Applicants and Licensees / Seed-to-sale Tracking
Seed-to-sale Tracking
Seed-to-sale Tracking is a rigorous inventory control system that tracks the cultivation, processing, and sales of cannabis and cannabis-infused products to consumers and Registered Qualifying Patients.
All licensed Marijuana Establishments (MEs) and Medical Marijuana Treatment Centers (MTCs) are required to maintain a Seed-to-sale Tracking System.
The Commonwealth of Massachusetts employs Metrc, a web-based marijuana inventory system that uses radio frequency identification technology and serialized plant and package tags to follow marijuana from seed to point of sale.
Cultivation
Guidance for cultivators on how to manage inventory with Metrc.
Are additives required to be entered in Metrc?
No, during cultivation, additives are not required to be tracked in the state’s Seed-to-sale Tracking System, Metrc. Cultivators may input additives into Metrc to track growing processes. A Licensee cannot edit or delete an additive once it has been entered.
How many tags do I need to order for plants and packages?
The number of tags you order is a business decision; however, you are responsible for having a sufficient stock of tags at all times for daily inventory reconciliation and tracking. A Licensee can order a maximum of 5,000 tags per order.
Immature Plants
Can I transfer seeds or clones to another license?
Yes, Licensees may transfer seeds and clones to a different license. Once a Licensee tags a plant in Metrc, however, it must remain under that license.
The FAQ for clone sales is available here https://masscannabiscontrol.com/frequently-asked-questions/#clone-sales.
Can I bring in New Genetic Material that is outside of Metrc?
Yes, please contact your Investigator or Compliance Officer.
How does a Licensee add their inventory to Metrc?
Clones are entered as strain-specific immature batches. There is a maximum clone count of 100 clones per batch. The Licensee is required to tag each clone once they are moved to the vegetative stage, usually once clones reach eight inches tall. All clone packages must be strain-specific, and the item name must include clones, for example, Blue Dream Clones.
The Commission strongly recommends Licensees manually enter their inventory into the state’s Seed-to-sale Tracking System. If a Licensee chooses to upload their inventory through their third-party API, they must ensure the figures entered reflect accurate inventory.
If a Licensee chooses this route, the Commission recommends that the Licensee create a master spreadsheet of inventory to keep on file.
How are seeds entered in Metrc?
Harvested seeds: Once a Licensee harvests seeds, they must be tracked. Each harvested seed packet cannot contain more than 50 seeds.
Immature seeds: Licensees must count and enter strain-specific immature seeds into Metrc unless they are in the process of being planted. Retail Licensees can store seed packages as count-based for internal use.
Transferring seeds: When transferring seeds to a Retailer, Licensees must physically put them into seed lots of six for sale. Licensees may put multiple packets of six under one Metrc tag.
How does a facility track the chain of custody for clones and seeds?
Strain-specific clone and seed packages are transferred using a transfer manifest in Metrc. The Licensee will select the tab “create plantings” from each of the strain-specific package tags. This will create a new strain-specific immature planting. The same “create plantings” tab is available under both the vegetative and flowering tabs for seeds or cuttings generated from tagged plants.
How do I enter strain-specific immature batches if I do not know what the strain is?
A Licensee is required to enter the strain name.
Flowering Plants
Read this bulletin about Harvest Batches Best Practices.
If a Licensee enters the incorrect wet weight for a plant, are they required to destroy their harvest batch?
No, a Licensee that enters the incorrect wet weight for a plant is not required to destroy the harvest. Licensees have 48 hours after the entry to contact Metrc Support to request a correction. If not corrected within 48 hours, Licensees should complete an incident report and document a plan of correction. Licensees are not allowed to average the wet weights of plants in their harvest batches.
When plants are entered in Metrc, should they be weighed individually or in bulk and then averaged?
Plants must be weighed individually when entered in Metrc. Licensees are not allowed to average weights of plants.
How does a Licensee make its test packages?
For cured and dried flower, test packages are made from each strain-specific post-harvest batch after trimming and drying. Post-harvest batches are limited to 15 pounds of dry weight flower, shake, or trim.
For wet processing, test packages are made from each strain-specific post-harvest batch. Post-harvest batches are limited to 15 pounds and must be tested for pesticides.
When making a test sample, all associated package tags must be selected in the creation of the Metrc test sample package.
How should waste be tracked in Metrc?
Waste should be reported in Metrc either by room or by plant tag. A Licensee may have multiple entries of waste, but all waste must be accounted for by the end of the business day.
Can a Licensee wait to create their harvest batch until the entire strain is harvested, which might take several days?
No, at the end of day physical inventory must match Metrc. For example, if a Licensee is harvesting a strain that takes two days to complete, the Licensees would create a batch each day for what is harvested.
Is it a requirement that Licensees enter the strain name as the harvest batch name?
Yes, Licensees should include the strain name and date of harvest in the harvest batch name.
Is there a maximum amount of plants in a harvest batch?
No, there is no maximum amount of plants in a harvest batch. Any product harvested throughout the day must match the end-of-day inventory in Metrc.
