The Cannabis Regulatory Agency of Michigan (CRA) has best practices available to help you remain in compliance according to Michigan State Law. Always follow the Michigan bulletins which can be found here, Bulletins (michigan.gov) to ensure you remain in compliance.
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Destruction
As stated by the CRA:
When destroying product, documentation of the destruction, including full Metrc tag number, reason for destruction, and method of destruction, is required to be logged on the waste/destruction log. Licensees should keep photos or video of the marijuana product in its destroyed state, and photos or video of all Metrc tag numbers that correlate with the product being destroyed.
Once product has been destroyed, the package(s) should be adjusted down to 0 and finished in the Statewide Monitoring System (Metrc). When making the adjustments, please use “waste” as the reason code and include a note that indicates the reason for destruction and the date it was completed.
Evidence of destruction must be made available to the CRA upon request, but you are not required to send destruction information unless it is requested.
Video and Photo Evidence of Destruction
When collecting video evidence to demonstrate destruction of product, it is essential that the CRA can clearly view and observe the actions taken by the licensee. To accomplish this, there are several things to keep in mind.
Ensure that the destruction is taking place where there is a clear camera view. The
frame should be free of obstructions, and all staff completing the destruction should be
behind the product as not to obstruct the view of the product.The product should be shown in its storage container before any product is removed.
The Metrc tag number should be visible and if possible, held up to the camera.
The weight or count should be shown prior to destruction, either by weighing the product
or by placing the individual items in groups (i.e., 10, 20, etc.) to clearly demonstrate the
number of products on hand that are being destroyed.
Transfers
As stated by the CRA:
All products transferred between marijuana businesses must be traceable in Metrc in compliance with the administrative rules. Product traceability is reliant on correct product labeling.
Package tag - an RFID tag supplied from Metrc for the purpose of identifying a package containing a marijuana product. The industry has coined the term “transfer tag.” In this document, we will use package/transfer tag. Package/transfer tags may only be used once and for the product they were originally created to hold.
Source package tag - the first tag created for a marijuana product, example: the package containing the harvest batch. This number is not required to be on the package.
Example:
Every item (brownie, cookie, vape, wax) created in Figure 1 below requires a new package/transfer tag, which will carry the source package in its history, ensuring accurate product tracking throughout the supply chain
Labeling Requirement Variations
Requirements for transfer tags, as stated by the CRA:
CULTIVATOR-TO-CULTIVATOR
Business or trade name
License number
Package/transfer tag assigned by METRC
Name of the strain
Date of harvest
Seed strain
Universal symbol
PRODUCER-TO-PRODUCER
Business or trade name
License number
Package/transfer tag assigned by METRC
Universal symbol
CULTIVATOR/PRODUCER-to-SALES LOCATION
Business or trade name
License number
Package/transfer tag assigned by METRC
Business or trade name & Marijuana license number of packager of the product (if different from the product of the product)
Date of harvest (if applicable)
Name of strain (if applicable)
Net weight (US or Metric)
THC and CBD concentrations (within 10% accuracy from licensed potency-testing lab)
Activation Time of the product (in writing or with a picture)
Name of the licensed compliance lab that tested the finished product
Universal symbol for marijuana products published by the CRA
A warning that includes all the following statements:
(i) "It is illegal to drive a motor vehicle while under the influence of marihuana."
(ii) “National Poison Control Center 1-800-222-1222.”
(iii) For products being sold by a marihuana facility that exceed the maximum THC
levels allowed for products sold under MRTMA, “For use by registered qualifying
patients only. Keep out of reach of children.”
(iv) For all other products, “For use by individuals 21 years of age or older or registered
qualifying patients only. Keep out of reach of children.”
(v) In clearly legible type and surrounded by a continuous heavy line: “WARNING: USE
BY PREGNANT OR BREASTFEEDING WOMEN, OR BY WOMEN PLANNING TO
BECOME PREGNANT, MAY RESULT IN FETAL INJURY, PRETERM BIRTH, LOW
BIRTH WEIGHT, OR DEVELOPMENTAL PROBLEMS FOR THE CHILD.”
Changing Product Categories using Production Batches
As stated by the CRA:
A production batch is the compliant way of creating new products that change categories. For example, you cannot create a package of vape carts directly from shake/trim; you must first create a new production batch of oil and then pull from the production batch of oil to make the vape carts.
To create an intermediate product – like a production batch of concentrate – you will pull from a package or packages of raw product to create the new package for the new concentrate. It is imperative that the weights used in the packages are accurate and the CRA can transparently see what and how much you are using. You may then pull product out of that production batch to create additional production batches (e.g., infused edible products). Each new production batch will have a new package tag and be marked as a production batch. If these production batches are final products; packages will be created from them for transfer to the sales locations and distribution to patients or consumers.
Samples
A large area of concern for the CRA comes from the concept of product samples. Obviously, samples are a great way to attract and retain customers (both individuals and licensed cannabis businesses who want to sell your products). Compliant samples avoid some of the more stringent requirements described above for regular cannabis product transfers. The CRA monitors when, where, how, and to whom samples are provided to offer this relaxed treatment.
METRC Transfer Codes and When to Use Them
Adult-Use Affiliated Transfer
For transfers between adult-use licenses with same ownership
Adult-Use Seeds and Seedlings
For adult-use cultivators to bring in seeds or seedlings from individuals aged 21 or older
Caregiver
For medical cultivators to bring in seeds, seedlings, tissue cultures, or cuttings from a registered
caregiver
Educational Research License Transfer
For transfers to an Educational Research License
External Cannabinoids
For acquiring hemp-sourced cannabinoids from businesses that do not hold a marijuana license
Shipping Errors
As stated by the CRA:
All errors made during shipping and receiving must be corrected. Physical and electronic inventory must match exactly to be compliant.
Examples of common errors include receiving more or less than what is stated on the manifest
or receiving product not on a manifest.
It is never acceptable to correct the errors by adjusting the packages.
All errors should be reported to Metrc support for assistance with correcting them compliantly.
The CRA will not approve virtual manifests directly to licensees. If the only correction for the
error is a virtual manifest, Metrc support will reach out to the CRA for approval.
Facility Inventory Errors
As stated by the CRA:
All inventory errors must be corrected. Physical and electronic inventory must match exactly to be compliant.
Examples of common errors include not creating products as production batches, adjusting
down packages instead of creating a new package, packaging errors during the harvest
process.
All errors should be reported to Metrc support for assistance with correcting them compliantly
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