We sound like a broken record at times, we know. “The costs of non-compliance keep going up.” “Know and trust every party in your supply chain.” “Inventory reconciliation is really important!” “Not knowing Metrc isn’t an excuse for incorrect track-and-trace data.” (Quick aside: here’s a quick walk-thru on Metrc and California.)
But, at the risk of sounding severely redundant, the costs of non-compliance do keep going up. And, speaking of compliance, there’s a big Metrc update later this fall (11/3/2020) for distributors. However the deadline to contact Metrc on any cannabis products lacking required testing results within the system is by COB on September 15th 2020.
While this significant update is for distributors primarily; the lead up to any significant Metrc update is a great time to get your track-and-trace (and other compliance matters) in order. We’ll get back to why it’s so convenient in a sec, but first let’s review what this big update is covering.
Metrc Lab Testing States Update
Metrc’s September update focuses on all licensees within CCTT-Metrc regarding the package Lab Testing States that each license type can receive. This update primarily impacts distributors who may need to take action, however, licensees across the supply chain, and especially retailers, need to be aware of these changes and what the implications are from an operational and compliance standpoint.
- Why are some test results not yet in Metrc? Remember in the long-ago, before the Great Distancing? Remember your temporary licenses? Products that were tested pre-Metrc onboarding, while under temporary licensing, or that were brought in with beginning inventories, are designated “Not Submitted” in Metrc. Heretofore it’s been totally cool, but also mildly alarming to licensees who have submitted products in Metrc to see that designation. After the November update, “Not Submitted” will not be so cool, as Metrc will no longer be accepting packages to be manifested to retail under that designation.
- Moving forward, all required testing results will be in Metrc. No longer will hard copy-only COA’s be a “thing” and, it is important to remember that test results older than 12 months old are no longer valid and those cannabis products must be retested.
- What’s to be done? Directly this impacts distributors who need to be aware of the testing status (in Metrc) of all of their inventory, check their testing expiration dates, and contact the BCC if applicable by the September 15th deadline. Also, it impacts everyone else in a distributor’s supply chain. Not only because of the obvious things like, say, working with a distributor who is on top of their inventory and implementing best practices such as FIFO, but also because every licensee should be doing 30-day inventory reconciliations and keeping an eye on solving the mystery of the missing testing results.
Now’s the time for Metrc/compliance audits in California
Today is July 27th. That gives all operators in California six full weeks to take stock of their inventory status, and for distributors to submit required info. Reconciling your track-and-trace, no matter what step of the supply chain you’re in is always crucial, and today is arguably the best time to make sure your inventory is on point.
Compliance is end-to-end and from seed to sale, and progressively, as the loopholes are closed, that is being accurately represented in Metrc.
If you have any concerns or questions about your company’s track-and-trace, we’re here to help. Here are some of the compliance services we offer:
- Mandatory inventory reconciliations
- Track and Trace regulatory timelines
- Discrepancies and system downtime notifications
- Metrc functionality training
- Audits on your business’s implementation of Metrc and track-and-trace (many operators are using Metrc incorrectly)
- Required Track and Trace documentation
- Operational checklists for Track and Trace compliance