Cannabis · guide
Metrc and Track-and-Trace Compliance Basics: Tags, Manifests and Common Violations
Updated
Track-and-trace is the system of record regulators use to follow every plant and package from cultivation to sale. Metrc is the vendor behind most of these systems, but each state writes its own rules for tags, transfers and reconciliation, and the state rule is what an inspector enforces. This guide covers the shared mechanics and the state-specific timing that trips up operators, as verified at time of writing (September 2026).
Which states use Metrc
| State | System | Rule or source |
|---|---|---|
| California | Metrc | 4 CCR ch. 1, art. 6 (sections 15047.1 to 15051); DCC delivery guidance references Metrc |
| Oregon | Metrc (called CTS in rule) | OAR 845-025-7500 series; OLCC CTS page |
| Massachusetts | Metrc | 935 CMR 500.105(8); CCC seed-to-sale guidance |
| Illinois | Metrc (replaced BioTrack) | Official system since July 1, 2025 per cannabis.illinois.gov |
| New Jersey | Metrc | N.J.A.C. 17:30-3.6; CRC resources |
| New York | Metrc (replaced BioTrack) | OCM seed-to-sale page |
Two of these changed recently. Illinois moved from BioTrack to Metrc in a phased rollout in spring 2025, with Metrc becoming the official inventory system on July 1, 2025. New York had required licensees to integrate with BioTrack, then switched vendors; OCM set a December 17, 2025 credentialing deadline, a January 12, 2026 deadline for retailers to enter existing inventory under package UIDs, and a February 28, 2026 date for retail item IDs. Older guidance that names BioTrack for either state is out of date.
Tags
Tags carry a unique identifier (UID). California's definitions distinguish a plant tag attached to a cannabis plant from an RFID-enabled package tag attached to a batch of cannabis or product, both provided by the department or its designee. Oregon's OAR 845-025-7520 requires a UID tag on each plant no later than when it reaches 24 inches in height or begins flowering, whichever is sooner, placed where it can be read by someone standing next to the plant, and a new tag each time an item is placed in a receptacle. Oregon added a batch-tagging option for groups of up to 100 plants in June 2024, and California noticed a group-tagging rulemaking in June 2026, so check whether your state now allows one tag per group at the immature stage. New Jersey's 17:30-3.6 makes licensees responsible for the cost of compatible tags; Illinois covered tag costs during its transition through state funding.
Transfer manifests
A manifest is the record that travels with product between licensees. Oregon's OAR 845-025-7700 lists what it must contain: origin and destination license numbers and addresses, each item's UID, product name and quantity, departure date and estimated time, route, vehicle make, model and plate, and the name and signature of the person accompanying the transport. For large shipments to retailers (over 25 pounds of usable marijuana, one pound of concentrate or 1,000 units of product) the manifest must be generated at least 24 hours before transport, and a printed copy must accompany every transport. The receiver must accept or reject each UID, verify items against the manifest and record any quantity discrepancy. California's section 15049.2 governs recording transfers, and section 15049.3 adds ledger requirements for retail deliveries.
Reporting and reconciliation windows
- California: section 15049 requires receipts, rejections, manufacturing, disposal, packaging, testing results and sales to be recorded within 24 hours. Section 15051 requires a review and physical reconciliation at least every 30 calendar days, an audit when a discrepancy is found, and written notice to DCC of significant discrepancies.
- Oregon: OAR 845-025-7580 requires all inventories and weights to be reconciled in CTS by 8:00 a.m. the following day, with a 45-day exception for evaporative moisture loss after harvest that must still be reconciled before transfer, processing or packaging.
- Massachusetts: the Commission's seed-to-sale guidance states that end-of-day physical inventory must match Metrc.
Training is also a rule, not a courtesy: Oregon requires a Metrc class and passing test before system access, and California's section 15048 covers training and credentialing.
Violations regulators cite
The same failures recur across states: untagged or mis-tagged plants, inventory counts that do not match the system, activities recorded late or not at all, transfers without a manifest or with a manifest that does not match the load, and unauthorized user access. California's disciplinary guidelines list failure to comply with track-and-trace reporting and reconciliation and unauthorized use of the system. Massachusetts warns that failing to enter inventory, or distributing product not tracked in the system, can lead to license suspension or revocation. Oregon's OAR 845-025-8520 classifies refusing an inspector access as a Category II violation, and importing or exporting marijuana items, which tracking data typically reveals, as Category I.
RegPing's cannabis bot delivers track-and-trace bulletins and rule changes from these agencies into Discord.
Where to verify
- California track-and-trace rules, 4 CCR art. 6
- Oregon OLCC CTS page
- Oregon OAR 845-025-7580 reconciliation
- Massachusetts 935 CMR 500.105
- Illinois seed-to-sale tracking
- New Jersey N.J.A.C. 17:30-3.6
- New York OCM seed-to-sale
This guide is general information, not legal advice. Verify against the primary source and consult counsel before acting.
Questions people ask
Do New York and Illinois still use BioTrack for cannabis tracking?
No. Illinois made Metrc its official system on July 1, 2025, and New York moved licensees to Metrc with credentialing and inventory deadlines in December 2025 and January 2026.
How often must California licensees reconcile Metrc inventory?
At least once every 30 calendar days under 4 CCR 15051, with most activities recorded within 24 hours under 15049. Oregon requires daily reconciliation by 8:00 a.m. the next day.
When must an Oregon cannabis plant be tagged?
No later than when it reaches 24 inches in height or starts flowering, whichever comes first, under OAR 845-025-7520.