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The Latest Information on California's Cannabis Track-and-Trace (CCTT) System

1/31/2018

 
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Whether you’re a cultivator, manufacturer, retailer or distributor, it’s important to become familiar with California’s Cannabis Track-and-Trace system. Through a platform called Metrc, California state officials can regulate and supervise the cannabis industry. Here are some of the basic things you need to know about this system.

What is the Cannabis Track-and-Trace System?
The California Cannabis Track-and-Trace system tracks all commercial cannabis and cannabis products—from cultivation to sale. CCTT is run by the the CalCannabis Cultivation Licensing division of the California Department of Food and Agriculture, which covers tracing cannabis in three different branches: Licensing, Compliance and Enforcement, and Administration.

Do I need to know about CCTT?
Yes. If you are a licensed cannabis business, you are required to use the CCTT system to record, track and maintain information about your cannabis and cannabis product inventories. CCTT is hosted on a system called Metrc, which is a cloud hosted online reporting tool you can use to maintain information about your cannabis products as they make their way from seed to sale.

Why does CCTT exist?
Cannabis Track-and-Trace is important for a few reasons:
  • Quality assurance: to detect traces of pesticides, record THC / THCA levels, and make sure cannabis products are safe for consumption.
  • Transport tracking: for oversight into the movement of cannabis and cannabis products, including the chain of custody from cultivator to customer
  • Manufacturing monitoring: for oversight into the transformation of plant material, as well as the proper recording of plant waste.
  • Supply chain oversight: to maintain insight into the location and amount of batches of products at any given time.
  • Compliance: to maintain the regulated standard of packaging, labeling, taxes, etc.
  • Accounting: to minimize the black market and track the growth of the legal market.

Basically, Metrc allows the state government to have oversight into the cannabis inventories, maintain quality control, make sure all taxes are being paid correctly, and regulate the transfer of cannabis supplies from cultivator to customer.

How do Metrc and CCTT work?
Metrc uses two types of tags to keep tabs on cannabis and cannabis products. The two tag categories are Plants and Packages.

Plants are are further categorized as either immature or flowering. Immature plants are cannabis plants that are not flowering. Flowering plants are those that have formed a mass of pistils measuring greater than one half inch wide at its widest point.  All plants must enter the system through immature plant lots (up to 100 plants/lot). With these lots, up to 100 plants are assigned a Unique Identifier Plant tag. Each immature plant gets a label with the lot UID, while individual flowering plants get a Plant tag.  

Meanwhile, Packages are created from immature plants, harvest batches, testing lab samples, production batches, and other packages. Any amount of cannabis or cannabis product that may be sold, manufactured or transferred must be placed into one or more packages. Then, each package receives an UID package tag created in Metrc. Make sure that any product that you intend to transfer from one licensee to another has an UID physically attached to the package.

What is a unique identifier (UID)?
The UID is a unique alphanumeric code or designation used to uniquely identify cannabis and cannabis products on a licensed premises. As an annual licensee, you will be responsible for assigning a CCTT-Metrc nonrepeating UID to each immature lot, flowering plant, and distinct cannabis product. Each UID then keeps track of the cannabis products as they make their way through the supply chain.

How will I get my UIDs? And do I have to pay for them?
When you’re set up in the Metrc system (more on that in a minute), you’ll be able to order your UIDs through the system. The cost of UIDs is factored into the fee for your state’s cannabis license.

How do I use my UIDs?
Let’s divide this up once more into UIDs for Plants versus Packages.
  • Plants: assigned on UID plant tag per immature plant lot (containing up to 100 plants per lot). Every plant in the lot must be labelled with the corresponding UID.
    • Flowering plants: assign a plant tag to every individual plant when moved to a canopy or when the plant flowers. These tags must be attached to the main stem a the base of each plant using a tamper evident strap or zip tie, and the tag must be clearly visible.
  • Packages: package tags are peel and stick. Use the package tag for transferring packages and for the tracking of finished product for each licensee in the chain of custody.

What do you need to do now?
To get started using Metrc, follow these steps:

  • Start by submitting your annual cultivation license application and completing the required training. You can submit your license application at the CalCannabis Licensing Site. Note that you MUST complete the training to gain access to the Metrc system.
  • When you have finished the training, obtain approval of annual license. Call or email Metrc Support to receive confirmation of annual license and training completion.
  • Next, complete your login credentials after receiving a welcome email:
    • Click on the first link in the "Welcome to Metrc" email. This will direct you to the website where you set-up your account.
    • Accept State Attestation and Metrc Terms and Conditions.
    • Setup a User Profile Introduction to California Cannabis Track. For tips on how to set up your account, read this presentation released by the CDFA.
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For more on how to get started using Metrc, follow the instructions listed in the primer released by the CDFA. If you get stuck or have any questions along the way, reach out to the experts at California Cannabis CPA to get advice.

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