If you're a California cannabis business operator, Metrc needs to be top of mind. So as you wait for your provisional/annual license to be awarded, you might be wondering "what does going live on Metrc mean for me?"
While there are plenty of strict regulatory hurdles that lie outside of your control, there are a few key factors within your control that can greatly impact how successful you'll be in a track-and-trace world.
Let's break down how you can make the most out of the timelines and options the Bureau of Cannabis Control (BCC) and Metrc are providing you with.
There's No Need to Rush on to Metrc: Your Temporary License is Still Valid
As soon as a provisional/annual license has been granted, the BCC will email the business owner (or whoever is attached to the license application as the primary contact), requesting that payment be submitted within a timely fashion. While not explicitly stated, the expectation has been set that once approved, you'll have 30-days to pay for your annual license fees. However, this 30-day timeline is a suggestion and not a hard and fast rule.
In reality, operators arguably have until the date their temporary license expires to pay for their provisional/annual license - barring one extremely important detail. If a licensing agency provides you with a specific date (e.g. August 11th, 2019) that any action needs to be completed by, then you MUST meet that deadline - no exceptions!
But let's get one thing crystal clear...
While your temporary license will remain active until its stated expiration date, this does not mean is that operators should wait until their license is days or even weeks away from expiration to set the payment wheels in motion. What it does mean, is that many operators may have more runway than they originally anticipated to gather the funds required and prepare their businesses for the operational demands of Metrc.
Why You Should Take Advantage of the Time You Have
This added runway is important because the BCC is issuing licenses throughout the supply chain at random. That means if you're a provisional/annually licensed retailer, the chances are high that many distributors you work with will still be operating on a temporary license. When this intersection of annually/provisionally licensed retailer-to-temporary licensed distributor occurs, there's a lot more manual action on the retailer's behalf to get new inventory onto their shelves - a Metrc-required process known as creating "Incoming External Transfers."
This requires the retailer to go through the time-consuming process of:
- Manually creating Metrc strains and items
- Building the wholesale manifest (normally supplied by an provisionally/annually licensed distributor)
- Assigning their limited number of package tags to each product on the shipment
- "Transferring" it to themselves, and
- Receiving the transfer in Metrc
All before they're able to import the manifest details into their POS system, add it to their inventory, and begin selling to customers.
Manageable? Yes. Easy? Definitely not.
Instead, when a provisionally/annually licensed retailer receives inventory from another annually/provisionally licensed distributor, the entire process is streamlined. This allows retailers to simply:
- Verify the manifest details
- Digitally "receive" (i.e. accept) the shipment, and
- Pull the inventory and package details automatically into their POS platform.
Some advanced point of sale systems, like Treez, simplify these processes even further by supporting a robust two-way integration with Metrc - reducing the need to work directly in Metrc by enabling the same actions in their native system.
Aside from having to support a more tedious process to receive inventory, going live on Metrc carries with it some additional compliance baggage: establishing a green waste protocol, performing and submitting full inventory counts and reconciliations no less than every 30 days, uploading all transaction data in near real-time, and a whole slew of other requirements that if not adhered to, could jeopardize your license.
Of course, you'll have to uphold all of the requirements put in place by Metrc and the BCC at some point, but if your temporary license is still valid for another few months, there's no reason retailers should feel the need to rush on to Metrc.
In an ideal world, the State would have started at the top of the supply chain by issuing licenses to all cultivators before slowly working their way down to manufacturers, distributors, and lastly, retailers. But seeing as that didn't happen, waiting a little while longer gives the State and the three regulatory agencies - BCC, CDFA, and CDPH more time to issue licenses further up the supply chain - ultimately, making your life as a dispensary operator a whole lot easier.
Paying for Your Provisional/Annual License
Strategically delaying payment for your provisional/annual license is one thing but under no circumstances should it be left to the last minute. Operators who have been granted the ability to secure their license must have it approved by the BCC prior to their temporary expiring. Because if a gap in licensure occurs, you'll be forced to close your doors until the BCC approves your license. Additionally, the BCC will be processing payments in the order they are received, so if a backlog begins to build, this will increase the amount of time it takes for them to process your payment. Luckily, understanding how you plan on submitting payment will allow you to plan accordingly and determine approximately how far in advance you'll need to get started.
There are 3 different options for paying your licensing fee: cash, check or credit/debit card. Each option carries with it a couple of variables that need to be taken into consideration when planning your payment timeline.
1. Cash PaymentsIn the cannabis industry, cash is king - for now. But when it comes to paying for your provisional/annual license, be wary of the additional logistical obstacles this method necessitates.
The BCC requires cash payments be made in-person, by appointment at their headquarters in Sacramento. So, for anyone outside of the Northern California region, make sure that you're baking in additional time to account for any travel. If you're planning on going this route, you can make an appointment with the BCC by calling (833) 287-8171 - but don't plan on showing up without one booked or you and your hard-earned money will be turned away at the door.
If you plan on making your payment in cash, you should call to book your appointment no later than 5 weeks prior to your temporary license expiring.*
2. Check Payments
If submitting your payment by check, you'll want to be mindful of how long it generally takes for mail to travel from your location to Northern California. Given the sizable amount you'll be cutting the check for, it's in your best interest to pay a little extra for registered mail or overnight delivery.
If you plan on making your payment by mailing a check, plan on sending it out no later than 3 weeks prior to your temporary license expiring.*
3. Credit/Debit Card Payments
If you plan on making your payment online by credit/debit card, plan on submitting payment no later than 2 weeks prior to your temporary license expiring.*
Regardless of which method you choose, it's not the travel time you need to account for - it's the processing time. While you may still be new to frequent interactions with Metrc and the BCC, you're no stranger to interacting with government bodies at large. And if past experience is any indication, government entities aren't generally the most efficient, so take that into consideration when planning your approach. Because of this, proper prior planning is paramount when choosing how and when to submit payment or making requests from these entities in general.
So, as you launch into this uncharted realm of compliance consider the following mantra as a guiding principle: proper prior planning prevents poor production.
So, what's the moral of the story here? In short, think strategically about how and when you go live on Metrc. While many factors lie outside of your control, paying for your license may not be one of them. And if there's an opportunity for you to use some of the timelines to your advantage, you should take it!
After all, it's your internal processes and operations that will cement your success in a track-and-trace world, and if a little more time in the short term, means a lot more success in the long-term, then the choice seems pretty clear. And for Treez operators, we'll be here to support you no matter what path you choose and will make your journey on to Metrc (and beyond!) as easy and enjoyable as possible.
*The payment timelines provided are general suggestions and should be used at the discretion of each individual operator. It is wholly the responsibility of the operator to account for enough processing time to secure their provisional/annual license.