Medical Marijuana Control Program

Ohio Department of Commerce June 8, 2022

Metrc RFID Tags Available June 13

The MMCP appreciates the feedback received from licensees on Metrc RFID tags. The MMCP worked with Metrc to create an option for utilization of RFID tags or the current non-RFID barcode labels. This option will be available in Metrc beginning June 13, 2022. Please read below for more information. Do we have to use RFID tags? No, licensees are not being required to use RFID tags. Licensees may continue to use the traditional barcode labels. If we begin using RFID tags and decide the barcode labels work better for our operations, can we switch back? Yes, at this time you may choose to utilize RFID tags or barcode labels. If we wish to utilize RFID tags for some plants or packages, but do not wish to switch fully to RFID tags, is that an option? Yes, at this time you may choose to utilize RFID tags or barcode labels for different parts of your operation. However, licensees must continue to properly tag and track all plants and packages in Metrc. If RFID tags and barcode labels are being used within the same room, it is the licensees’ responsibility to ensure that all plants and packages are accurately tracked. If my facility wants to switch to RFID tags, do we have to do so all at once or can we phase them into our operations? If a licensee chooses to utilize RFID tags, it may do so using a phased approach whereby RFID tags are attached to new plants and packages, and barcode labels simply phase out over the life of the plant or package. A licensee may also choose to switch out all of their barcode labels for RFID tags at once. If choosing this approach, the licensee must ensure that all plant and package labels are appropriately replaced with the RFID tags utilizing the Metrc tag replacement functionality. Please review the tag replacement instructions outlined in the Metrc Industry Generic User Guide. Is any additional equipment or software required to switch to RFID tags? Metrc does not require additional hardware or software; however, additional hardware and software may be necessary to take full advantage of the RFID technology, such as the scanners themselves. Licensees are encouraged to discuss options with your hardware and software vendors. What is the price differential between barcode labels and RFID tags?

Prior to purchasing RFID tags, licensees are encouraged to review options and any additional costs for hardware or potential software upgrades to your facility’s system with your hardware and software vendors. Can we return RFID tags or barcode labels for a refund if we don’t need them or accidentally purchased them? No, Metrc does not currently provide refunds.   How do we get started with RFID tags? Work with your third-party vendor to ensure the facility fully optimizes its use of the RFID technology and functionality. Metrc does not directly provide RFID hardware; however, Metrc’s validated integrators can be found here: https://www.metrc.com/validated-integrators/#. Please refer to the Metrc Industry Generic User Guide (RFID tags are discussed beginning on page 54) and Metrc Tagging Guideline Memorandum for more information regarding RFID tags. What else do we need to know? If a facility chooses to switch completely to RFID tags, it must notify the assigned MMCP agent once the switch is complete (i.e., you are only using RFID tags and no barcode labels are left on any of your plants or packages). As a reminder, whether using RFID tags or barcode labels, it is the licensee’s responsibility to ensure accuracy of the data input into Metrc and to comply with all tracking requirements of Ohio Revised Code/Ohio Administrative Code 3796. Licensees should educate themselves on the RFID technology before proceeding.     Example of Metrc RFID Tag and Barcode Label Order Screen   “Medical Plant Tag” and “Medical Package Tag” include the RFID chips in addition to the barcode. “Medical Plant Label” and “Medical Package Label” are the traditional barcode labels only (non-RFID).

Medical Plant Tag

Medical Package Tag

Labeling THCA

The MMCP has received some questions regarding whether or not “Delta-9” should be included in front of “THCA” on product labels as a result of the THC Definition Rule Update guidance sent out on April 5. As the current Standardized Label Template does not include “Delta-9” in front of “THCA,” cultivators and processors are not currently required to include “Delta-9” on the label in front of “THCA.”   At this time, labels that say either “Delta-9 THCA” or “THCA” are acceptable.   As provided in the guidance and Standardized Label Template, “Delta-8 THC” and “Delta-9 THC” must be specified.

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