The seed-to-sale tracking system is on the back burner until annual licenses are distributed to cannabis businesses.
Along with legalization of recreational marijuana, California’s legal seed-to-sale tracking system had its launch. However, marijuana businesses that have temporary licenses do not have the requirement to use the tracking system. The state’s Department of Food & Agriculture’s proposed medical regulations states that anyone with a license to cultivate must start using the system within 15 days of receiving their license. Legalization has taken off with a number of hiccups. And the mandatory use of the tracking system may not happen until much later in the year.
According to the California Department of Public Health’s regulations, track and trace programs will “track the movement of cannabis and cannabis products through the distribution chain established by the Department of Food and Agriculture in accordance with section 26067 of the Act.”
The California Department of Food and Agriculture (CDFA) requires all annually licensed cultivators and distributors of cannabis to use a seed-to-sale tracking program. Franwell Inc. is the contract service provider for the Metrc California Cannabis Track-and-Trace system (CCTT). All annual licensees will likely use it.
According to the CDFA’s FAQ page, user training is required during the reviewing/processing of an annual license application. It states that “the CCTT-Metrc Account Manager New Business System Training will be provided via live, interactive facilitated webinars [and] via pre-recorded webinars.”
The CDFA’s emergency regulations took effect on Tuesday and they state that:
“Each applicant shall register for track-and-trace system training…within ten (10) business days of receiving notice from the department that their application for licensure…is complete”.
However, that doesn’t necessarily mean that authorities will compel them to use the system after completing the above steps. Many rules went into effect at the turn of the new year.
The CDFA’s proposed medical regulations state that growers must implement California’s legal seed-to-sale tracking systems 15 days after receiving a cultivation license. Fortunately, it seems that growers will have more than just two weeks into January before they must use it.
California’s legal seed-to-sale tracking system has seen delays because of the fact that no one has an annual license yet. So far, the state has only granted temporary ones. Temporary licensees do not need to abide by the same regulations that a business with an annual license would.
According to the Bureau of Cannabis Control’s list of regulations, “a license operating under a temporary license issued pursuant to section 5001 is not required to record commercial cannabis activity in the track and trace system as otherwise required by this article.”
Instead, temporary licensees will employ more old-school forms of tracking of their inventory and transactions.
“Temporary licenses shall track and record all cannabis commercial activities and information required pursuant to this division and any other provision of law, at a minimum, on paper receipts, invoices, or manifests.”
It appears that the state won’t implement California’s legal seed-to-sale tracking system as soon as we thought. The state has only given out temporary licenses for cultivation and distribution so far. Temporary licensees don’t have a requirement to use seed-to-sale tracking and will not have access to the system. The state will not accept annual licenses yet but applicants can begin filling them out in the meantime.
Seed-to-sale tracking systems come with their own set of pros and cons. Large quantities of cannabis have managed to make it from licensed cannabis processor’s to the streets without being detected by a legal state’s seed-to-sale tracking system. Tracking and tracing systems provide transparency with lab testing. But things can sometimes slip through the cracks. Tracking each and every plant from seed to sale will likely slow production of legal cannabis down and decrease supplies. Not to mention, the costs of complying with security and tracking regulations will cost growers and retailers more money. This, in turn, will likely drive prices up for consumers.
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