The purpose of the statewide track and trace system is to accurately track marijuana products from seed to sale. This ensures marijuana products originate from plants cultivated in the regulated market and are safe for consumers and patients. Licensees are responsible for entering accurate information, and these entries must match what is shown in product packaging and advertising. Changing an existing strain name in the statewide track and trace system can be considered intentionally misusing or falsifying state-wide track and trace system tracking data as licensees are required to ensure the accuracy of information entered into the statewide track and trace system on a daily basis, and changing an identifier, such as strain name, indicates the identifier was not accurate before the change or is not accurate after the change. See 19 CSR 100-1.130(1)(M) and 19 CSR 100-1.130(2)(E)2.  

Examples of falsifying information in the statewide track and trace system:

• Introducing new strains by entering clones under a strain name that is different than the strain name of the mother plant from which the clones were taken.
• A clone is genetically identical to a mother plant; therefore, it cannot be used to create or introduce a new strain.
• Changing strain names on plants and plant batches as a way to create or introduce new strains.
• e.g. An immature plant batch entered as “Northern Lights” is later renamed “Midnight Frost” without documentation showing the batch was initially mislabeled, such as Certificate of Analysis from the original breeder indicating a mistake.
• Combining multiple strains and labeling the resulting product with a new strain name.
• e.g. Material from “Strain A” and “Strain B” is blended together and assigned a new strain name such as “Pine Ridge Blend,” even though no breeding occurred to create a genetically distinct strain.
• Combining multiple strains and labeling the result as one of the original strains.
• If the material is not strain-specific, it may not be labeled as strain-specific.
• e.g. A batch made from mixed trim of “Strain X,” “Strain Y,” and “Strain Z” is labeled as only “Strain X.”

Licensees must enter accurate strain names for seeds, clones, plants, and products into the statewide track and trace system. For a product to be strain specific, it must come from strain specific bud/flower. If mother plants, seeds, clones, or plants are later determined to have been mislabeled, the licensee may correct the strain name but must maintain documentation supporting the correction.

Cultivation licensees that conduct breeding must accurately record the seeds in the statewide track and trace system to demonstrate the genetic cross.

Examples of compliant entries:

• An entry demonstrating the cross of two known strains (Strain One x Strain Two).
•  e.g. Blue Dream x OG Kush
• An entry demonstrating the cross of one known and one unknown strain (Strain One x Strain Unknown).
• e.g. Pineapple Express x Strain Unknown
• New, unique strain name for genetic cross.
• Riverbend Haze (for a new cross such as Super Lemon Haze x Chem Dawg, when the licensee is establishing a new, original name).

Licensees that enter seeds as genetic crosses may update the strain name after the plant exhibits strain specific characteristics.

Licensees should expect DCR to request documentation to support strain-name changes. Such documentation must reflect the origin and breeding lineage of the seeds, clones, or plants affected by the change.

Generally, when recording strain names or seeking to change strain names, Licensees should understand the most important consideration for DCR is whether track and trace data is accurate, and many strain name change scenarios call into question the accuracy of track and trace data, as demonstrated above. Furthermore, DCR is aware that strain names for cannabis varietals are largely nomenclature utilized to convey expected characteristics. Until the scientific and legal frameworks for strain identification and trademarking progresses, DCR will not rely on or entertain arguments for identifying strains by genetic testing or heritage.

Please contact your compliance officer or CannabisCompliance@health.mo.gov if you have any questions.