METRC Compliance Requirements 5 — Questions and Answers
Question 1: A METRC API integration used by a third-party point-of-sale system begins returning errors during a sale. What is the licensee's compliance obligation?
- Sales may continue without limit as long as paper records are kept
- The licensee must halt sales and fix the integration before processing further transactions
- The licensee should report the API error to the POS vendor and continue sales normally
- The licensee may continue sales but must enter all transactions into METRC manually within 24 hours (Correct answer)
Correct answer: The licensee may continue sales but must enter all transactions into METRC manually within 24 hours
When automated integrations fail, licensees are responsible for manually entering all transactions into METRC within the required timeframe to maintain compliance.
Question 2: Under METRC rules, which entity is responsible for ensuring that a cannabis transfer manifest is accurate before the transport vehicle departs?
- The state cannabis regulator
- The transporting driver
- The originating (sending) licensee (Correct answer)
- The receiving (destination) licensee
Correct answer: The originating (sending) licensee
The sending licensee is responsible for creating an accurate manifest in METRC before the transfer departs their facility.
Question 3: A cannabis testing laboratory receives a sample with a METRC tag but the physical weight does not match the manifest. What is the lab's required action?
- Test the sample using the manifest weight and note the discrepancy internally
- Reject the transfer in METRC, document the discrepancy, and notify the sending licensee and regulator (Correct answer)
- Accept the transfer and adjust the weight in METRC to match the physical sample
- Destroy the sample immediately due to chain-of-custody break
Correct answer: Reject the transfer in METRC, document the discrepancy, and notify the sending licensee and regulator
A weight discrepancy at receipt is a compliance red flag; the lab must reject the transfer and document the issue for regulatory review.
Question 4: In METRC, 'immature plants' are tracked differently from 'mature plants' primarily because:
- Immature plants have no commercial value and do not need individual tags
- Immature plants are tracked as batches rather than individually tagged plants (Correct answer)
- State law exempts immature plants from all traceability requirements
- Immature plants can only be tracked using paper manifests
Correct answer: Immature plants are tracked as batches rather than individually tagged plants
Immature plants (clones and seedlings) are grouped into plant batches with a single batch tag, while mature flowering plants receive individual plant tags.
Question 5: Which of the following best describes why METRC uses unique identifiers (UIDs) on both plants and packages?
- To allow consumers to look up the history of products they purchase at dispensaries
- To enable regulators to track every unit of cannabis from seed to sale without breaks in custody (Correct answer)
- To help wholesalers price cannabis based on origin and quality scores
- To prevent licensed growers from selling to out-of-state markets
Correct answer: To enable regulators to track every unit of cannabis from seed to sale without breaks in custody
Unique identifiers support complete seed-to-sale traceability, allowing regulators to audit any unit of cannabis at any point in the supply chain.
Question 6: A cultivator harvests plants from two different strains on the same day. Under METRC compliance rules, these harvests should be:
- Combined into a single harvest batch to simplify reporting
- Recorded as separate harvest batches to maintain strain-level traceability (Correct answer)
- Recorded in a paper log and entered into METRC at month-end
- Tagged under one batch if total weight is under 5 pounds
Correct answer: Recorded as separate harvest batches to maintain strain-level traceability
Different strains must be recorded as separate harvest batches to preserve product identity and support accurate lab testing and labeling.
Question 7: A METRC compliance officer notices that a licensee's account shows zero plant or package activity for 60 consecutive days despite an active license. This situation most likely warrants:
- No action, as licensees are permitted to pause operations without notification
- A regulatory inquiry or inspection to verify the licensee's operational status and inventory (Correct answer)
- Automatic suspension of the METRC account by the software
- A fine equal to 60 days of license fees
Correct answer: A regulatory inquiry or inspection to verify the licensee's operational status and inventory
Extended inactivity in an active METRC account can indicate unreported operations, diversion, or a dormant license that should be surrendered.
METRC Compliance Requirements 5
A METRC API integration used by a third-party point-of-sale system begins returning errors during a sale.
What is the licensee's compliance obligation?