Seed-to-Sale Tracking - Oregon Liquor Control Commission

Effective September 20, 2016




CTS Requirements
(1) A licensee must:
(a) Use CTS as the primary inventory and recording keeping system.
(b) Have a CTS account activated and functional prior to operating or exercising any privileges of the license and must maintain an active account while licensed.

(2) A licensee must have at least one license holder who is a CTS administrator. A licensee may authorize additional license holders or licensee representatives to obtain Administrator accounts.
(3) In order to obtain a CTS administrator account, a license holder must attend and successfully complete all required CTS training, except as provided in section (4) of this rule. The Commission may also require additional ongoing, continuing education for individual administrators to retain his or her CTS administrator account.
(4) A licensee may designate licensee representatives as CTS users. A designated user must be trained by a CTS administrator in the proper and lawful use of CTS. Notwithstanding section (3) of this rule a licensee may designate a licensee representative to attend and successfully complete required CTS training so long as both the licensee and the designated representative obtain CTS administrator accounts.
(5) A licensee must:
(a) Maintain an accurate and complete list of all CTS administrators and CTS users for each licensed premises and must update the list when a new CTS user is trained.
(b) Train and authorize any new CTS users before those users are permitted to access CTS or input, modify, or delete any information in CTS.
(c) Cancel any CTS administrator or user from an associated CTS account if that individual is no longer a licensee representative or the administrator or user has violated OAR 845-025-7500 to 845-025-7590.
(d) Correct any data that is entered into CTS in error.
(6) A licensee is accountable for all actions licensee representatives take while logged into CTS or otherwise conducting inventory tracking activities.
(7) Nothing in this rule prohibits a licensee from using secondary separate software applications to collect information to be used by the business including secondary inventory tracking or point of sale systems. If a licensee uses a separate software application that links to the CTS system it must get approval from the CTS vendor contracting with the Commission and the software application must:
(a) Accurately transfer all relevant CTS data to and from CTS for the purposes of reconciliations with any secondary systems.
(b) Preserve original CTS data when transferred to and from a secondary application.
(8) If at any point a licensee loses access to CTS for any reason, the licensee must keep and maintain comprehensive records detailing all tracking inventory activities that were conducted during the loss of access.
(a) Once access is restored, all inventory tracking activities that occurred during the loss of access must be entered into CTS.
(b) A licensee must document when access to the system was lost and when it was restored.
(c) A licensee may not transport any marijuana items to another licensed premises until such time as access is restored and all information is recorded into CTS.
Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100, 475B.110 & 475B.560
Stats. Implemented: ORS 475B.150
Unique Identification (UID) Tags

(1) A licensee must:
(a) Use UID tags issued by a Commission-approved vendor that is authorized to provide UID tags for CTS. Each licensee is responsible for the cost of all UID tags and any associated vendor fees.
(b) Have an adequate supply of UID tags at all times, except that the licensee is not required to have UID tags during the first ten calendar days of licensure so long as UID tags have been ordered and are in transit to the licensee.
(c) Tag individual marijuana plants with a UID tag no later than when each plant reaches a height of eight inches, and properly tag all other inventory with a UID tag pursuant to the system requirements of CTS.
(d) Place tags in a position that can be clearly read by an individual standing next to the item and the tag must be kept free from dirt and debris.
(2) A licensee may only tag and package together identical items for transport to another licensee, except for mixed lots of usable marijuana, cannabinoid concentrates or extracts that are transferred to a processor license to be processed.
Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100, 475B.110 & 475B.560
Stats. Implemented: ORS 475B.150
CTS User Requirements
(1) A licensee and any designated CTS administrator or user shall enter data into CTS that fully and transparently accounts for all inventory tracking activities.
(2) A licensee is responsible for the accuracy of all information entered into CTS.
(3) An individual entering data into the CTS system may only use that individual’s CTS account. Each CTS administrator and CTS user must have a unique log-on and password, which may not be used by any other person.
(4) A violation of this rule is a Category III violation. Intentional misrepresentation of data entered into the CTS system is a Category I violation.
Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100, 475B.110 & 475B.560
Stats. Implemented: ORS 475B.150
System Notifications
A licensee must:
(1) Monitor all compliance notifications from CTS and resolve the issues detailed in the compliance notification in a timely fashion. A licensee may not dismiss a compliance notification in CTS until the licensee resolves the compliance issues detailed in the notification.
(2) Take appropriate action in response to informational notifications received through CTS, including but not limited to notifications related to UID billing, enforcement alerts, and other pertinent information.
Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100, 475B.110 & 475B.560
Stats. Implemented: ORS 475B.150

Cultivation Batches
(1) A producer must establish cultivation batches consisting of marijuana plants less than 8 inches tall, seeds and tissue cultures and assign each cultivation batch a unique identification number.
(2) A cultivation batch may not have more than 100 marijuana plants less than 8 inches tall.
(3) A producer may have an unlimited number of cultivation batches at any one time.
Stat. Auth.: ORS 475B.025
Stats. Implemented: ORS 475B.070 & 475B.150
Reconciliation with Inventory
(1) All licensees must:
(a) Use CTS for all inventory tracking activities at a licensed premises;
(b) Reconcile all on-premises and in-transit marijuana item inventories each day in CTS at the close of business pursuant to system requirements; and
(c) Record all required information for seeds, usable marijuana, cannabinoid concentrates and extracts by weight.
(d) Record the wet weight of all harvested marijuana plants immediately after harvest.
(e) Record all required information for cannabinoid products by unit count but must also record the weight per unit of a product.
(2) The requirements in section (1)(b) of this rule do not apply during the first ten calendar days of licensure so long as the license has ordered UID tags and the UID tags are in transit to the licensee.
(3) The requirements in section (1)(b) of this rule do not apply to marijuana items held by a laboratory licensee that are undergoing analytical testing required by these rules or OAR 333-007-0300 to 333-007-0490 so long as the marijuana items do not leave the laboratory’s licensed premises and are reconciled on the same day that the analytical testing concludes.
(4) In addition to the requirements in section (1) of this rule retailers must record the price and amount of each item sold to consumers and the date of each transaction in CTS at the close of every business day.
Stat. Auth.: ORS 475B.025, 475B.
Stats. Implemented: ORS 475B.150
Inventory Audits
The Commission may perform a physical audit of the inventory of any licensee at the agency’s discretion and with reasonable notice to the licensee. Variances between the physical audit and the inventory reflected in CTS at the time of the audit, which cannot be attributed to normal moisture variation in usable marijuana, are violations. The Commission may impose a civil penalty, suspend or revoke a licensee for violation of this section.
Stat. Auth.: ORS 475B.025, 475B.070, 475B.090, 475B.100 & 475B.110
Stats. Implemented: ORS 475B.160