Guidance Document – October 15, 2026
The purpose of the statewide track and trace system is to accurately track marijuana products from seed to sale to ensure the safety and integrity of the regulated market. To improve service and efficiency for the industry, the Division of Cannabis Regulation (DCR) is introducing an updated process for virtual transfers. This update streamlines the way licensees address product transfer errors by removing unnecessary administrative steps and allowing for independent correction. This process cannot be used for discrepancies.
Licensees must ensure that all information entered into Metrc is accurate on a daily basis. As a result, they should routinely identify and correct any errors. The key distinction between an error and a discrepancy is that an error can be explained (often with supporting documentation); the licensee is able to identify the issue, and account for the difference between the physical inventory and the inventory recorded in the statewide track-and-trace system. If documentation or a clear explanation exists describing the actions that led to the issue and how it was resolved, the situation is considered an error. In contrast, a discrepancy is a difference that cannot be accounted for.
The New "Virtual Transfer" Transfer Type in Metrc
Metrc has developed a dedicated transfer type called “Virtual Transfer”. A Virtual Transfer allows licensees to independently resolve transfer errors directly within the track and trace system using a manifest specifically designed for virtual transfers. This simplified manifest is designed to reduce the data entry burden on facility staff. Under this updated process:
- Licensees independently determine the need for a virtual transfer. The initiating and receiving licensees coordinate as needed to complete the process in Metrc without requiring initial DCR or Metrc intervention.
- The new “Virtual Transfer” type must be utilized for all virtual transfers.
- Virtual Transfers are intended for situations in which a transfer error is identified after the original transfer has been received and the error can no longer be corrected through the standard rejection process.
Compliance
DCR continues to utilize reporting data to monitor overall compliance and review these transfers for any irregularities. While the new process grants licensees the autonomy to correct transfer errors independently, DCR maintains oversight to ensure track and trace accuracy. For complex scenarios or discrepancies requiring guidance, please contact your compliance officer for assistance.
Next Steps for Licensees
Licensees should review their internal inventory and transfer standard operating procedures (SOPs) to integrate the new Metrc transfer type into their daily workflows. Facility staff responsible for track and trace data entry should familiarize themselves with the virtual transfer manifests to ensure continued compliance with daily tracking requirements. For details on how to utilize the new Metrc transfer type, please refer to Metrc Bulletin MO_IB_0051.
Please contact your licensee’s compliance officer or CannabisCompliance@health.mo.gov if you have any questions.