<!-- TITLE: Transfers --> <!-- SUBTITLE: Transferring Product in Metrc (Last Updated 11/22/2021) --> # Compliance Bulletins <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_2021_02.pdf' target='_blank'>Compliance Education Bulletin CE2021-02</a> Bulletin CE2021-02 covers the following issues: * Recording Average Harvest Weights in Metrc * Virtual Transfer Request Form (replaces information from Bulletin CE2020-02) <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_2020_02.pdf' target='_blank'>Compliance Education Bulletin CE2020-02</a> Bulletin CE2020-02 covers the following issues: * Transfer Rule and Common Mistakes * Virtual Transfer Guidance (updated information in Bulletin CE2021-02) * Rejecting Transfers Guidance * Stuck’ Manifest Guidance * CSV Upload for Packages on a Manifest # Transfer Types When completing a manifest, you will be required to choose what type of transfer it is in Metrc. There are two types of transfers: * Transfer: Used between facilities that are under the same ownership structure, where no money is exchanging hands or to send a shipment consisting only of trade samples * Wholesale Transfer: Used between unrelated facilities, where money is being exchanged for the product. If a manifest contains a mix of priced items and trade samples, you may enter the trade samples on the "wholesale transfer" manifest using a price of $0.01 in order to avoid creating an additional manifest. # Transfer Requirements All transfers require that the product be put in a container with an assigned Metrc package tag prior to transport. > Manifest Requirements: All passengers must have a valid marijuana worker permit, and be listed on the manifest, per <a href= 'https://secure.sos.state.or.us/oard/view.action?ruleNumber=845-025-7700' target='_blank'>OAR 845-025-7700</a> and <a href= 'https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=254277' target='_blank'>OAR 845-025-5500</a>. # Manifest Transporter Information Based on feedback from our proactive Metrc data reviews, this section walks through how to select the correct transporter license for the driver when creating the manifest in Metrc. Begin in the Licensed Transfers section of Metrc. Select the “new transfer” button and choose the transfer type (Wholesale was used for this example): <br><img src=/uploads/transfers/tpic-1.jpg height="500"> The first screen option to select is the Transporter License. This field defaults to the facility creating the transfer, but should be updated if needed to reflect the license that is physically transporting the product. <br><img src=/uploads/transfers/tpic-2.jpg height="600"> By hovering over the magnifying lens you can verify the transporter details: <br> <img src=/uploads/transfers/tpic-3.jpg height="500"> To select a different license you can start typing the license number: <br> <img src=/uploads/transfers/tpic-4.jpg height="500"> Or you can click the magnifying lens to select your choice from a list of licenses then clicking “select” to return to the manifest. <br> <img src=/uploads/transfers/tpic-5.jpg height="500"> Once back on the manifest page, fill in the associated driver and vehicle information, then complete the remaining steps needed to register your manifest: <br> <img src=/uploads/transfers/tpic-6.jpg height="600"> To ensure that your driver and transporter are correct, you can verify them on the Licensed Transfer summary screen and make any needed edits prior to the driver leaving the facility: <br> <img src=/uploads/transfers/tpic-7.jpg height="300"> # Manifest Business Contact Information The manifest contains certain pre-populated information for the originating licensee including: * Name * Address * Phone Number * Contact Phone Number This information comes directly from the Facility Manager area of our Online Licensing System and cannot be edited directly in Metrc. To make changes to this area, please contact <a href= 'https://wiki-or.metrc.com/compliance-contacts#licensing-renewals-inspections-and-investigation-questions' target='_blank'> Licensing</a>. # Intermediary Stops/Cold Calling **NEW RULES EFFECTIVE FEBRUARY 1, 2020!** Please refer to <a href = 'https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_2020_01.pdf' target ='_blank'> Bulletin CE-2020-21</a>, Implementation of 2019 Legislative Changes and Technical Rule Amendments for details. In January of 2020, the Oregon Liquor and Cannabis Commission adopted changes to Oregon Administrative Rules Chapter 845, Division 25. These include general clarifications and changes regarding how recreational marijuana licensees should generate manifests in CTS. These changes also specifically address how licensees must generate manifests with respect to the practice of “cold calling” or “hopscotching” product from one location to multiple destinations. This refers to the practice of a licensee or representative leaving a facility with several different packages of marijuana items that they are planning to take to several different licensees as potential buyers who may wish to purchase the product. This guide details how cold calling to intermediary stops must be done to remain in compliance with OLCC rules. To remain compliant, licensees may only undertake the activities described in