Now that Medical Marijuana potency testing is live for harvest batches harvested on or after November 1, 2016 (microbials testing soon to follow), the Marijuana Enforcement Division has made adjustments to the Medical Marijuana Code to allow for the additional time needed to package and label Medical Marijuana once it has been tested.

Under the old MED rule, M 501 E read that processed Medical Marijuana “must be transported to the Medical Marijuana Business within 48 hours and recorded as inventory at the receiving Medical Marijuana Business.”  In other words, a medical OPC is required to transfer finished marijuana to its associated dispensary within 48 hours of the completion of processing.

But the old rule did not allow enough time to account for testing. It would be nearly impossible to test, obtain testing results, package, label, and transport Medical Marijuana within the 48 hour window.

As a result, the new Medical Marijuana Code allows for 7 days (rather than 48 hours) to transfer Medical Marijuana after receiving the notification that the Harvest Batch of Medical Marijuana passed required testing.

Once medical microbial testing goes live, the 7 day window becomes that much more valuable.  In cases where microbial testing fails, there might be situations where this timeline is especially applicable.

If a Harvest Batch fails microbials testing on the first test, then two additional Test Batches must be tested in order for the Harvest Batch to be transferred to a Medical Marijuana Center. Upon retesting, if passing results are received on both retests, then the licensee has 7 days from the date of the last passing retest to package, label and send the product to the Medical Marijuana Center.

This rule change ensures that the licensee has enough time to properly label and package Medical Marijuana after it passes all required tests. Thank you MED!

As a reminder, Complia offers the first comprehensive test data manager which automatically determines if your licenses are in compliance with all testing rules.  If you’d like to see a demo, drop us a line at

Yours in Compliance,

Team Complia