In this month’s newsletter, learn more about the following:
- Transporter license requirements
- Reminder regarding custom labels
- Cannabis testing
- Fraudulent activities against marijuana businesses
- Reminder regarding license renewal timing
Transporter license requirements
A Transporter License is only required if you plan to transport marijuana or marijuana products belonging to another licensee.
A Transporter License is not required if you are transporting your own marijuana and marijuana products. For a product to be considered “yours” for purposes of transporting, it must be entered into your Metrc inventory prior to transport.
Reminder regarding custom labels
Dispensary licensees are required to submit custom (i.e. contains graphics and/or logos) packaging applications (and possibly custom labeling applications) for any new marijuana or marijuana products that they are selling.
Additionally, dispensary licensees that have had their custom label/package denied and have not resubmitted their revisions must do so before they can sell those products.
Reminder: marijuana product testing must be done when the product is it its final form and in its final packaging.
ARM 37.107.316(2) states that “All marijuana items intended for direct sale or transfer to customers shall be tested in its final form. The addition of any ingredient after final quality assurance compliance testing will require retesting.”
The Department of Public Health and Human Services Quality Assurance Sampling Protocol for Usable Marijuana, Marijuana Concentrates and Extracts, and Marijuana Infused Products, which is incorporated by reference in ARM 37.107.310, states that “the process lot shall be in its final packaging at the time of testing.”
Pursuant to these provisions, testing must be done when the product is in its final form and in its final packaging
Fraudulent activities against marijuana businesses
There are reports of increased fraudulent activity reported from licensed marijuana businesses across the nation:
- Marijuana licensees are being contacted by an individual or entity that desires to place a sizeable order of marijuana and/or marijuana products on behalf of another licensee.
- The interested party is knowledgeable about how to place an order for marijuana/ marijuana products, and therefore appears to be credible.
- When the licensed marijuana transporter arrives, the delivery address is not a valid marijuana licensee’s premises.
Marijuana licensees are encouraged to have their employees confirm the validity of the potential purchase(s) and the associated delivery address with their manager(s) and/or owner(s), prior to delivery.
Reminder regarding license renewal timing
Please remember to submit your renewal application at least sixty days before the expiration of your license to avoid any interruption to your business operations.
Licensing information requirements can be found here.