Samples are an important part of the marijuana industry. There is no better way to understand the quality of a product than by sampling it yourself. However, if provided improperly, samples can cause some compliance issues. Remember, licensed marijuana businesses are required to utilize METRC for moving product around the closed loop system, and samples are NOT exempt from this requirement!
First, samples should not be sent to a Medical Marijuana Center or Retail Marijuana Store to be picked up by a sales rep to distribute at will. Samples must be manifested in METRC just like any other marijuana or marijuana product. Samples can only be sent to a licensed Medical Marijuana Center or Retail Marijuana Store to distribute to its employees to test the samples and should NOT be given to customers.
Here are a few best practices to keep in mind when preparing samples:
1) Each set of samples must be packaged with a METRC package tag and manifested in METRC to the end destination store just like any other marijuana product.
2) One package tag per category is required for your samples. So if you have edible and a concentrate samples, you will need at least 2 METRC tags.
3) Multiple category samples can be on the same manifest as regular products as long as they have their own METRC package tag as indicated above.
4) When naming the sample products in METRC, refrain from using the word “sample.” Instead, just use the regular name of the product and indicate it is a sample on the invoice.
5) Samples should be received by the Medical Marijuana Center or Retail Marijuana Store in METRC, and then entered into the point of sale inventory.
6) The Medical Marijuana Center or Retail Marijuana Store should sell the sample through the point of sale, even if it is at a minimal cost of $1.
7) Samples should be properly labeled like all other products that are sold. They should also include a sticker that indicates that the product is a sample.
While it might seem easy enough to just take a few items from your inventory for sampling “off the record”, don’t do it! This could land your business in hot water.
Yours in Compliance,