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Revised Rule Related to Seed-to-Sale Reconciliation Now Effective

  • August 31 2026

Summary of Key Changes 42.39.203, Reconciliation

DOR adoption notice, August 18, 2026 – MAR 2026-445.2 amended ARM 42.39.203. Significant requirements include daily inventory reconciliation by 11:59 p.m.; five-pound limits for most flower packages; clarified process-lot limits; same-day recording expectations; legible, unobscured tags; and resolution of compliance notifications within 30 days. Testing laboratories may reconcile sample consumption at the end of the applicable testing period instead of daily.

Effective Date: August 22, 2026

Tagging and Tracking Clarifications

  • Terminology: The rule now clarifies that "plant tag" and "package tag" refer to unique identification number tags for plants and packages, respectively. The generic term "tag" applies to both.
  • Plant Tagging: Plants reaching 12 inches must be tagged, but the tag only needs to be physically affixed once the plant reaches 18 inches (previously, the tag was affixed earlier).
  • Package Tagging: All marijuana items, test batches, harvest lots, and process lots must be issued package tags. The language is updated to clarify that tags cannot be reused, photocopied, or replicated.

Physical Placement and Packaging

  • Physical Tag Placement: The requirement is now that the tag must be placed "with the unique identification number affixed to it," rather than simply "placed on it."
  • Packaging Limits: Packages of marijuana flower and usable marijuana must not exceed five pounds, except for concentrate/extract production and whole, wet plants from harvest. Process lot packages are limited to 5,000 units of sale.

Testing and Sub-Packages

  • Testing Requirement: Sub-packages cannot be created or distributed until the source package passes all required testing.
  • Combining Process Lots: Multiple process lots cannot be combined under one package tag after testing unless they are manufactured into a new product, which must be tested.

Tag Integrity and Vendor Requirements

  • Tag Integrity: All tags must be unaltered, legible, and placed so they can be clearly read, free from dirt and debris.
  • Vendor Requirement: Licensees must use tags purchased from the seed-to-sale tracking system vendor.

Inventory Reconciliation

  • Daily Reconciliation: All on-premises and in-transit inventories must be reconciled in the tracking system by 11:59 p.m. daily, with specific examples provided for plant counts, product quantities, location, facts panels, variance, depleted packages, process lots, rejected manifests, finished lots, and remediated products.

Sales and Transfers

  • Cardholder Verification: For each sale or transfer, licensees must verify cardholder eligibility and purchase limits, and record quantity, price, and date in the tracking system.

Harvest and Waste Recording

  • Harvest Recording: Wet weight of each harvested plant must be recorded immediately after harvest, with additional requirements for unit count, weight per unit, waste disposal, harvest scheduling, strain-specific harvests, theft/loss, and other department-required information.
  • Harvest Scheduling: Each plant harvest must be scheduled in Metrc 72 hours prior to conducting the harvest (see directions below).

ARM 42.39.203(12)(d) states, "Licensees must record in the seed-to-sale tracking system: the schedule date for a plant harvest at least 72-hours before beginning the harvest."

To use the harvest scheduler

  1. Log in to your cultivation site in Metrc.

  2. Under the Plants tab in the upper left corner of the screen, select "Harvest Schedulers."

    Metrc Plants page with the Plants menu expanded and a red arrow pointing to the Harvest Schedules option.(opens full-size image)

  3. A new window will pop up with a calendar for Harvest Schedule; select the "Schedule Harvests" icon in the upper left corner, fill out the harvest schedule with the location of the room you plan to harvest, and the date you plan to harvest. You can also enter more dates to harvest by selecting the + (plus sign) icon.

    Metrc Harvest Schedule calendar with the Schedule Harvests button outlined in red, and the Schedule Harvests window open showing Location, Sublocation, Date fields, and a plus sign icon to add more harvests.(opens full-size image)

Laboratory and Testing Adjustments

  • Laboratory Exemption: Requirements do not apply to items held by labs for testing, as long as they remain on premises and are reconciled after testing concludes.
  • Package Adjustments: Adjustments must be accompanied by an entry detailing the reason and cannot be used to resolve inaccurate sales, package transfers, or inventory discrepancies.

Quality Assurance and Compliance

  • Testing Samples: All samples for quality assurance must be recorded.
  • Testing Results: Licensed labs must record all results in the tracking system.
  • Compliance Notifications: Licensees must monitor and resolve compliance notifications within 30 days.
  • Administrative Action: Packages under administrative action must be quarantined and may only be destroyed per Montana administrative rules.

Detailed Tracking Requirements

  • Tracking Details: Licensees must accurately record harvest lots, manufacturing process lots, item categories, remediation steps, and destruction documentation.

Seed Input

  • Seed Input: Only seeds may be accepted from outside the tracking system, and licensees must contact the department to input seeds.

Tags: CARD and Cannabis