Post-harvest batches, i.e., cured and dried flower, are limited to 15 pounds per batch.
Product Manufacturing
Guidance for product manufacturers on how to manage inventory with Metrc.
During the product manufacturing stages, when is it required to assign a production batch number?
If a product is physically or chemically altered, a new production batch number must be assigned.
Whenever a new product is created for the purpose of selling to the general public, or for the purpose of adding to a product which will be sold to the general public, that product must be tracked in Metrc.
When does the separation of Medical versus Adult Use products occur?
If potency levels allow the product to be sold to either medical patients or adult consumers, the separation must be demonstrated at the point of sale.
Are additives required to be entered into Metrc?
Yes, product manufacturing additives, including THC and CBD potency, serving size, and ingredients, are required.
The Commission will allow for a transition period for compliance. Additional information will be provided through the issuance of a bulletin.
Is there a limit to how much product can be assigned to a Metrc tag?
Yes, no more than three liftable containers, each not heavier than 50 pounds, per Metrc tag. Once assigned a Metrc tag, these containers cannot be separated. We strongly suggest keeping all inventory in one contained location for the purpose of inventory tracking.
Additionally, multiple containers containing one package (termed 1 lot) must travel together. For example, if one container is needed in product manufacturing, then the other two must go with it.
If lots are separated, either within or outside a facility and are assigned to one tag, Licensees will be in violation of the Commission’s Seed-to-sale Tracking guidance.
Retail
This section provides guidance to retailers on how to manage inventory with Metrc.
When does the separation of Medical versus Adult Use products occur?
If during production the potency of the product exceeds the allowable limit for adult use, the product must be separated at that stage. If potency levels allow the product to be sold to either medical patients or adult consumers, the separation must be demonstrated at the point of sale.
All sales must be recorded under the appropriate license in Metrc. This ensures that medical patients remain exempt from paying sales’ tax on products, and appropriate sales data is aggregated under the applicable license.
How should display products be tracked in Metrc?
Display products should have their own separate Metrc package tag, created from the parent package.
These tags can be kept in a contained location in a secured area. Display products do not require tags to be physically displayed on the product. Once the product is wasted, this package tag will also allow transportation of this product to a processor for disposal, if the waste disposal process does not occur at the retail.
How do retailers enter their sales into Metrc?
Retailers can utilize an API, CSV file, or manual upload. Retails should contact their point of sale provider for the functionality.
How does an MTC perform a patient return or exchange in Metrc?
Any patient return cannot be resold and must be wasted.
A new package tag is created with the item category name “waste – concentrate” or “waste – flower.” Creating this category requires Commission approval. Contact the Commission in this situation.
A new waste log feature is in development for accepting and wasting returned products. Once this feature is complete, further industry guidance may be released in the form of a Metrc bulletin.
How do I perform home delivery to Registered Qualifying Patients?
Delivery to Registered Qualifying Patients may be tracked using the sales delivery feature in Metrc.
Can a Licensee sell seeds and clones?
Commission regulations allow for the sale of seeds and clones.
The FAQ for clone sales is available here: https://masscannabiscontrol.com/frequently-asked-questions/#clone-sales.
The FAQ for seeds is available here: https://masscannabiscontrol.com/frequently-asked-questions/#seed-sales.
FAQs
Can Licensees list multiple occupants on a manifest?
Yes, include the names and badge or registration card number of all registered agents transporting products on the manifest. All occupants must be entered in the space provided, separated with either a comma or slash. Licensees must include the travel route. If changing drivers in route, identify the location of the change in the planned route section.
When a Licensee is transferring product to another Licensee, what transfer type do they select on the manifest?
If the Licensees are not affiliated through licensure, then it will be an “unaffiliated transfer.”
When a Licensee does an affiliated transfer within the same facility, does there need to be a physical paper manifest?
No, if the movement is within the same physical space a paper manifest is not necessary. Any movement between separate physical locations requires a paper manifest.
Can a Licensee send whole wet plants to another Licensee to dry, cure and package into bud and trim packages and test on their behalf?
No, Cultivators cannot send wet plants to another Licensee to dry. However, Cultivators may send wet plant material that has been tested in accordance with the Commission testing protocol to another facility for extractions.
The Commission will provide additional information through the issuance of a bulletin.
How do we create sample packages?
All sample packages should have an assigned package tag; specific name denoting it is a sample or research and development (R&D) item (e.g., “R&D: UniqueName”); and proper testing status prior to transfer. Samples and R&D packages cannot be sold.
How do retailers edit their sales if their file was uploaded twice, sold from the incorrect package ID, or need to delete a sale if receipt based?
The retailer will be required to void or edit each receipt number individually upon notification of the issue and reconcile the void in Metrc and point-of-sale system within 24 hours.
Can retailers create gift box package tags?
No, retailers are not allowed to create gift box package tags.
Can a Licensee transfer or receive a product that has not been tested?
No, a Licensee may only transfer cannabis products that have test results. This requirement includes transfers between licenses.
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