Division of Cannabis Regulation
Guidance Document – 9.20.24
Topic: Retesting of Final Marijuana Product on Administrative Hold Due to Non-Compliant Mandatory Testing
The Division of Cannabis Regulation (DCR) has received questions related to retesting final marijuana product subject to administrative holds, and resulting public recall, due to non-compliant mandatory testing.
Can final marijuana product producers retest final marijuana product for reentry into the regulated market?
Yes. Licensees with final marijuana product on administrative hold, and resulting public recall, due to non-compliant mandatory testing should request to transfer their product back to the origin facility of the product. Only marijuana product that has been transferred to, is in control of, and is available for sampling at the origin facility, where the final product was produced, shall be considered for retesting.
Licensees wishing to retest product on administrative holds, and resulting public recall, due to noncompliant mandatory testing should email their assigned compliance officer and copy CannabisCompliance@health.mo.gov.
Licensee should only include source tags submitted for mandatory testing. DCR will not consider new package tags with this submission for retesting. Tags not submitted in the request will remain on hold and be subject to quarantine, storage, or voluntary destruction.
After receiving DCR written approval, licensees must repackage all returned product into a new tag using a production batch. At that time, the licensee may request mandatory from another certified marijuana testing licensee. Any product that fails testing may be remediated, retested or destroyed per 19 CSR 100- 1.110(10)(B).
Additionally, the licensee must ensure the final marijuana product packaging meets all requirements of 19 CSR 100-1.120 Packaging, labeling, and Product Design. Including updating the compliance label with new test results. A sticker containing the required information and placed in the approved location is acceptable.
Can a facility transfer marijuana product on administrative hold to another facility?
Yes. Licensees wishing to transfer product on administrative hold should fill out the Administrative Hold Product Transfer Request document. Licensees should email the completed document to their assigned compliance officer and copy CannabisCompliance@health.mo.gov.
Origin licensees should combine all received product into a single tag using a production batch to sever any previous testing ties.
Can a licensee voluntarily destroy product on administrative hold within their facility?
Yes. Licensees wishing to voluntarily destroy marijuana product on administrative hold should complete and submit the Administrative Hold Product Voluntary Destruction Request document. Licensees should email the completed document to their assigned compliance officer and copy CannabisCompliance@health.mo.gov .
For questions, please contact the licensee’s assigned compliance officer or CannabisCompliance@health.mo.gov . Licensees may find additional information on our website: Facility Communications and Guidance.