this guide if: • The “route” as recorded on the manifest in CTS includes the trade name, license number, address, and estimated arrival time for each licensed premises that will be visited as an intermediary stop; • The amount of marijuana in the vehicle is no greater than: o 25 pounds of usable marijuana; o 1 pound of concentrate or extract; and o 1,000 units of any individual cannabinoid product; • All marijuana items are delivered to licensees or returned to the originating location within 60 hours of departure from the originating licensee; and • All overnight stops are identified in the manifest route. Cold calling to intermediary stops is done by a licensee creating a “circular manifest” to themselves, in which the same license number is both the originating and receiving license. The licensee will fill in the planned route information on the manifest with the complete route including directions and each licensed premises that is intended to be stopped at during the trip. For more information on "hopscotching" or cold calling with a manifest, please view the <a href = 'https://www.oregon.gov/olcc/marijuana/Documents/CTS/Intermediary_Stops_Transfer_Guide.pdf' target = 'blank'> Intermediary Stop Transfer Guide </a>. # Advance Notice Certain deliveries must be planned and recorded in Metrc 24 hours prior to being transferred to a Retail Licensee. These items are outlined in <a href= 'https://secure.sos.state.or.us/oard/view.action?ruleNumber=845-025-7700' target='_blank'> OAR 845-025-7700 (4)</a>. # Receiving a Transfer in Metrc In order for a transfer to be completed, it must first be Received in the CTS by the destination license or the inventory will not reconcile between facilities. At the time a transfer is delivered, the receiving entity may opt to reject any package on the manifest. There are a few methods available to the user in Metrc when accepting or rejecting packages. The screen shots below attempt to cover the options and potential pitfalls associated with the types of actions. As usual, it is important to pay attention to the details when accepting or rejecting items on a manifest in order to avoid the need for a virtual transfer or package adjustment at a later time, both of which are potential flagged items for additional compliance review. Once the **Receive** button is clicked, the following screen opens and if everything is good to go, the receiver can just click the **Receive Transfer** button at the bottom and all packages will transfer to the receiver's inventory. <br> <img src=/uploads/transfers/man-1.png height="400"> If a package needs to be rejected, it is imperative that the **reject** box is clicked. You will know this step has been completed when the **reason for rejection** area opens. <br>If this area does **not** appear and you click **Receive transfer** the manifest will be received and not rejected. <p><img src=/uploads/transfers/man-2.png> You can reject every package on the manifest using the template (green check) option. First, click the **reject** checkbox, then click the green check to select every package on the manifest for rejection as shown in the example below. <p> <img src=/uploads/transfers/man-3.png height="400"> # External Transfers ## Producers - Seed inventory from an unlicensed Oregon Location This is new for 2022 and additional information on how to navigate this type of external transfer can be found <a href = 'https://wiki-or.metrc.com/transfers/seed-transfers' target='_blank'> here</a>. ## Initial Start-Up Inventory As a producer there are two types of “start-up inventory” you are allowed to have: * Seeds and Immature Plants brought into your inventory during the first 90 days of licensure * Seeds, Plants (immature and mature), and Usable Marijuana that are approved by OLCC as part of your <a href= 'https://www.oregon.gov/olcc/marijuana/Documents/Licensing_Forms/mj_opt_pro_inventory_transfer.pdf' target='_blank'>Inventory Transfer Request</a> prior to licensure <a href='https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=245005' target='_blank'>OAR 845-025-2060</a> <a href='https://www.oregon.gov/olcc/marijuana/Documents/Licensing_Forms/Inventory_Transfer_Guide.pdf' target='_blank'> Processor & Retailer Inventory Transfer Guide</a> <a href='https://www.oregon.gov/olcc/marijuana/Documents/CTS/Producer_Inventory_Transfer_Metrc_Instructions.pdf' target='_blank'> Producer Inventory Transfer Guide</a> ## Medical Grow Site Transfers All transfers to and from patients at a medical grow site are done in Metrc through an external transfer. To bring plants into Metrc for a patient a Medical grow site would use the incoming external transfer type "Transfer from Medical Patient", input the patient's Oregon Medical Marijuana Program (OMMP) Card number and the number of plants they are growing for that patient. To send the usable Marijuana to the medical patient a grower would use the outgoing transfer type "Transfer to Medical Patient", input the patient's OMMP Card number and add the package of flower to the transfer. Transfers to and from medical grow sites that involve any patient information should be kept anonymous and confidential. For that purpose the names, phone numbers, and planned route should be kept to