About 80% of Washington’s licensed marijuana businesses rely on third-party companies to report state-required traceability data, even though those companies are not licensed by the Washington State Liquor and Cannabis Board (LCB), according to newly released agency documents.
The disclosure comes in an LCB staff response prepared for the board’s October 7 meeting. Staff are recommending that board members reject a rulemaking petition seeking new accountability requirements for third-party vendors that interact with the state’s Cannabis Central Reporting System (CCRS).
CCRS is Washington’s seed-to-sale reporting platform. Licensed marijuana businesses use it to report information on production, inventory, laboratory testing and sales.
Many businesses do not submit that information directly. Instead, they use third-party “integrators” that provide inventory management or point-of-sale software and can upload traceability data into CCRS on a licensee’s behalf.
“Not all licensees use integrators for reporting traceability information, but approximately 80% do,” the agency said.
LCB maintains a list of integrators that have been vetted for access to CCRS, but the companies themselves are not licensed by the agency. The state says licensees must grant an integrator permission before it can submit information on their behalf, and licensees remain responsible for the data reported.
The petition was submitted August 13 by Amy Dalluge, owner of The Green Seed, a marijuana retailer in Moses Lake. Dalluge asked the board to establish rules addressing vendor accountability, traceability system integrity, comparative audit rights, enforcement standards, independent validation and other issues.
Dalluge alleged there is a “lack of vendor accountability” and statewide CCRS reconciliation problems, and argued that licensees cannot independently verify what information CCRS ultimately receives or reconciles.
LCB staff disputed several of those assertions.
The agency said licensees can request CCRS data reports to validate information submitted on their behalf and said LCB regularly assesses reporting discrepancies.
The response also reveals that Washington has now received 15 rulemaking petitions since March 19 seeking changes related to marijuana traceability or CCRS.
LCB acknowledged that both a 2025 Joint Legislative Audit and Review Committee report and a 2024 State Auditor report identified limitations with CCRS. The agency sought funding from lawmakers for a standalone replacement system for fiscal year 2027, but the request was not funded.
LCB has now submitted another funding request seeking a CCRS replacement for fiscal year 2028. That request remains pending.
Staff nevertheless argue that the current petition cannot accomplish its central goal because LCB’s marijuana rules govern businesses licensed by the board, while third-party integrators are not themselves licensed.
“To create rules for integrators the legislature must first create a license for third party integrators to be licensed by the board,” staff wrote.
The Director’s Office is recommending that the three-member board deny the petition when it considers the matter Wednesday.
