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.
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.
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.
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.
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.
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.
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.
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.