The Rhode Island Cannabis Control Commission (CCC) recently issued a decision regarding advertising regulations for Hank’s Herbs. The central issue? The billboard advertisement featured imagery that regulators deemed “appealing to minors.” This is a major compliance no-no across the cannabis industry, and the CCC took action.
What did Hank’s Herbs do to violate advertising regulations? Was this Rhode Island cultivator really targeting individuals under 21? This should be an easy violation to avoid, but Hank’s argued that the regulations in Rhode Island are vague. Maintaining compliance with advertising regulations is more challenging than you might think.
The billboard in question
The advertisement in question was located on several billboards in Rhode Island. It depicts a digitally-rendered image of a man with a gray mustache and goatee, wearing sunglasses and sporting a belt with a “1” in the center, held over his shoulder. To the left of this image, the advertisement reads “You Never Forget Your First Hank’s.” On the bottom right corner, the advertisement states “For ages 21+ and Medical Patients,” as well as the cultivator’s registered license number.
Is this billboard advertisement really a compliance issue? Regulators argued that Hank’s Herbs violated advertising regulations under § 2.8(B)(4)(c) of the Operational Requirements for Cannabis Establishments by featuring images that appeal to minors. Specifically, the enforcement action states that the image of the man is a “cartoon,” which is attractive to children. This is considered a compliance violation because it promotes underage cannabis use.
The CCC also mentions that the belt is a “champion belt for a boxing or a World Wide Wrestling match” and contributes to the violation. According to the CCC, individuals under 21 could be enticed to use cannabis if it is associated with wrestling related images. Apparently, regulators consider wrestling appealing to minors.
The owner of Hank’s Herbs argued strongly against the enforcement action. They indicated that the image of the man is not a cartoon, but a stylized and humorous depiction of the owner. They also clarified that the “championship belt” in question is not related to wrestling, but is an award for producing premium cannabis products.
Regulators pushed back, citing Merriam-Webster’s definitions of “drawing” and “cartoon.” Arguments over terminology and interpretations went back and forth. Ultimately, the CCC narrowed it down to whether the image depicted could be attractive to children.
What are the consequences of violating advertising regulations?
The CCC determined that the advertisement could be attractive to children and issued a cease-and-desist order to Hank’s Herbs. They were no longer allowed to use the image in question, per R.I. Gen. Laws § 21-28.11-18(a)(iii), and were required to remove the advertisement from all of the billboards that featured it, five in total.
The cost of billboard installation and rent depends on the location. Installation costs can range between $500 and $1,500. Monthly rent costs are much higher and could reach $30,000 depending on the location, such as a major highway. Even the design layout can cost $1,500 or more. That’s a lot of money to throw away if an advertisement violated advertising regulations! What’s worse is that early termination of a contract could result in 100% payment of the remaining contract balance.
Attorney fees are also nothing to laugh at. Hank’s Herbs was first cited for violating advertising regulations in October of 2025. The final decision on the matter was not reached until March of 2026.
Did they get off easy? Perhaps. The CCC could have imposed its own hefty fines for the violation. It settled for remediation, aka removal of the advertisements. There’s always the possibility that violating advertising regulations or advertising to minors could result in license revocation or inventory holds. We won’t know immediately, but this decision could affect Hank’s Herbs ability to renew their cultivation license in the future.
Arguments for what is and is not appealing to children will likely become a more frequent debate as the cannabis industry evolves. Interpretations and artistic license can vary while regulations change. Perhaps it’s best to avoid illustrations or digitally rendered images altogether, just to be safe.
How could this have been prevented?
Hank’s seemed to be informed about existing regulations when you consider the fact that they listed the required verbiage and their license number on the advertisement. The enforcement action taken against them serves as a stark reminder of how easily cannabis operators can violate advertising regulations when trying to create brand awareness.
A subscription to Simplifya Protect could have helped Hank’s Herbs avoid an advertising violation and unnecessary financial strain by doing the work for them. Simplifya monitors cannabis regulations in states across the country. A subscription to Protect starts at $335/month per location. Simplifya also monitors upcoming regulations that operators might not be aware of.
In the case of Rhode Island, changes to current regulations could significantly impact cannabis advertising in the near future. Take House Bill 7856, for example. If passed, this bill would prohibit any cannabis advertising on social media, TV, radio, magazines, billboards, and other print media. The bill was eventually held for further study, but it’s clear that regulators are looking to make advertising rules more restrictive, especially regarding minors.
So, how do cannabis operators stay informed? Simplifya can help businesses maintain compliance and prepare for regulatory changes that could impact their advertising and operational practices. Regulators don’t always make this information easily accessible to your average operator. The CCC posts informational bulletins from time to time, but these could be easily missed if there isn’t a designated compliance manager employed at companies like Hank’s Herbs.
While the “is it or isn’t it a cartoon” debate may seem subject to interpretation, for the CCC, the determination was clear. The imagery violated strict prohibitions against advertising that targets or attracts individuals under the age of 21.
Compliance is not just about avoiding fines; it’s about protecting your license and the integrity of the industry. As regulators in Rhode Island and beyond increase their oversight, ensuring your marketing meets the letter of the law is your best investment.