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Memphis, TN Business Licensing & Operations: Tobacco Retail License (2026)

Significant Restrictions
Compiled from the official code textEditor Martyn O'NeillLast verified September 2026

Key Facts

Governing section
UDC § 2.6.3.S, Smoke Shops
Buffer distance
1,320 feet from school, church, day care, park
Measured
Parcel to parcel, not building to building
Grandfather cutoff
Vapor shops open before Nov. 15, 2016
Applies to
City of Memphis and unincorporated Shelby County

Summary

Memphis and Shelby County zoning bars new smoke shops from locating within 1,320 feet of any school, place of worship, day care facility, or park, measured parcel to parcel. Vapor shops open before the November 15, 2016 effective date of ZTA 16-1 are grandfathered and can expand, modify, or relocate within the same site despite the buffer.

Smoke shops not covered by an exception below shall be located no closer than 1320 feet from any school, place of worship, day care facility or park, as measured from the parcel that contains the smoke shop and the parcel that contains the school, place of worship, day care facility or park. The following smoke shops are exempted from this provision: 1. Vapor shops that existed at the time zoning text amendment ZTA 16-1 became effective (November 15, 2016) shall not be considered nonconforming uses and may be expanded, modified or relocated within the same site.

View official code

Official source re-checked September 8, 2026: the cited page had not changed since it was quoted.

Full Breakdown

S of the Unified Development Code, part of the Commercial Use Standards chapter that governs both the City of Memphis and unincorporated Shelby County, sets a hard locational buffer for smoke shops rather than a licensing scheme. Any smoke shop not covered by the section's exception must sit no closer than 1,320 feet, about a quarter mile, from a school, a place of worship, a day care facility, or a park. The distance is measured parcel to parcel: from the parcel that holds the smoke shop to the parcel that holds the protected use, not simply from building to building.

The only carve-out in the section covers vapor shops that were already operating when zoning text amendment ZTA 16-1 took effect on November 15, 2016. Those pre-existing vapor shops are not treated as nonconforming uses under the buffer, which means they can be expanded, modified, or relocated within the same site without losing their exemption, something an ordinary nonconforming use could not do. Any smoke shop that opened after November 15, 2016, or that was not a vapor shop at that time, gets no exemption and must meet the full 1,320-foot separation before it can obtain a certificate of occupancy.

Because the standard sits in the shared Unified Development Code, the identical buffer and grandfather rule apply whether the proposed smoke shop is inside Memphis city limits or in unincorporated Shelby County.

Violations & Fines

A smoke shop sited inside the 1,320-foot buffer without qualifying for the vapor-shop exemption can be denied a certificate of occupancy or ordered to relocate by the Zoning Administrator. Operating without the required separation, or expanding a non-exempt shop into the buffer zone, exposes the business to zoning enforcement action and possible closure until the site meets the distance standard.

Frequently Asked Questions

How far must a new smoke shop be from a school in Memphis?
Section 2.6.3.S requires 1,320 feet, measured from the parcel containing the smoke shop to the parcel containing the school, church, day care facility, or park. That distance applies to any smoke shop that does not qualify for the vapor-shop grandfather exemption, and it is the same standard inside Memphis and in unincorporated Shelby County.
Is my existing vape shop exempt from the 1,320-foot buffer?
Only if it was already operating on November 15, 2016, when zoning text amendment ZTA 16-1 took effect. Section 2.6.3.S says those pre-existing vapor shops are not considered nonconforming and can be expanded, modified, or relocated within the same site. A shop opened after that date gets no exemption.
Does this section require a business license for smoke shops?
No, Section 2.6.3.S is a zoning locational standard, not a licensing ordinance; it controls where a smoke shop can sit relative to schools, churches, day cares, and parks. Separate city and state tobacco retail licensing requirements apply on top of, and independently from, this zoning distance rule.

Sources & Official References

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