FAQ | Administrative Order No. 5 | June 13, 2025

Administrative Order No. 5 (the Order) is issued by the Cannabis Control Commission (Commission) on April 17, 2025, to ensure transparent and consistent reporting of compliance test results for Marijuana and Marijuana Products sold or otherwise marketed to Patients and Consumers in accordance with the applicable adult-use and medical-use regulations.

Effective: June 16, 2025, the Order will remain in effect until the Commission rescinds or amends it. The Commission may issue further technical bulletins or guidance documents to clarify required processes through the Seed-to-Sale System of Record, Metrc.

Guidance for Marijuana Establishments and Medical Marijuana Treatment Centers (Licensees)

In accordance with the Order, all Licensees must have access to Certificates of Analysis (COA) associated with Marijuana in its inventory through Metrc. Additionally, Metrc has issued the following bulletins to advise Licensees on how to access and download COAs: “MA_IB_0093_COA Upload Requirements” and “MA_IB_083: COA Download and View”.

For Licensees submitting test samples to Independent Testing Labs (ITLs), the Order outlines the disclosure requirement that must be followed when ordering testing. If a Licensee applies a pre-testing sanitization treatment on a production batch, it must be disclosed to the ITL performing testing for that production batch. A “sanitization treatment” means a treatment of a Marijuana batch, conducted prior to compliance testing, that is intended to minimize microbiological contaminants in Marijuana and Marijuana Products. The same requirement regarding the disclosure of the pre-testing sanitization treatment applies to tested Marijuana that has undergone remediation due to a contaminant failure. In Metrc, the pre-testing sanitization treatment disclosure and the method used for sanitization shall be indicated in the Notes field when creating a test sample.

Licensees are reminded that they must comply with the Sampling Program Design and Sample Collection Procedures specified in Sections 5.0 and 6.0 of 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 in accordance with 935 CMR 500.160 and 925 CMR 501.160. Pre-testing sanitization treatments or remediation must be applied to the entire source production batch that is to be tested to ensure representative sampling accuracy and applicability of testing results.

Frequently Asked Questions (FAQs)

How do I upload COAs to Metrc?

ITLs should follow the instructions outlined on page 52 through 55 of the “MA Testing Facility User Guide Revision 25.1”. This document was sent directly to ITLs by Metrc. Please contact Metrc support for additional guidance.

Can an ITL upload revised COAs?

The testing facility can upload amended or updated COAs; however, only the latest COA will be visible. Previously uploaded COAs remain in the system and cannot be removed by the ITL.

Can an ITL upload COAs in bulk?

At this time, Metrc does not permit bulk uploads of COAs.

When Administrative Order No. 5 becomes effective on June 16, 2025, will the requirements apply to COAs issued after that time or to samples received after that time?

All COAs produced from samples received on or after June 16, 2025, at 12:00 a.m. are subject to Administrative Order No. 5 compliance requirements.

Does the COA need to contain the name of the agent overseeing the analysis?

The Order requires ITLs to report the Agent registration number of the Agent(s) overseeing each analytical process, in the same area of the COA where the results of that process are reported (accompanying the reported results of each compliance test category). ITLs may include initials or additional identifying information at their discretion, and consistent with their ISO accreditation. The ITL Agent(s) overseeing the analytical process must be the same as the analyst that conducted the analysis.

How should the reference to the Lab SOP be formatted?

ITLs must identify the analytical method utilized for each test as a reference to the ITL’s applicable written standard operating procedure (SOP) outlining the method (i.e., lab SOP #), The lab SOP must match the ITL’s internal naming convention, as well as a version identifier, if applicable.

Whose responsibility is it to disclose sanitization and remediation?

Disclosing whether a batch of Marijuana was subjected to a pre-testing sanitization or remediation process is the responsibility of the Licensee that submitted the test sample(s) to an ITL. For the purposes of consistent compliance, all Marijuana and Marijuana Products derived from or partially comprised of a batch that was sanitized pre-testing or remediated shall continue to be tracked as such.

The ITL can only report the representation of the sample made by the originating Licensee. The ITL is not expected to determine if the batch it received a sample from was sanitized or remediated, nor which process was used. Therefore, an ITL should only report on the COA the characterization made by the Licensee that produced the product.

Licensees are required to report the sanitation or remediation status on the production batch from which the test samples derive. The ITL can enter the sanitation or remediation report on the cover page of the COA where the sample properties are described. ITLs may create an additional field in the COA to report this information, if desired.

Are types of sanitization and remediation processes standardized or up to the Licensee to characterize?

At this time, the Commission does not specify standardized sanitization steps. It is the responsibility of the originating Licensee to identify and characterize the method used for sanitization and remediation, and to report that to the ITL receiving the test sample. For remediation, the method used must match the information that is entered in Metrc. For example, if a Marijuana flower product was remediated using extraction, then the resulting concentrate product would need to be described in that manner.

For example, irradiation, ozone treatment, and similar processes would be considered sanitization or remediation treatments that would need to be disclosed to their ITLs when ordering testing.

If a production batch undergoes a sanitization step and the representative test sample fails testing which then receives remediation, are both processes reported to the ITL and indicated on the final COA?

Yes, if a production batch undergoes any of these processes, the designation must remain with all subsequent packages that are tested by an ITL. All processes must be reported separately, both to the ITL and on the COAs.

What happens if a Licensee fails to disclose the sanitization or remediation process?

Failure to comply with the Order may result in administrative or disciplinary action against a Licensee and its agents up to and including a fine, suspension, and/or revocation of licensure or registration. Additionally, the Commission may take enforcement action against any Licensee that selectively applies sanitization or remediation only to lab test samples and not the entire source production batch.