something generic, with no personal identifiable information appearing on the transfer manifest. This is to protect the patient's privacy as well as the privacy of the medical grow site. # Transfers from Medical Grow Sites into Recreational Market Medical marijuana grow sites that are subject to tracking in METRC are allowed to transfer limited amounts of usable marijuana to recreational marijuana Processor or Wholesaler licensees. A medical marijuana grow site must register for this privilege and be approved by the OLCC prior to making any of these transfers. The registration form can be found under the <a href= 'https://www.oregon.gov/olcc/Pages/ommp_product_transfers.aspx' target='_blank'> Marijuana Product Transfer</a> page. For the specific law see <a href= 'https://www.oregon.gov/olcc/pages/ommp_tracking.aspx#Forms_&_Publications' target='_blank'> ORS 475B.825</a>. <a href= 'https://www.oregon.gov/olcc/marijuana/Documents/Med/med_opt_gsa_info.pdf' target='_blank'> Grow Site Transfer Information</a> <a href= 'https://www.oregon.gov/olcc/marijuana/Documents/Licensing_Forms/mj_opt_pro_transfer_agreement.pdf' target='_blank'> Personal Inventory Transfer Agreement</a> <a href= 'https://www.oregon.gov/olcc/marijuana/Documents/Med/med_opt_gsa_transfer_rev20180629_FILLABLE_2.pdf' target='_blank'> Registration for Medical Grow Site Transfers to Recreational Processors and Wholesalers</a> <a href= 'https://www.oregon.gov/olcc/marijuana/Documents/Licensing_Forms/mj_opt_pro_prmg_info.pdf' target='_blank'> PRMG Information Disclosure</a> More complete information on these types of transfers can be found in <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_1808.pdf' target='_blank'> Compliance Education Bulletin CE2018-08</a> published November 8, 2018. # Virtual Transfers The OLCC CTS Team now has the functionality to facilitate virtual transfers on your behalf. ***The process below should be followed in lieu of creating a virtual manifest within Metrc. A virtual transfer created in CTS without written pre-approval may result in a compliance action.*** The use of virtual transfers are limited and require OLCC approval. The use of virtual transfers does not substitute for a licensee’s due diligence in reporting information into CTS accurately. **Virtual transfers are approved by the OLCC when one licensee has a package physically while another licensee has control of the package in Metrc.** Virtual transfers are not approved when product or tags need to physically change locations. Virtual transfers do not correct product categories. Transfers between businesses located on the same premises should not be recorded as virtual transfers and do not require pre-approval. However, transfers between licenses sharing the same location must be recorded and tracked in CTS as required by rule. We recommend that co-located facilities use “co-located handoff” or “transfer within same building” or similar wording rather than “virtual” on their manifests. Using "virtual" will flag manifests for review by compliance staff. Complete the request form below or <a href="https://forms.office.com/Pages/ResponsePage.aspx?id=fvjHqQys_EW8EkgK0LTvRHGMef_eW7lHqAzXx1iiFNtURThXV1QwWDFVNERBQzVMVUU5UUVTOVpMVy4u" target='_blank'>click here to open it in a new tab.</a> >Virtual Transfers are not approved when product or tags need to change locations. >A Metrc ticket number must be obtained before submitting your request. Please email <a href="email@example.com">firstname.lastname@example.org</a> to request a ticket number. >**Please submit one request per impacted manifest and per destination.** >Licenses, including labs, with **test sampling issues should NOT use this form** and should instead reach out to the <a href="mailto:Marijuana.CTS@oregon.gov">CTS team</a>. >**Only click submit once.**</br> <center><iframe width="640px" height= "480px" src= "https://forms.office.com/Pages/ResponsePage.aspx?id=fvjHqQys_EW8EkgK0LTvRHGMef_eW7lHqAzXx1iiFNtURThXV1QwWDFVNERBQzVMVUU5UUVTOVpMVy4u&embed=true" frameborder= "0" marginwidth= "0" marginheight= "0" style= "border: none; max-width:100%; max-height:100vh" allowfullscreen webkitallowfullscreen mozallowfullscreen msallowfullscreen> </iframe></center> # Related Compliance Bulletins: <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_2020_02.pdf' target='_blank'>Compliance Education Bulletin CE2020-02</a> Bulletin CE2020-02 covers the following issues: o Transfer Rule and Common Mistakes o Virtual Transfer Guidance o Rejecting Transfers Guidance o Stuck’ Manifest Guidance o CSV Upload for Packages on a Manifest <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_1801.pdf' target='_blank'>Compliance Education Bulletin CE2018-01</a> Metrc functionality enhancements o Viewing item information prior to receipt of transfer; and o External Transfers <a href='https://www.oregon.gov/olcc/marijuana/Documents/Bulletins/Compliance_1713.pdf' target='_blank'> Compliance Education Bulletin CE2017-13</a> o Marijuana Product Transfers # Wiki Feedback If you encounter a technical problem or just want to provide general comments regarding your visit to the Oregon Metrc Wiki, we welcome your <a href="mailto:Marijuana.CTS@oregon.gov?subject=OLCC Metrc Wiki Feedback">Feedback</a>.