda.gov/animal-veterinary/cvm-updates/fda-solicits-public-comments-use-cannabis-derived-products-veterinary-medicine

13. Rozental AJ, Weisbeck BG, Corsato Alvarenga I, et al. The efficacy and safety of cannabidiol as adjunct treatment for drug-resistant idiopathic epilepsy in 51 dogs: a double-blinded crossover study. J Vet Intern Med. 2023;37(6):2291-2300. doi:10.1111/jvim.16912

14. Bradley S, Young S, Bakke AM, et al. Long-term daily feeding of cannabidiol is well-tolerated by healthy dogs. Front Vet Sci. 2022;9:977457. doi:10.3389/fvets.2022.977457

15. Review of cannabidiol: report of the Science Advisory Committee on Health Products Containing Cannabis. Health Canada. July 2022. Accessed October 8, 2026. https://www.canada.ca/en/health-canada/corporate/about-health-canada/public-engagement/external-advisory-bodies/health-products-containing-cannabis/review-cannabidiol-health-products-containing-cannabis.html

16. Cleaver L. Update: Animal Health Supplement Act would give products legal home. Petfood Industry. October 7, 2026. Accessed October 8, 2026. https://www.petfoodindustry.com/pet-supplements-pro/nasc-regulatory-update/article/15831660/update-animal-health-supplement-act-would-give-products-legal-home

Regulatory and legislative information in this article is current as of the publication date and is subject to change.