As a licensed transporter of cannabis for sale, are you responsible for errors or discrepancies between what is listed on the required paperwork and the goods being transported?
The short answer is: No.
According to the Bureau of California Cannabis Control § 5314, “the distributor is responsible for any discrepancies between the shipping manifest and the cannabis goods in its possession during transport, and subject to any enforcement or disciplinary action related to such discrepancy.”
But that doesn’t mean you’re off the hook as a transporter of cannabis products. Before we get to the shipping manifest requirements, there are a few key requirements a transporter must keep in mind.
Key requirements when transporting cannabis for sale
- Anyone transporting cannabis for sale must hold a distributor license or be an employee or contractor of a licensed distributor.
- You must also have a motor carrier permit.
- The cannabis goods being transported must be stored in a locked box, container or cage that is secured to the inside of the vehicle or trailer. The locked container also has to be separate from the body of the vehicle or trailer.
- The vehicle must have a Global Positioning System (GPS) device so the geographical location of the delivery can be identified at all times.
- Anyone employed by the licensee or anyone acting on behalf of the licensee, must wear a laminated or plastic-coated identification badge
You don’t want to make the mistake of overlooking these and other requirements when transporting cannabis. It’s also a good idea to be aware of the shipping manifest requirements the distributor you are transporting for must meet.
Shipping manifest requirements
Before transporting any cannabis goods, a licensed distributor must generate a document listing the cargo and passengers of the vehicle, known as a “shipping manifest” through the track and trace system.
The California Cannabis Track-and-Trace (CCTT) system is used statewide to record the inventory and movement of cannabis and cannabis products. Licensees are required to use the system to record, track, and maintain information about their cannabis and cannabis-product inventories and activities.
A shipping manifest must include:
- The name, license number, and address for:
- The licensee who possesses the cannabis goods
- The licensee transporting the cannabis goods
- The licensee receiving the cannabis goods
- Name and license number of any licensee involved in the activity or transaction who is not shipping, transporting, or receiving the cannabis goods
- Date and time of activity
- If cannabis goods are being shipped from multiple locations in one transport vehicle, the date and time of departure from each location
- Estimated date and time of arrival at each receiving location
- Driver’s license number for any person driving the transport vehicle
- Make, model, and license plate number of the transport vehicle
- Name and type of cannabis goods being transported
- Unique identifier
- Amount of cannabis goods in weight or unit count
What else to know as a transporter
You want to make sure all your bases are covered when transporting cannabis goods. Below are other important requirements to know about the shipping manifest.
- A physical copy of the shipping manifest must be carried in the transport vehicle at all times while transporting cannabis goods. This is important, because upon request, the shipping manifest must be provided to law enforcement and Department of Consumer Affairs agents.
- The shipping manifest must be completed by the distributor and transmitted in the track and trace system to the Bureau and receiving licensee.
- If the distributor has not yet obtained access to the track and trace system, the licensee shall transmit the shipping manifest to the Bureau and receiving licensee by electronic mail.
Once the cannabis goods are delivered, the receiving licensee must make sure that the goods received match the shipping manifest and accept the goods in the track and trace system. If there is a discrepancy between the cannabis goods received and the shipping manifest, the receiving licensee must document the discrepancy in the track and trace system and any other relevant records.
There aren’t any excuses when it comes to the shipping manifest. You either have it or you don’t, and it contains what’s listed or it doesn’t. Even if you personally aren’t responsible for any errors or discrepancies with the shipping manifest, you can be responsible for making sure the shipping manifest is attainable and accurate.
Transporting cannabis products safely and legally is critical to the success of your business. With the new California regulations in place, secure transport is crucial to stay compliant and avoid getting ticketed – or even worse – losing your license.
You should be able to transport your products with confidence, not worrying about the proverbial “lights in your rear-view mirror.”
*To see the full description of compliance requirements review the California Code of Regulations to make sure the transportation of your cannabis product is being done safely and legally.
Failure to Comply with Inventory Documentation and Reconciliation Requirements
(16 CCR §§ 5051, 5309 and 5423- 5424)
Failure to Comply with Track and Trace Reporting and System Reconciliation Requirements
(16 CCR §§ 5049-5051)
Failure to Comply with Shipping Manifest Requirements
(B&P §§ 26067 and 26070 16 CCR § 5314)
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