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Month: June 2019

As of June 30th, brands’ cannabis products will most likely be non-compliant

Posted on by Alvaro Wong

Yes, you read that right. As of June 30, 2019 many brands’ products will be non-compliant due to the updated package regulations by California’s BCC. The California Department of Public Health has mandated that “any inhalable cannabis product” should be marked with the universal symbol. This means that hardware, like vapes and vape cartridges, will now need to be labeled with the universal symbol if they want to remain compliant and continue to be sold in retailers. Previously, only the packaging itself needed to be labeled.

This is the timeline of execution for the new product requirements:

  • •Cannabis and cannabis product packaging that was compliant under the emergency regulations but is no longer compliant under the permanent regulations can be transferred to a licensed distributor until June 30, 2019.
  • •Licensed retailers may sell these cannabis products through December 31, 2019.

If you’re a retailer, you still have a little more time to get rid of the products, but are expected to destroy the items after December 31, 2019.

 

 

Now the question is why? The BCC hasn’t justified this new regulation ultimately leaving brands in the air. The Bureau is now expecting brands and manufacturers  to re-invest significant amounts into re-labeling products that were compliant a few weeks ago. Ultimately, this hurts the players who are trying to operate correctly and props up those who don’t abide by (or have the resources to abide by) the constantly-evolving arbitrary regulations.

We at WebJoint feel your pain, this is reminiscent of last year’s switch from whole weight to pre-packaged items – it put brands and retailers in a difficult position, costing them time and money to stay compliant with regulations. So, we compiled all the assets from the BCC that outline the expectations for compliant product packaging and labeling. 

We also did some graphic design work for the universal symbol, as the BCC only provides a JPEG of the logo. *sigh*

 

 

Although, this guide is in respect to branding your cannabis delivery, we can still apply those concepts to the packaging.

Disclaimer

The materials made available in this blog are for informational purposes only and not for the purpose of providing legal advice. You should contact your cannabis attorney to obtain advice with respect to any particular issue or problem.

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METRC and Your License: When should you be reporting?

Posted on by Alvaro Wong

When should you be reporting to METRC?

The licensing structure for the California cannabis industry is complex and confusing. Mix in the tech infrastructure of METRC and you’re thrown deeper into confusion. 

If you’re a cannabis delivery service and have struggled with the ambiguity of the BCC, you’re not alone. Many cannabis deliveries are fighting to stay licensed—and operating in confusion is anything but helpful. There is a large grey area and due to a lack of information being available to non-applicants, we can only help with the resources made available to us.

METRC can be very confusing if you've never used it before.

 

 

 

 

 

NOTE: All credentialed CCTT–METRC system users have access to the “California Transition Period Guide,” which outlines how annual and provisional licensees will process and report transfers to and from temporary licensees. (CDFA x BCC FAQ)

However, we wanted to share what we do know in order to better service our delivery clients in this time of transition to compliance.

Temporary Licenses and METRC

Most cannabis deliveries are currently operating under this license type. The State stopped granting these licenses as of December 31, 2018. Many businesses are now in a state of limbo awaiting their annual license while unable to operate because the temporary license has expired.

Retailers operating under temporary licenses are not required to report data to METRC, but are expected to do so after transitioning to a provisional or annual license.

 

Provisional Licenses and METRC

The provisional license was granted to those operators who had submitted annual applications to the BCC, but due to administrative delays on the State’s end, were not able to get processed before the expiration of the temporary license.

Under the provisional license, retailers are expected to report to the state’s track-and-trace system, METRC. If you have a provisional license, it also means you have applied for the annual license, hence you are eligible to receive training on METRC.

five common compliance violations for cannabis deliveries

Annual Licenses and METRC

METRC is transitioning to full scale in California. The cutoff to apply for temporary licenses was December 31, 2018 according to the BCC Order of Adoption. Any applicants post-date will have to apply directly for this type of license. The annual license is the ultimate goal for all cannabis deliveries. If you are a new applicant, meaning you have not received a temporary license, you are required to receive the “Account Manager System Training” program for METRC. This is mandatory. The training will allow for the individual to order tags, record inventory, and train other staff members on using the compliance system. Keep in mind you need an application number to register for this training.

You will have 30 days after receiving your annual license to complete the training and source a METRC-validated software (i.e. WebJoint) to run your business on. Because staying compliant is a crucial component of your delivery’s success, we recommend having a dedicated compliance officer or inventory manager who has extensive knowledge on compliance. The application process is expensive and tedious enough—risking your license due to an administrative hiccup is the last thing you need.

How WebJoint Helps

WebJoint is a METRC-validated software.  We have made our software around all the compliance points METRC looks for. Data on driver location, inventory management, sales, etc. are relayed to METRC in real-time. Our software eliminates the need for cannabis deliveries to “double input” data into their management software and METRC. Operate your cannabis delivery efficiently and compliantly with WebJoint.

Author’s Note

Though cannabis retailers are expected to report to METRC during their provisional license period, there has been a grey are in terms of enforcement, hence the “30 day rule” mentioned above is put in place to make the annual license reception the hard cut-off point for not reporting to METRC. Please keep in mind that the BCC does have the power to audit any retailer at will. Seek legal counsel from an attorney for any further questions.

Disclaimer

The materials made available in this blog are for informational purposes only and not for the purpose of providing legal advice. You should contact your cannabis attorney to obtain advice with respect to any particular issues or problems.

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