It’s almost 420, are you compliant?
As cannabis businesses across the country prepare for one of the busiest days of the year, ITCC would like to remind all ITCC regulated facilities to keep compliance in mind when coordinating advertisements, events, sales promotions and other 420 related activities.
Areas of potential concern that licensees and operators should be aware of during this year’s 4-20 weekend:
Fake IDs - seem to be popular around the busiest shopping days for cannabis retailers because people assume employees are less likely to spot a fake id if they are really busy with customers;
Fake cash - also popular on busy days for cannabis retailers due to a lower probability that a busy employee will spot a fake bill;
Fake patient cards - I know, it sounds odd when you hear it at first. Fake out of state patient cards are being used to avoid paying the excise tax in some situations. ITCC’s “Nonresident Reciprocity Form” can be found on the new home page in the “I am looking for…” section (see image below) or the Industry Documents page of our new website.
Quarterly Reports
I. Each marijuana establishment shall:
(c) Provide for quarterly physical inventory counts which are reconciled to the perpetual inventory records. Significant variances must be documented, investigated by management personnel and immediately reported to the Department.
These inventory reports are due no later than 5 business days following the last day of the quarter.
An “Inventory Adjustments” report and an “Inventory snapshot/raw data” report should be generated from the POS and/or seed-to-sale tracking system, depending on facility type, and included as attachments with your form submission.
ITCC.AGENCY Website
On April 22, 2024, the ITCC will change over to our new website and compliance platform. This new platform brings improvements in:
page loading speeds,
responsive display settings,
form submission performance
And presents them in a user friendly format designed to get you directly to what you need to succeed.
The website is still under construction but ITCC has made it “live” so you can start exploring and bookmarking forms you commonly use at your facility. Your feedback is crucial as you are the ultimate user of the platform. We’d love to hear what you like, what you don’t like, and any suggestions you have for improving the website. A Feedback Form has been provided.
metrc Tribal Nations
ITCC regulated facilities are currently in the process of transitioning to the metrc Tribal Nations seed-to-sale tracking software platform. ITCC participates in bi-weekly meetings with a team from metrc to discuss instabilities and barriers to full implementation at all facilities.
Currently there are facilities using the Dutchie POS software platform who are experiencing difficulties connecting to the metrc Tribal Nations platform. ITCC is aware of these issues and is communicating with Dutchie and metrc to address the problems. The projected date that the two systems will be able to connect via API is the first week of May.
Once both platforms have been tested and confirmed to be working together, ITCC will host a series of training webinars with teams from metrc and Dutchie to assist facilities in resolving any remaining issues they might encounter.
Tribal Cannabis Compliance Regulations
Also known as “TCCR”
Tribes that have adopted the TCCR can access the regulations at the new ITCC website.
The TCCR are separated into comprehensive and cohesive sections designed to highlight the area of the industry they specifically address. (see example below)
The section on cultivation (TCCR 8) seems rather small at first glance. This does NOT mean that portion of the industry is not discussed elsewhere within the code. There is overlap. Using cultivation as an example, opening the TCCR pdf and using “control+F” or the Find function to search the word “cultivation” will display the following results:
The word “cultivation” is used 166 times within the complete TCCR and those working at a cultivation facility need to know every reference. The same can be said for dispensary, known within the regulations as a “cannabis sales facility” which appears 200 times-
Tribes that haven’t adopted the TCCR are to continue using the existing regulations you have on record. If you are unsure, contact your local tribal administrative office for more guidance.
Each facility type is responsible for knowing the regulations that apply to their operations. If you have questions regarding the TCCR as they apply to your facility type, send them using the ITCC contact form and selecting “Request Information” from the Reason For Contact dropdown menu.
Changes to the industry based on the TCCR
MEA ID cards are changing! The fee for an ITCC issued MEA ID card is changing to $75 per application. This is an increase in cost, however, you’ll find the following in TCCR 5.120 (11) “A cannabis establishment agent registration card will expire 2 years after the date of issuance.” This places the annual cost at $37.50 which is comparable to most program’s current costs.
Those renewing for their 2nd year can renew with or without changes as shown below-
Sales & Possession Limit Changes-Personal possession and sales limits have effectively doubled based on the state of Nevada’s SB277. Amending language was sent to each member tribe to adjust the TCCR language and reflect these changes. If you are unclear if your facility is controlled by the TCCR, please contact your local tribal administration office and ask which regulations are currently in place. Do not assume your facility can sell 2.5 ounces, know you can.
**Seeds, Clones, Genetic Material-As ITCC member tribes adopt the TCCR, some have amended their cannabis code definitions to change, (or remove) language regarding seeds, immature plants, and genetic material. TCCR 6.080 to add the following language (or similar): “4. Medical and Retail Cannabis Cultivation Facilities may send and accept seeds, Immature Plants, and cannabis Genetic Material from the following sources:
A licensed cannabis cultivation facility in another U.S. state or territory,
A licensed cannabis Testing Facility in another U.S. state or territory,
An individual with a permit, registration, or license to work in the regulated cannabis industry in another U.S. state or territory.
An individual with a permit, registration, or license to work in the hemp industry in another U.S. state or territory.”
Tribes that have adopted 6.080.4 amendments can now send and receive “seeds, immature plants, and cannabis genetic material from a variety of sources. Check with your local tribal administration office to see if this applies to your facility.
SEEDS are tracked in the seed-to-sale tracking system.
ITCC will send a specific bulletin to address this issue during the first half of April, shortly after the facilities will receive a support bulletin from metrc.
>This concludes the April 2024 ITCC Industry Bulletin
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