California marijuana regulators have released revised proposed rules that would allow cultivators to track groups of cannabis plants under a single tag, including groups containing multiple strains or cultivars.
The California Department of Cannabis Control (DCC) published the modifications September 17 as part of an ongoing rulemaking designed to reduce the costs and administrative burden associated with the state’s track-and-trace requirements.
Under the broader proposal, immature and mature marijuana plants could be tagged individually or as established groups rather than requiring every mature plant to carry its own individual tag.
One of the most significant changes announced Thursday removes a proposed requirement that plants within a group be uniform in strain or cultivar when that information is entered into the state’s track-and-trace system.
DCC said several commenters interpreted the previous language as requiring every plant in a group to be the same strain. Regulators said that was not their intention and that strain uniformity is not necessary for regulatory oversight.
Under the revised language, a group could contain multiple strains or cultivars as long as other requirements are met. Plants within a group would still need to be uniform in their application of pesticides and other agricultural chemicals, be planted within three calendar days of the first plant in the group, be located contiguously and be clearly separated or delineated from other plants or groups.
DCC is also revising how plants transition from the immature to mature growth phase.
When an immature plant or group located outside a designated canopy area is moved into the canopy upon flowering, a new plant tag would be required. If plants are moved into the canopy before flowering, they could retain their existing tag until flowering begins.
For immature groups already located within the canopy, cultivators would have several options when some plants begin flowering. They could individually tag each mature plant, transition the entire group to a mature plant group or establish one or more separate mature groups consisting of plants that have begun flowering.
Plants that have not yet begun flowering could remain in the existing immature group.
The department said the revised structure is intended to work with changes being made to California’s track-and-trace system. Existing pathways would remain in place for immature plant groups and individually tagged plants, while a new tracking pathway would be established for mature plant groups.
According to DCC, maintaining much of the existing system while adding the mature-group option will reduce development and testing requirements and allow group tagging to be implemented sooner.
The revisions would also require licensees to report movement of any plant or plant group between locations on a licensed premises within three calendar days. The assignment of a new tag when plants transition to maturity would likewise need to be recorded within three days.
DCC says the overall group-tagging proposal is expected to reduce economic burdens on marijuana businesses and decrease environmental harm while maintaining regulators’ ability to verify that plants physically present at a cultivation site match records in the state tracking system.
The department is accepting public comments specifically on the revised regulatory language through October 2. The regulations remain proposed and would need to complete California’s rulemaking process before taking effect.
