Batch Tracking and METRC Responsibilities in Cannabis Tolling
In cannabis tolling (often called toll processing), two licensed businesses split roles: one party owns the biomass or oil and the brand, while a separate “toller” performs extraction, infusion, manufacturing, packaging, or labeling for a fee. The contract may define ownership and payment, but regulators care about something simpler: whether every movement and transformation is recorded in the state’s track-and-trace system.
Why batch tracking sits at the center of tolling compliance
In Metrc jurisdictions, traceability is built from batches, packages, and manifests. Cultivation outputs are organized as harvest batches and then converted into packages that can be transferred between licensed facilities. Manufacturing steps are captured through production batches and the creation of new packages that represent intermediates (oil, distillate, kief) or finished goods. Metrc’s production-batch best practices emphasize documenting transformations, maintaining accurate source-package linkages, correct item categorization, and detailed ingredient records.
Tolling increases risk because physical custody changes while legal ownership may not. The compliance test is whether Metrc mirrors physical reality: who has custody, what was combined, what was converted, what became waste, and what is ready to move again.
Metrc responsibilities that matter most in tolling
1) The license that “touches” the product must track it. State seed-to-sale programs commonly place responsibility for tracking inventory on the licensed processor and its employees while cannabis is on that premises. A toll manufacturer cannot run a customer’s material “off book” and reconcile later.
2) Transfers are the legal handoff. When customer-owned material moves to the toller, it should move on a Metrc transfer manifest, be received, and be matched to the correct packages and quantities. METRC transfer best-practice bulletins emphasize double-checking packages added to manifests because errors can create compliance problems and “locked” inventory. Tolling requires at least two compliant transfers: inbound to the toller and outbound after processing.
3) Production batches must preserve lineage. When the toller combines packages, extracts oil, infuses an edible mix, or converts bulk into finished SKUs, the transformation should be recorded through production batches and resulting packages so regulators can trace each output back to its inputs. Metrc bulletins describe production batches as the mechanism for documenting these manufacturing transformations in-system.
4) Testing status must match state rules before onward distribution. Regulators publish compliance guidance tying what can be transferred or sold to test results and statuses reflected in Metrc. In tolling, decide whether the toller or the customer coordinates sampling and lab results—but ensure the correct Metrc package carries the required test status before it leaves the manufacturing chain.
5) If your state supports it, document the tolling agreement inside Metrc. Some Metrc states provide a workflow to upload or associate tolling agreements with transfers; Metrc has issued bulletins describing this feature for certain jurisdictions. Treat it like part of the shipping checklist, not optional “back office” work.
Controls that prevent batch-tracking failures
Write a tolling SOP that assigns who creates manifests, who receives them, who creates production batches, and who prints/applies package labels. Reconcile physical counts to Metrc daily to catch receiving and unit-of-measure mistakes early. Restrict Metrc permissions for adjustments, voids, and batch creation to trained staff, and review audit logs. Finally, put compliance into the contract—timelines for Metrc entries, QA holds, and dispute rules for losses, waste, or failed tests—while remembering the contract supports compliance but doesn’t replace it.