URGENT UPDATE: Oregon Medical Marijuana Growers

Prepare for Tracking By July 1

These marijuana growers in Oregon must begin tracking their cannabis from seed-to-sale. 

In a recent memo distributed by the Oregon Liquor Control Commission, medical marijuana growers in Oregon will be required to use the Oregon Cannabis Tracking System (CTS) starting July 1, 2018

This change in tracking, outlined in the Oregon Senate bill 1544, stipulates for all Oregon Medical Marijuana Program (OMMP) medical marijuana grow sites—with three or more patients—to begin using CTS tracking by the July 1 deadline.  Medical marijuana grow sites limited to two or fewer growers and two or fewer patients are exempt from using CTS.

More than 1800 licensees in Oregon’s Recreational Marijuana system are already using CTS which tracks marijuana and marijuana products from seed to sale.  Beginning in July, these marijuana growers must begin tracking their cannabis from seed-to-sale to ensure the marijuana they grow for medical marijuana patients is tracked and reported.  This requirement is most likely a response to Oregon’s documented issues with the black market, in tandem with Attorney General Jeff Sessions’ repeal of the Cole Memo.

How Do I Comply?

A series of information sessions and workshops are being offered to help growers registered with the OMMP begin the sign-up process to use CTS.  Grow sites required to use CTS can take the following steps to prepare for this change:

  1. Designate one grower at the grow site address as the grow site administrator (GSA)

  2. Consider attending the following outreach, workshop or informational sessions:

  • Community outreach session administered by the Oregon Healthy Authority (OHA) for registered medical growers to help understand reporting and tracking requirements for all grow sites.

  • Information session for registered medical marijuana growers, processors, and dispensaries on the requirements for using CTS. These sessions are administered by the OHA and the Oregon Liquor Control Commission (OLCC).

  • Workshop for OMMP registrants explaining how to use CTS.

Additional Information

In addition to the change in tracking, the memo highlights the following:

  • GSAs will be allowed to sell up to 20 pounds of marijuana into the OLCC regulated recreational marijuana system in a 12 month period.

  • GSAs must provide proof of legal access to water before the marijuana can be sold into the OLCC market. This sell-in option applies to a grow site as a whole, so a grow site with four growers would only be allowed to sell a total of 20 pounds into the recreational market, not 80 pounds.

  • In July 2018, the OLCC will begin auditing OMMP grow sites, processors, and dispensaries subject to tracking in CTS.

  • Later in 2018, OLCC inspectors will begin visiting OMMP grow sites required to use CTS to verify CTS tracking information, check to make sure CTS is being used properly, and look for any other violations. However, because OHA regulates the OMMP program, OHA will determine any enforcement based on investigations conducted by OLCC.

For additional information or to learn about the informational sessions, visit the OMMP website. If you need assistance or advice, contact Attorney Lindsey Weidenbach, at JDSA Law.