Since the launch of the METRC system in 2014, a great deal of confusion has surrounded transferring medical cannabis from an OPC to an unaligned Center or MIP.  Transferring marijuana from an OPC to it’s aligned Center has always been straightforward.  However, there have always been a range of opinions as to the transfer of medical cannabis in cases where the cannabis is destined for a license that is not aligned with the originating OPC.  We are happy to report that the MED has finally shed some light on this controversial topic.

Suppose you operate an OPC in Denver that is aligned to a Center in Colorado Springs, but hope to sell some excess bud to a Center in Boulder.  Historically, operators were with faced with three options:

  1. Physically manifest/transfer the product from Denver to Colorado Springs and then create a new transfer manifest from Colorado Springs to Boulder.  In the absence of MED guidance, this has been the most conservative way to approach this transaction but it comes with a substantial cost – nearly 168 miles of driving!  Not fun.
  2. Create a transfer manifest direct from the Denver OPC to the Boulder Center.  This makes life much easier on your delivery driver with only 30 miles of driving required.  However, the aligned Center was not involved with this transfer so there is obviously some compliance risk associated with this approach.
  3. Lastly, some operators chose to create transfer manifests that “virtually” show the flow of product from the Denver OPC to the aligned Center in Colorado Springs and then from Colorado Springs to Boulder.  However, the product was actually just physically transported from Denver to Boulder.  On paper, this approach looks good but it doesn’t tell the whole story.

Clearly, none of these are great options.  As a business operators in the industry, we’re constantly faced with these tough decisions.  It’s no secret that many businesses decided that the cost of physically transporting product all over Colorado just to complete a single transaction did not outweigh the compliance risk cost.  Thankfully, the MED has finally clarified what is and is not permissible.

Just last week the MED posted a Compliance Tip on this very topic.  We were very excited to read that “Current statute allows for a physical transfer of medical marijuana from OPC to an unassociated Center or MIP if the medical marijuana is first virtually transferred to the OPC’s associated Center.”  In other words, the MED has clarified that option 3 (as detailed above) is compliant.  We expect this will save licensed businesses a lot of headache moving forward.  Thank you MED!  Be sure to read the whole tip in detail to get the full scoop!

If your team has questions on this topic or anything else surrounding the world of cannabis compliance, drop us a line.  We’re here to help.


Yours in Compliance,

Team Complia