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Matt Frisbie edited this page Nov 15, 2024 · 18 revisions

Overview

Metrc (Marijuana Enforcement Tracking Reporting Compliance) is a state-mandated cannabis compliance system, required in various U.S. states to track cannabis cultivation, production, testing, and sales. Developed by Franwell, Metrc operates as a cloud-based platform intended to monitor cannabis products throughout the supply chain.

Which states use METRC?

Metrc Key Components

Metrc’s compliance ecosystem is built around several key components, each serving a unique role in ensuring cannabis industry compliance with state regulations:

Web UI

The Metrc platform's primary tool is its web-based user interface (Web UI). In states that have adopted Metrc as their compliance tracking system, all licensed cannabis businesses are required to use this interface to report essential compliance data. Key reportable events include:

  • Cultivation Activities: Planting, harvesting, and waste disposal.
  • Manufacturing: Processing raw cannabis into consumable products.
  • Transportation: Tracking the movement of products between licensed facilities.
  • Testing: Documenting results from state-mandated lab testing.
  • Sales: Recording transactions at dispensaries.

Despite the availability of an API, many compliance actions must still be completed through the Web UI due to gaps in API coverage.

Metrc API

Metrc provides an API designed to enable licensed operators and third-party integrators to programmatically interact with its system.

There are two versions of the API:

  • v1 (Free): Available at no cost, this version provides basic functionality for interacting with Metrc’s compliance system.
  • v2 ("Metrc Connect", Paid): A premium version with some additional features, requiring payment for access.

RFID Tags

Radio-frequency identification (RFID) tags are mandatory for tracking every plant and product within the Metrc system. These tags play a critical role in enabling accurate seed-to-sale tracking. States differ in how these tags are funded:

  • In some states, the government covers the cost of RFID tags.
  • In others, the expense is borne by the businesses themselves.

State Agency Interface

Metrc also provides tools for state agencies to monitor and audit cannabis license holders. This lesser-known component of Metrc's platform grants state regulators full visibility into the activity of licensed businesses, enabling enforcement of compliance standards. Features available to state agencies include:

  • Audit Tools: For detailed reviews of licensee data and activity.
  • System-Wide Monitoring: Allowing oversight of all cannabis operations within the state.

These tools form an integral part of Metrc's value proposition to state governments, enhancing transparency and accountability across the regulated market.

Criticisms of the Metrc API

The Metrc API is often criticized for its limitations and challenges.

  1. Dual API Key Requirement
    The Metrc API operates in an unusual manner by requiring two API keys to function:

    • One API key is issued to the cannabis business itself.
    • The other API key is issued to an approved Metrc integrator.

    Becoming an approved integrator involves navigating a state-specific approval process, as each U.S. state mandates its own procedures. This effectively means:

    • Cannabis businesses cannot directly access their own data through the API unless they work with a state-approved integrator.
    • The added dependency on integrators creates barriers for businesses seeking full control of their data.
  2. Incomplete Compliance Support
    Neither version of the Metrc API fully supports all required compliance actions. As a result:

    • Cannabis businesses must frequently rely on Metrc’s web-based user interface (Web UI) alongside the API.
    • This dual dependency increases operational inefficiencies and complexity.
  3. Cost of Access

    • Access to the Metrc API v2 is not free. Businesses are charged for using it, effectively imposing a fee for accessing their own compliance data.
    • This pricing structure adds to the financial burden of regulatory compliance.
  4. Performance Issues
    The Metrc API suffers from significant technical shortcomings:

    • Slow Response Times: The API often performs poorly under load, leading to delays.
    • Lack of Usability: Developers frequently report the API as difficult to use due to its unintuitive design.
    • Poor Documentation: Incomplete or unclear documentation makes implementation and troubleshooting unnecessarily challenging.
    • Unhelpful Error Handling: The API returns generic or unclear error codes, complicating error resolution for developers and users.

State-Specific Metrc Implementations

Each state implements Metrc differently, based on specific regulations and requirements mandated by its regulatory bodies. This means Metrc operates as a slightly different system in each state, adding another layer of complexity for operators who must adapt to the unique requirements where they operate. For multi-state operators, these differences create significant operational challenges, as compliance processes may vary dramatically across state lines.

Metrc RFID Tags

Metrc "tags" are a cornerstone of Metrc’s compliance system, enabling a standardized way to track cannabis plants and products from growth to sale. Each legal cannabis plant or product is assigned a unique identifer, or UID, issued by Metrc, to ensure that items can be identified and monitored across the supply chain.

Each tag is a 4"x1.5" rectangular piece of printed plastic uniquely tied to a UID in Metrc's database. The UID is a 24 character identifier that uniquely a plant batch, plant, or cannabis package. 1A440000C030000000001234 is an example of a UID.

Metrc Tag

A Metrc tag identifies the corresponding UID in one of three ways:

  • The UID is printed on the tag
  • A Code128 barcode that can be scanned with an optical barcode scanner
  • An embedded UHF RFID chip that returns the UID when scanned with a RFID reader

Each UID can only be owned by one cannabis license at any given time. These UIDs are passed between Metrc licenses via transfers.

