By Cannabis In Black NY Team
As the New York cannabis market continues to mature, compliance remains the backbone of a successful operation. With the Office of Cannabis Management (OCM) and Metrc rolling out the next phase of traceability requirements, we know that "deadline anxiety" is real.
To help our community of retailers and delivery operators stay ahead, we have broken down the critical updates arriving in February and March 2026.
Here is everything you need to know about the new Retail Item ID (QR Code) and Testing requirements—and crucially, what is not your responsibility.
1. The "QR Code" Mandate (Retail Item ID)
Deadline: February 28, 2026
Starting at the end of this month, the intake process for new inventory changes. The goal is granular traceability—tracking every single unit, not just the bulk case.
• The New Rule: You cannot accept any new transfers unless every individual unit (jar, bag, pre-roll pack) has a Retail Item UID (QR Code) sticker affixed to it.
• Your Job: When a delivery arrives after Feb 28, inspect the individual units. No QR code? Do not accept the transfer.
• The Valid Check: Continue to ensure the physical Package UID (the blue tag on the bulk box/case) matches the digital manifest in Metrc exactly. This hasn't changed.
2. The "Test Passed" Mandate
Deadline: March 31, 2026
A month later, the focus shifts to rigorous quality assurance verification within the Metrc system.
• The New Rule: You cannot accept inventory with a "Not Submitted" status.
• Your Job: Before accepting a transfer in Metrc, verify that the incoming inventory has a status of "TestPassed" or "RetestPassed".
• Why it matters: This ensures that no product enters the retail stream without a confirmed, passing Certificate of Analysis (CoA) linked directly to the batch in the state tracking system.
Important: What You DO NOT Need to Do
Compliance updates often lead to panic about existing stock. Let’s clear up a few myths so you don’t waste time or resources.
You DO NOT need to label your current inventory.
This rule is not retroactive. You do not need to go into your vault or shelves and apply QR codes to products you already own. The requirement applies strictly to new transfers coming in after the February 28th deadline.
You DO NOT need to buy the stickers.
Retailers are not responsible for purchasing or printing Retail Item IDs. These must be purchased and applied by the Processor or Distributor before the product ever reaches your door. If a distributor asks you to pay for them, that is incorrect.
You DO NOT need to reject products... yet.
Until February 28, 2026, it is business as usual. You can still accept products that do not have the QR code on individual units, provided the bulk package has a valid Metrc tag.
The Compliance Timeline: At a Glance
Print this out and tape it to your intake desk!
• NOW – Feb 27, 2026:
• Status: Business as usual.
• Action: You may start seeing QR codes on units, but they are optional for acceptance.
• Feb 28, 2026:
• Status: STOP.
• Action: Do not accept a transfer unless individual units have the Retail Item ID (QR Code).
• March 31, 2026:
• Status: CHECK.
• Action: Ensure all incoming inventory has a passing test status in Metrc.
Need Support?
If you run into issues with a specific delivery or have questions about a manifest, contact your distributor immediately. For specific questions regarding shipments from NYS Distribution, please reach out to support@nysdistribution.com.
Stay compliant, stay profitable, and keep building the New York ecosystem.
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