The Bureau of Cannabis Control announced recently that their first batch of annual commercial licenses have been doled out. You can click the above link to the BCC’s news announcement to see who the lucky 12 licenses were, but we’re here to fry bigger fish. Namely, we’re here to fry the “What Does This Mean For My Business” fish and for that, we’ve wrangled our compliance angler par excellence, Dr. Juli Crockett to chime in on what this news means for the cannabis industry in California.

Track and Trace/Metrc Is Ready

You may recall a few weeks back when your favorite cannabis compliance blog reported on Metrc receiving a round of investment from Tiger Global and Casa Verde Capital. At the time we mentioned that Metrc was planning to bolster its staff and operations, but we didn’t know that some of the bolstering was potentially for California.

Here’s Juli’s take, “Rumors have swirled endlessly since early this year about either the regulatory agencies or CCTT/METRC not being ready for prime time, and that was the holdup for annual licenses. With the issuance of annual licenses beginning, rumors are hereby dispelled and the countdown to CCTT on-boarding has begun!”

The Countdown

Get Europe on the phone, because this is the (not-so final) countdown. Dr. Juli again: “Once a licensee has received their annual license, they have five days for their designated track and trace system account manager to complete the required track and trace training. No later than 30 days after this training, all inventory must be entered into the T+T system. After the 30-day on-boarding period, no other cannabis goods can be brought into the system unless they are starting from seed, or coming to the licensee from another licensee that on-boarded those cannabis goods in the system during their 30-day on-boarding.”

Now, we know what you’re thinking: “More bureaucratic red tape? After they took away our CBD lattes??” And yes, we are all sad about Jerry Brown snapping his fingers a la Thanos and making our CBD lattes disappear, but track and trace, painful as on-boarding has the potential to be, is very good news in the long run. Take it away, Dr. Juli:  “We are transitioning into a truly ‘seed to sale’ visible product pipeline wherein the total history of every cannabis product will soon be recorded in track and trace. The bad news: While this will (hopefully) streamline many aspects of supply chain communications and record keeping, for most operators the crossover isn’t going to be easy, or graceful.”

It’s Complicated, But We’re Getting Close To The Finish Line

With the issuing of annual licenses, the coming of provisional licenses, and some temporary licenses still active into early 2019, the beginning of CCTT will be a mixture of paper manifests/record keeping AND METRC happening simultaneously, at various stages of the supply chain. An annually licensed cultivator on METRC creates a CCTT manifest for a temp. licensed manufacturer, who receives it in paper form and then produces products that are manifested on paper to an annually licensed distributor on CCTT who has to enter the paper manifest into Track and Trace, and then goes on to distribute the products to retailers both annual and temp.

The bottom line is this, it’s a good time to schedule a record-keeping audit and make sure that internal systems are on point for dealing with all the various scenarios coming down the pike. MMLG, by the way, does offer record-keeping audit services.