Types of Metrc Tags

  1. Plant Tags: Plant tags are applied to individual mature plants, and in some states, plant batches.
  2. Package Tags: Package tags are applied post-harvest to any quantity of cannabis in any form that is not waste.

How RFID Works in Metrc

Each RFID tag in the Metrc system is embedded with a unique identifier that corresponds to detailed records in the system, such as plant strain, growth stage, weight, and batch information. The RFID readers, or "scan guns," communicate with these tags by emitting radio waves, which activate the tags and trigger them to send back their data. This information is captured by the reader and recorded in the system, theoretically allowing operators to track and manage their inventory with minimal manual intervention.

The Reality of RFID in Metrc Compliance

In practice, Metrc’s RFID system has proven to be a double-edged sword for cannabis operators. While RFID was intended to streamline inventory management and compliance tracking, the technology’s inconsistent performance and limitations often complicate rather than simplify these processes. Many operators report that they rely on manual data entry to supplement RFID tracking due to frequent read failures and interference. This hybrid approach not only negates the potential benefits of RFID but also places additional burdens on staff, who must constantly double-check automated readings against manual counts.

For a technology intended to ensure accurate, automated compliance, RFID in Metrc has become an ongoing pain point for cannabis operators, creating more challenges than solutions. Operators are left with the task of working around a system that, rather than simplifying compliance, requires constant vigilance and manual intervention to maintain accurate records.

Metrc's RFID tags are expensive and single-use. The reality of this is that cannabis businesses across the US pay thousands of dollars annually to purchase tags, only to throw them away at the end of the year. Since these tags contain RFID chips, the effect of this process generates a tremendous quantity of e-waste.

What is RFID?

RFID (Radio Frequency Identification) is a technology that uses radio waves to transfer data between an RFID tag and a reader, allowing for automated tracking and identification of items without requiring line-of-sight scanning. In theory, RFID streamlines the tracking of cannabis plants and products in the Metrc system, enabling regulatory oversight and compliance through automated data collection. RFID implementation in Metrc often suffers from reliability and accuracy issues, adding complexity and frustration to daily operations.

RFID Frequencies and Tag Technology

RFID operates at different frequencies, which affect its range, speed, and ability to pass through materials:

  1. Low-Frequency (LF) (125-134 kHz): Offers a short read range (typically inches to a foot) and can penetrate materials like liquids and metals more effectively, but it transmits data slowly. Examples include pet microchips and keycard fobs.

  2. High-Frequency (HF) (13.56 MHz): This frequency offers a slightly longer range (up to 3 feet) and faster data transfer than LF. Examples include contactless payment cards and Near Field Communication (NFC) scanning.

  3. Ultra-High-Frequency (UHF) (860-960 MHz): UHF RFID is the standard used in most industrial and inventory applications, including Metrc. UHF tags offer a long read range (up to 20-30 feet in optimal conditions), making them suitable for scanning large quantities of items at once. UHF tags are highly susceptible to interference from metal, liquids, and other environmental factors, which can cause read failures and reduce accuracy.

How RFID Readers (Scan Guns) Work in Metrc

RFID readers, commonly called "scan guns," are handheld devices or fixed scanners that emit radio waves to locate and read RFID tags within their range. These readers are equipped with antennas that can detect tags in the surrounding area, gathering data from multiple tags in a single scan. In theory, scan guns should simplify the process of counting, organizing, and tracking inventory.

The Metrc system’s reliance on scan guns has introduced several significant issues:

  1. Interference and Environmental Factors: UHF RFID readers are sensitive to interference from metal surfaces, water, and even other electronic devices, which are common in grow facilities. For example, the humidity in cultivation areas and the use of metal shelving can interfere with signal transmission, making it difficult to read tags reliably.

  2. Read Range Variability: While UHF RFID tags are theoretically scannable from distances of up to 20-30 feet, real-world conditions often reduce this range. Operators often have to move closer to tags or perform multiple scans to capture all required data, defeating the purpose of using RFID for rapid, hands-free tracking.

  3. Read Directionality: UHF readers typically have a directional antenna, meaning they are more effective when pointed directly at a tag. In busy environments where tags may be stacked or positioned at awkward angles, directional limitations result in missed scans and force operators to re-scan items manually.

  4. Batch Scanning Issues: Metrc promotes RFID as a tool for batch scanning, which should theoretically allow operators to capture data from multiple tags in one go. The system’s inconsistent performance often results in partial reads, where only some of the tags are successfully captured.

Common Problems with RFID in Metrc

The challenges of using RFID in Metrc stem not only from the technology itself but also from its implementation within a demanding compliance framework. Operators frequently report these issues:

  • Missed Scans: Due to environmental interference and tag placement, scans often miss certain tags, especially those blocked by metal objects or other tags.

  • Unreliable Data Capture: Inconsistent RFID performance in Metrc often results in unreliable data, forcing operators to perform manual checks.

  • High Cost of Equipment and Tags: RFID readers and tags are costly, and the additional expense can be significant for operators already working within tight margins.

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