If You're a NY Dispensary, You Better Prepare to Label Every Product In Your Store!
New York State cannabis regulations require that each item sold at a dispensary must have on its label a unique scannable code that can be used by regulators and consumers to trace the entire supply chain of that item (see page 17 - https://cannabis.ny.gov/system/files/documents/2023/03/packaginglabeling-and-marketingadvertising-guidance.pdf).
What does this mean in practice?
Simple: Retailers will need to put a sticker on each product they sell that will reflect the BioTrack UIN that for that item.Breaking this down, there are always at least 2 UINs that an item is tracked unping meder during its lifetime from manufacturing onto a retail shelf (sometimes more).
The first BioTrack UIN is the UIN that tracks the manufactured batch of the product. Whether flower from a grow, vape oil from distillation, or an edible, the batch of product that is packaged for retail sale is assigned a UIN.
The second BioTrack UIN is the UIN assigned to the group of products (all from the same originating batch) that are shipped to a retailer. This UIN is specific for the retailer (and is also unique for the shipment) and comes from sub-lotting the first batch UIN (see first bullet point).
Note: there are more complex operational workflows with additional intermediary UINs as well, and those need to be tracked as well.
When NY State Regulations say the lot unique identifier must provide a “complete history of cultivation, manufacturing, processing, testing, distribution or recall of a lot of a cannabis product”, the important part is the “distribution” component. By distribution, the state is saying that it needs to be able to track the full distribution chain, including the retail part. In other words, it must be the UIN for the retail shipment received by the retailer.
Since the retail shipment will have a different UIN from the original batch of product (in almost all cases), this means that the item being sold must have a scannable code that can provide the retail shipment UIN (not to be confused with the manifest UIN).
This is the same requirement as many other states (such as Michigan and California).
Since the retail shipment UIN (sometimes referred to as the “package UIN”) isn’t known by the manufacturer when they label the product, the UIN on the regulatory label will be the Batch UIN, and won’t meet state requirements for traceability.
To meet this state requirement, retailers must either:
sticker all products they receive, when they receive them, with a scannable UIN, or
use an item ID (such as LucidID) system QR code, if it is added to the regulatory label by the manufacturer
If you want to learn more about option 2, please ping me. I’m happy to connect you with the right people.
