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.
As the Commission continues to implement regulatory changes that were promulgated in January 2021, information contained on these webpages may require updates and/or verification by applicants and licensees in order to maintain compliance. Thank you for your understanding.
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.
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.
Can I transfer seeds or clones to another license?
Yes, seeds and clones that are under eight inches can be transferred to a different license. Once a plant is tagged in Metrc, it must remain under that license.
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 seeds are harvested, they must be tracked. Each harvested seed packet cannot contain more than 50 seeds.
Immature seeds : Strain-specific immature seeds will be counted and entered into Metrc unless they are in the process of being planted. Retail licenses can store seed packages as count-based for internal use.
Transferring seeds : When transferring to a retailer, the seeds are physically put 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.
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.
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.
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. At this time, the sales delivery feature is currently activated for Medical Use Licensees only.
Can a Licensee sell seeds and clones?
Commission regulations allow for the ability to sell seeds and clones; however, guidance on testing, packaging, and clone limits are to be developed.
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.
Additional information will be provided 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.
Seed to Sale Tracking: Why it’s Crucial
One of the great benefits of legal, regulated cannabis sales is that consumers are buying tested, quality products and trust what they’re putting into their bodies. This is essential for increasing the number of cannabis consumers which is good for all cultivators, manufacturers, dispensary owners, and everyone else connected to the modern cannabis marketplace. Seed to sale tracking means exactly what it says; cannabis plants are tracked from seeds through planting, harvesting/curing, manufacturing, testing, and packaging before they’re sold in a licensed cannabis dispensary.
So why should you care about seed to sale tracking? For consumers, their health, wellness, and confidence depend on it. For cannabis professionals, cloud-based seed to sale tracking provides much-needed compliance tools and optimal data for improved cultivation techniques and profits. For cannabis regulators, tracking allows for monitoring every cannabis product at each stage of the supply chain through the final sale. To sum it up, everybody wins.
The Legal Cannabis Marketplace Needs Seed to Sale Software
To date, 33 states, Washington, D.C., and several U.S territories permit medical cannabis, and 11 allow for adult-use sales with more likely on the way in 2020. While laws and regulations vary from state to state, nearly all require compliance with seed to sale tracking and testing regulations. This is why cloud-based, seed to sale tracking software for cultivators is a fundamental part of the new cannabis marketplace.
Without it, compliance is next to impossible. With BLAZE Grow, not only is compliance possible, our platform makes it practically easy.
How Does Seed to Sale Tracking Work?
You might be wondering how a company can track a seed or young plant (typically a clone from a mother plant). The answer is simple; labels or tags with identifying barcodes or QR codes are placed on the containers containing the seeds. Most commercial growers rely on clones, not seeds when planting their crops. As the plant matures, a tag may be hung on the plant itself and some states mandate this step. For indoor grows, many states require tracking the plant even when moved from room to room during the growth cycle. Mobile scanning/reading devices are commonly used by employees in the field or indoor cultivation or manufacturing facilities. For its clients, BLAZE offers the rugged and dependable Durascan portable device for scanning barcodes. The label or tag with the barcode or QR code then follows the plant through the entire supply chain. If the harvested plant is processed into vape oil, a tincture, an edible, a topical, or other cannabis product, the code stays with it to ensure the tracking chain remains unbroken.
Manage Cultivation and Sales
It’s the Law in Most States
Government regulators require tracking software to eradicate illicit cannabis sales and “grey market,” off the book sales. While regulations are certainly an unwelcome challenge for a business model that was previously based on secrecy and independence, they are necessary to integrate the cannabis marketplace into mainstream business communities. Virtually every commercial product sold in the U.S must deal with regulatory issues and cannabis is no exception. Without a doubt, changes need to evolve over time as regulators and business professionals alike find their way in the new cannabis landscape. Tracking software helps cannabis cultivators stay compliant with state law, and may help keep federal agencies at bay from enforcement actions. The data may also play a role in the eventual de-scheduling of cannabis at the federal level.
Dispensaries Will Love You
Tracking data is of immense value to dispensaries. Up to date inventory management, customer trends, and marketing strategies are critical to managing a dispensary. Savvy owners will want to make use of any data that helps them improve sales and educate customers. In many ways, cannabis data management is BLAZING new paths for supply chain management in other industries, and we’re proud to be at the forefront of that effort.
Does Seed to Sale Tracking Protect Consumers?
Illicit cannabis producers and sellers do not care or abide by tracking or testing regulations. While consumers may save money buying underground cannabis, the recent vape crisis is a perfect example of the potential health risks. According to the U.S. Centers for Disease Control, the untested, underground, and illegal counterfeit vape products contained Vitamin E acetate which severely damages the lungs when heated and inhaled. Legal vape sales plummeted and hopefully will recover in 2020. People died, and the untracked, illegal products gave the entire cannabis community a black eye. Unfortunately, the incidents also provided ammunition for prohibition supporters. The seed to sale tracking ecosphere greatly reduces the risk of contaminated products from ever reaching the consumer. This is just one more reason why you should care about seed to sale tracking ⎼ your livelihood may very well depend on it.
We’re here to help you compete in the new world of regulated cannabis cultivation and sales. At BLAZE we want each and every customer to succeed. How can we help? Let’s talk about it. Contact us online or call us at (415) 964-5689.