Michigan Vertically Integrated Company with Extraction about to go online with a Metrc/MRA Question:
Can I combine untested packages of flower/trim/biomss before I send to processing?
Is it easier to send packages individually to Processing, and then have Processing combine packages?
Can Processing combine any package, wether, passed, failed, or untested if going to extraction?
I am 99% sure I can combine untested biomass into one package under my grow license with the intention of extraction, but I just want to make sure I am dotting the Iās and crossing the Tās before I pull the trigger. Thanks!
welcome!
i hesitate to say iām an expert on this subject (my company has a team devoted to METRCās nuances exclusively) but if the combination you speak of reflects the actual reality of the steps performed on the material represented by these packages, you should be fine. And i think youāre talking about two viable ways to skin a cat hereāthat being said, you might be adding an unnecessary step by combining before processing, where they could be combined after processing into one new package, then continuing to extraction as one, easy to use package.
or, you could combine them all now, send them into processing as one package, where itās one easy to handle package for your people to use down the rest of the line. the advantage there would be ease of use for whoeverās doing the Metrc work down the line.
i think both will work, but again so long as it reflects the reality of which step the material was combined in, etc. youāll be good i think. best of luck!
Thanks. The Grow has more Metrc experience, and just for ease, I would combine all the Non-Tested packages, floor trim and biomass, here under the Grow license.
I am wondering what Processing can actually combine for an extraction run? Untested, Passed and Failed together? Not sure. I will keep digging.
In Michigan, you can ask the governing body, (MRA), to allow you to transfer, untested, specific packages of biomass with written permission if the intent is extraction. Michigan calls it Fresh Frozen Transfer, since we do not test fresh flower. We use the same form for any and all untested product intended for extraction, (floor trim, biomass, etc.). You can also send them, via a transporter, to an unafilliated liucense. Works really well, and you can get rid of your floor trim!
Feel free to PM me. I have been dealing with METRC in Michigan since 2019 and am pretty well versed in the regulations, what is allowed, what isnāt allowed, etcā¦
there are lots of METRC bulletins and i am sure this is outlined in one, i cant remember which one, will have to check my files.
growers can not combine any packages made from different strains or harvest batches. tested or untested, the designation is per strain and per harvest batch. this was not always the case.
not sure about the pass/failed topic for processors, i imagine they will have to keep batches from remediation separate from batches that are not slated for remediation because failed products are locked in the āon Holdā tab.
processors can combine lots more packages together and have more freedom with end product batches.
Just a METRC word of warning for all, you can do āillegalā moves and METRC will not stop you, there are no red flags and no āas you sure you want to make this moveā. The governance is within the regulatory agency in the state in question. they will come down on you for making METRC moves that are not approved by the agency.
Iāve always been able to compile everything regardless of testing status, usually in the MIPP just because sometimes I have packages coming from multiple grows or even left over crude that already exists in the MIPP, that I would like to combine. I havenāt had any issues since the final product is always tested before transferring into the dispensary for sale.