How to Stay Metrc Compliant in Montana 2024

Montana’s cannabis industry continues to expand, driven by the legalization of recreational marijuana in January 2022. As the market grows, so does the complexity of maintaining compliance with state regulations. At the heart of these regulations is the Metrc (Marijuana Enforcement Tracking Reporting Compliance) system, a critical tool for ensuring the integrity and transparency of the cannabis supply chain.

According to cannabis sales reports from the Montana Department of Revenue (MDOR), medical cannabis sales have declined since January 2022. Nevertheless, the state’s cannabis industry is still growing, fueled by a significant increase in recreational cannabis sales. For dispensary owners in Montana, staying Metrc compliant is crucial for maintaining licensure and avoiding hefty fines.

Types of Licenses in Montana

Montana offers several types of licenses for cannabis businesses. Each one has specific Metrc compliance requirements:

• Cultivator License: Allows the holder to grow marijuana plants. Cultivators must track each plant from seedling to harvest using Metrc plant tags.
• Manufacturer License: Permits the production of cannabis-infused products. Manufacturers must track the transfer of cannabis from raw plant material to finished product.
• Dispensary License: Authorizes the sale of cannabis products to consumers. Dispensaries must track the receipt of products from cultivators and manufacturers and their subsequent sale to customers.
• Transporter License: Approves the transportation of cannabis products between licensed facilities. Transporters must document each movement of cannabis in the Metrc system.
• Testing Laboratory License: Permits the testing of cannabis for potency and contaminants. Labs must enter their test results into Metrc, linking them to the specific batch of cannabis tested.
• Combined-use Licenses: These are special types of licenses designed for Montana’s eight federally recognized tribes or the entities majority-owned by these tribes. These licenses include cultivation and dispensary operations at the same location.

Components of Metrc Compliance

• Plant Tags and Packages

Metrc requires the use of plant tags and package tags to track marijuana throughout its life cycle meticulously. Plant tags affixed to each cannabis plant contain unique identifiers entered into the Metrc system. Package tags track cannabis products post-harvest and processing. Each tag must be scanned and recorded at various stages, ensuring comprehensive traceability.

• The Costs Associated with Metrc Tags and Packages

Plant tags are priced at $0.45 each, and package tags cost $0.25 each. Additionally, all Montana licensees must pay a $40 monthly support fee, which covers Metrc support and training services.

• Seed-to-Sale Tracking

Seed-to-sale tracking, the cornerstone of Metrc compliance, requires every stage of the cannabis life cycle—from seed planting to final sale—to be recorded scrupulously in the system. This includes:

1. Propagation: Documenting the germination of seeds and cloning of plants.
2. Cultivation: Tracking plant growth, including watering, nutrient application, and pest control.
3. Harvesting: Recording the collection of cannabis flowers and leaves.
4. Processing: Tracking the conversion of raw plant material into consumer products.
5. Testing: Documenting mandatory potency and contaminant tests.
6. Distribution: Recording the transportation and delivery of products to dispensaries.
7. Retail: Documenting the sale of products to consumers.

RFID technology is integral to Metrc compliance. Each plant and package tag contains an RFID chip that facilitates easy scanning and tracking. This technology ensures the accurate recording of every cannabis movement, minimizing the risk of human error. IndicaOnline’s RFID tracking system provides a non-invasive way to monitor cannabis plants.

Advanced Compliance Practices

• Adopting Third-party Integrations

Many dispensaries utilize third-party software to enhance their Metrc compliance efforts. These integrations can automate various aspects of compliance, from data entry to reporting and inventory management. However, ensuring the Montana Department of Revenue validates any third-party software used is crucial. Using unvalidated software can result in non-compliance and potential penalties. IndicaOnline’s POS system integrates seamlessly with Missouri’s Metrc tagging system, ensuring accurate tracking and reporting. 

• Comprehensive Record-keeping

Maintaining comprehensive and accurate records is a fundamental aspect of Metrc compliance, and dispensaries must document every stage of the cannabis life cycle, from propagation to retail sales. This includes detailed records of plant growth, harvesting, processing, testing, distribution, and final sale. Ensuring all records are up-to-date and accurate is essential for compliance and provides a clear audit trail for regulatory inspections. IndicaOnline’s reporting system generates and exports reports to ensure compliance with state requirements.

• Regular Internal Audits

Regular internal audits can help dispensaries identify and address compliance issues before they become significant problems. Internal audits should review all aspects of Metrc compliance, including inventory management, data entry, RFID scanning, and reporting. Dispensaries can maintain compliance and avoid penalties during official audits by proactively identifying discrepancies and implementing corrective actions.

• Employee Training and Education

Ensuring all employees are thoroughly trained in Metrc procedures is vital for maintaining compliance. This includes understanding how to use plant and package tags, RFID scanning equipment, and entering data into the Metrc system. Regular training sessions and updates on Metrc protocols help maintain compliance and reduce the risk of errors. Investing in employee education ensures all staff members are knowledgeable about compliance requirements and best practices.

Specialized Compliance Areas

• Managing Waste Disposal

Proper waste disposal is a critical aspect of Metrc compliance that is often overlooked: Dispensaries must track and document the disposal of cannabis waste, ensuring it is handled according to state regulations. This includes recording the weight and type of waste, as well as the method of disposal. Proper documentation ensures all cannabis waste is accounted for and disposed of safely, preventing potential compliance issues.

• Handling Product Recalls

In the event of a product recall, having a robust Metrc compliance system in place is essential, as dispensaries must be able to identify and remove affected products from the market quickly. This includes notifying customers, tracking returned products, and documenting the recall process in Metrc. A well-integrated POS system can simplify this process by providing real-time data and reporting capabilities, ensuring all recalled products are managed effectively.

• Compliance with Packaging and Labeling Requirements

Packaging and labeling are crucial components of Metrc compliance. Dispensaries must ensure all cannabis products are packaged and labeled according to state regulations, including accurate product information, warning labels, and RFID tags. Proper packaging and labeling not only ensure compliance but also enhance consumer safety and trust. Detailed documentation of packaging and labeling processes should be maintained in Metrc to provide a clear audit trail.

Consequences of Non-compliance

Failure to comply with Metrc regulations can result in severe consequences, including fines, suspension of licenses, and criminal charges. Non-compliance can also damage a dispensary’s reputation and lead to loss of business. By adhering to Metrc requirements, dispensary owners not only protect their operations but also contribute to the overall integrity and success of Montana’s cannabis industry.

Adapting to Changing Regulations

As the industry develops, staying informed and prepared is key. The future of Montana’s cannabis industry looks promising, with continued growth in recreational cannabis sales and evolving regulatory requirements. Staying compliant with Metrc is not just a legal obligation but a crucial part of maintaining the integrity and trustworthiness of the industry. As regulations become more sophisticated, integrating advanced technologies like IndicaOnline’s POS system will be essential for dispensaries to keep pace.

Official sources such as the Montana Department of Revenue provide comprehensive guidelines and updates on compliance requirements. By applying these resources and partnering with technology providers like IndicaOnline, dispensaries can manage the complexities of Metrc compliance with confidence.