Operations & SOP Requirements

Day-to-Day Compliance Requirements (Adult- Use)

MRTA Article 4, Sections 78–86

Sections 78–86 set the operational rules every adult-use cannabis licensee must follow once licensed. These provisions govern daily operations, inspections, records, packaging, testing, distribution, retail conduct, and advertising.

If you are open for business, these are the rules inspectors enforce.

What This Covers

Recordkeeping and tracking obligations
Inspection authority and compliance expectations
Ownership and vertical-integration restrictions
Packaging, labeling, and testing requirements
Cultivation, processing, distribution, and retail rules
Advertising and marketing restrictions

Recordkeeping and Tracking (78)

Licensees must maintain complete and accurate records from acquisition through sale or destruction.

Requirements include:

Tracking inventory, transfers, sales, waste, and product movement
Keeping records on-site and available at all times
Using a seed-to-sale system if required by OCM
Maintaining all information specified by regulation

Failure to maintain required records is grounds for enforcement action.

Inspections and Ongoing Requirements (79)

OCM, peace officers, and police may inspect licensed premises at any time.

Inspectors may review:

Records and inventory
Financial and corporate documents
Building, fire, health, and safety compliance

A responsible employee must be present. Inspections must not unnecessarily disrupt security or operations, but participation is mandatory.

Ownership Restrictions (No Vertical Integration) (80)

These rules apply to cultivators, processors, and distributors.

These licensees may not:

Own any interest in a retail dispensary
Loan money to a retailer
Provide gifts, services, or inducements to influence retailers
Enter exclusive purchasing or coercive supply agreements

Prohibited agreements are void and may result in license revocation.

Exceptions:
Registered Organizations and microbusinesses may be vertically integrated only within the limits of their license and OCM rules.

Packaging, Labeling, and Product Standards (81)

Cannabis products must meet all packaging and labeling requirements.

Rules include:

Child-resistant packaging meeting safety standards
Accurate labeling with THC content, servings, warnings, and required disclosures
No packaging or labels attractive to individuals under 21
OCM approval for new product forms
Compliance with any standardized packaging or warning requirements

Improper packaging or labeling may result in fines, suspension, or enforcement.

Laboratory Testing (82)

Processors and manufacturers must use independent, permitted laboratories.

Requirements include:

Labs must be independent and hold no other cannabis license
Test results must be provided to distributors and retailers
Retailers must retain test reports and make them available to consumers
On-site testing does not replace required lab testing

OCM may regulate sampling, retesting, quarantines, recalls, and reporting.

Cultivation and Processing Rules (83)

Operators must:

Follow OCM cultivation and processing standards
Sell products only in sealed, labeled containers
Use approved pesticides and sustainable practices where applicable
Transport cannabis only in approved vehicles
Follow good manufacturing practices (GMPs)

Operators may not:

Provide unauthorized signage to retailers
Offer incentives or inducements to retailers
Market products appealing to individuals under 21
Mix cannabis with alcohol or nicotine

Distribution Requirements (84)

Distributors must:

Deliver only sealed, labeled products
Use approved vehicles and deliver only to licensed premises
Maintain detailed purchase and sales records for at least five years
Track THC content, batch numbers, and license information

Distributors may not:

Provide unauthorized signage
Offer discounts, rebates, or loyalty programs unless authorized
Exceed OCM-set markup limits

Retail Dispensary Rules (85)

Retailers must:

Verify valid ID and refuse sales to anyone under 21 or visibly intoxicated
Sell only approved, tested cannabis products
Display prices clearly
Maintain required consumer education materials
Have a responsible employee present during inspections

Retailers may not:

Sell alcohol or hold an alcohol license
Sell products intended for unlawful resale
Hold ownership interests in cultivators, processors, distributors, or microbusinesses
Loan money to those license types
Permit gambling or illicit activity

Advertising and Marketing Restrictions (86)

Advertising may not:

Be false or misleading
Promote overconsumption or show consumption
Appeal to individuals under 21
Appear near schools, parks, childcare sites, or public transit
Use unsolicited pop-ups
Appear on public property
Make medical or wellness claims
Use billboards
Offer discounts or coupons that reduce tax burden

Marketing must:

Clearly identify the advertiser
Appear only where the audience is reasonably expected to be 21+
Be supported by audience-age data if requested

OCM may review and enforce all advertising activity.

What Operators Usually Miss

Recordkeeping violations are among the most common enforcement triggers
Ownership restrictions apply even without day-to-day involvement
Advertising rules are enforced aggressively and retroactively

When This Comes Up

Daily operations
Inspections and audits
Product launches
Marketing campaigns
Ownership or contract reviews