Is seed-to-sale inventory tracking required in the state of Vermont? What platform is the state using?
Inventory tracking is required under state law. The Cannabis Control Board is in the process of developing its own platform for inventory tracking.
In the meantime, Licensees must track their inventory via the forms staff have built here:
https://ccb.vermont.gov/inventory-tracking
All licensees must enter their inventory tracking information to the form on a bi-weekly basis.
Additional guidance on inventory tracking is available here: https://ccb.vermont.gov/guidance
My inventory has not changed in two weeks. Do I still need to enter my inventory tracking information?
Yes. All licensees must check into the inventory tracking system every two weeks, even if nothing has changed.
I’m a cultivator, and I haven’t finished harvesting, drying, and curing my plants. Do I need to track my inventory, and can I change my data after harvesting and drying?
Yes, you must track your inventory every two weeks, no matter what. Inventory tracking is designed to be a seed-to-sale tracking system. This means that all inventory is traced from when plants are put in the ground, through the discard of any male plants, to harvest, to manufacturing, to when the final cannabis or cannabis product is sold to the end consumer.
The inventory tracking system is designed to be updated as plants continue through their growth stages through harvest.
The tracking forms refer to “Harvest Lot” and “Process Lot.” What do those terms mean?
These terms are defined in guidance. Please refer to the Inventory Tracking and Lab Testing Guidance document on our webpage:
https://ccb.vermont.gov/guidance
Is each license holder that must have its product tested required to get the testing done by an independent laboratory?
Yes, the Vermont legislature has mandated independent testing for every license holder that is subject to a testing requirement.
The relevant statute provides: “A cannabis establishment that is subject to testing requirements under this chapter or rules adopted pursuant to this chapter shall have its cannabis or cannabis products tested by an independent licensed testing laboratory and not a licensed testing laboratory owned or controlled by the license holder of the cannabis establishment.” 7 V.S.A. § 908(f).
Additional guidance on lab testing may be found on our website: https://ccb.vermont.gov/guidance
What tests are required for smokeable flower?
Smokeable flower must be tested for THC potency, pesticides, and pathogens. In order for flower to be offered for retail sale, THC potency must test below 30%. Flower that tests positive for aspergillus cannot enter the market as smokeable flower, unless it has been remediated and subsequently tests clean. See Lab Testing guidance for aspergillus remediation pathway. Aspergillus positive flower may be used for extraction manufacturing purposes.
I own a business that produces non-THC infused food products - can I start manufacturing edibles containing THC?
Businesses manufacturing food products that don't contain THC must have a license through the Vermont Department of Health. If you have a Food Processor license through the Department of Health, you cannot manufacture edibles containing cannabis at the same facility that's licensed to manufacture products that don't contain cannabis.
The Department of Health produced a Frequently Asked Question document specifically on this topic. Please refer to it for additional information:
Will the Department of Liquor and Lottery be handling compliance and enforcement actions for the Cannabis Control Board?
No. The Cannabis Control Board has full civil and administrative enforcement authority of its rules under state law (7 VSA § 843). Under the 2022 public safety plan released by Governor Scott, the Department of Liquor and Lottery should be called upon by the Cannabis Control Board for criminal law enforcement support instead of relying on Vermont State Police, when the Board deems it necessary.
The has its own independent compliance division, tasked with fostering a culture of education and compliance in Vermont. The compliance division is also responsible for investigating complaints about the actions of any cannabis establishment, and can recommend administrative and civil sanctions to the Board. Should law enforcement support become necessary in enforcing the Board’s rules, the Board will rely on DLL on a case-by-case basis. Compliance inquiries or complaints may be made online via Adult-Use Complaint form (linked below), or by emailing CCB.Compliance@vermont.gov.