Administrative Order Requiring Licensees to Upload Certificates of Analysis in Metrc | April 17, 2025

Administrative Order No. 5
Issued: April 17, 2025
Effective: June 16, 2025

Medical Marijuana Treatment Centers
Marijuana Establishments

Administrative Order Requiring Licensees to Upload Certificates of Analysis in Metrc

G.L. c. 94G, G.L. c. 94I

935 Code Mass. Regs. §§ 500.105, 500.120, 500.130, 500.140, 500.141, 500.146, 500.147,
500.160, 500.200 and
935 Code Mass. Regs. §§ 501.105, 501.120, 501.130, 501.140, 501.141, 501.146, 501.147,
500.160, 501.200

The Cannabis Control Commission (“Commission”), acting through its Executive Director, hereby issues this Administrative Order No. 5 (“Administrative Order”) to ensure transparent and consistent reporting of compliance test results for Marijuana and Marijuana Products sold or otherwise marketed to Patients and Consumers consistent with its statutory mandate under G.L. c. 94G and G.L. c. 94I, and applicable adult- and medical-use regulations, 935 Code Mass. Regs. (CMR) §§ 500.000 and 501.000.

The Commission, acting through its Executive Director, hereby ORDERS as follows:

This Administrative Order requires all licensed Independent Testing Laboratories (“ITLs”) to upload all certificates of analysis (“COA”) to Metrc’s Seed-to-Sale System of Record (“SOR”), for all testing performed on behalf of Marijuana Establishments (“ME”) and Medical Marijuana Treatment Centers (“MTC”) in accordance with 935 CMR 500.160, 935 CMR 501.160, and the Protocol for the Sampling and Analysis of Finished Marijuana Products and Marijuana Products for Marijuana Establishments, Medical Marijuana Treatment Centers, and Colocated Marijuana Operations and associated exhibits (collectively, the “Protocol”). In compliance with this Order:

1. ITLs shall begin simultaneously reporting results and uploading COAs to Metrc, the Commission’s seed-to-sale system of record within sixty (60) days after the effective date of this Administrative Order, until its recission or amendment.
2. ITLs shall report the measured concentration for each analyte detected during the course of Marijuana or Marijuana Product testing on the COA and in the Commission’s seed-to-sale system of record.
3. ITLs shall identify the analytical method utilized for each test as a reference to the ITL’s applicable written operating procedure outlining the method (i.e., lab SOP #), and a description of the method (e.g., HPLC, LC-MS, etc.), as well as the registration number of the ITL agent(s) that oversaw the analysis. The method, lab SOP, and analyst shall be reported in the COA accompanying the reported results for each compliance test category.
4. An ITL with an approved hardship subcontracting request is responsible for the creation of the final COA which shall include tests results from the subcontractor. Tests performed by the approved subcontractor shall be clearly denoted on the COA. An ITL using the services of a subcontractor shall have procedures detailing the review of the subcontractor results for conformance and known data quality. The subcontractor is required to report all compliance test results in compliance with ISO 17025:2017 requirements.
5. For purposes of this Administrative Order, a “sanitization treatment” shall mean a treatment of a Marijuana batch, conducted prior to compliance testing, that is intended to minimize microbiological contaminants in Marijuana and Marijuana Products.
6. MEs and MTCs shall disclose to the ITL if the Marijuana batch was subjected to a sanitization treatment or if the Marijuana batch was remediated prior to reanalysis, and what method was used.
7. ITLs shall indicate on the COA whether the source Marijuana batch was subjected to a sanitization treatment or if the Marijuana batch was remediated prior to reanalysis, as well as the method used.
8. Failure to comply with the above conditions may result in disciplinary action against Licensees and its agents up to and including a fine, suspension, and/or revocation of licensure or registration.
9. Nothing herein shall be construed as precluding or limiting the Commission’s authority to take additional administrative action to protect the public health, safety, and welfare.
10. The provisions of this Administrative Order shall be severable. Should a court of competent jurisdiction declare any provision of this Order unconstitutional or invalid, the validity of the remaining provisions shall not be affected.

This Administrative Order No. 5 shall take effect on June 16^th, 2025, at 12:00 A.M.

This Administrative Order No. 5 shall remain in effect until such time the Commission rescinds or amends this order. The Commission may amend or modify this order as applicable to individual Licensees, groups of Licensees, or all Licensees. The Commission may issue further technical bulletins or guidance documents to clarify required processes through the Seed-to-Sale System of Record.

Questions about this order may be directed in writing to the above address, by phone (744-415-0200) on Monday – Friday from 9:00 A.M. – 5:00 P.M., or by email at Testing@CCCMass.com.

Signed this 17^th day of April 2025.

Commonwealth of Massachusetts Cannabis Control Commission
Travis Ahern
Executive Director