Plants: To Tag, or Not To Tag

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Plant tagging is at the core of track and trace for the cannabis industry while also being the thorn in the side of many cultivators and microbusiness operators. While unique tags are required on every harvested plant, a common question is, “When is a plant tag required?” As a general rule of thumb, when in doubt… tag. Regulators will not penalize you for using too many tags, but they will penalize you during audits for not having enough tags and/or having untracked plants.

Tagging every single clone/seedling in the building may not be feasible as some plants may not live through the entire growth cycle. So, let’s take a look at some of the typical cases we with Cortex have encountered while helping cultivators and microbusinesses rollout business operations software.

I. Plants grown from Seeds or Cones

Not all seeds or clones will result in a viable plant that can later be harvested and sold as either flower or trim based products. These fledgling plants are considered to be a plantings batch in the METRC lingo. The requirement is that a plantings batch must have been planted all on the same day and be of the same strain. This batch, which cannot exceed 100 plants, is tagged with 1 METRC tag. It is the responsibility of the cultivator to tag each plant in this batch with a label that has the same barcode as the METRC tag.

In this case, the METRC tag keeps track of the live and dead count in the batch. Any other data recorded for one plant is assumed to also affect all other plants in the batch. As the plant grows, it will cross the threshold where the plant is expected to be viable through maturity and harvest. At this threshold, the plant is supposed to be tagged with its own unique METRC tag. The METRC tag will stay with the plant all the way to harvest.

So, what is the threshold to individually tag a plant? There has been a lot of discussion among cultivators if the plant needs to be in flowering before getting a unique tag or in veg as expected by the METRC platform. Through trial and error at multiple indoor cultivation sites, we’ve found that a simple rule of thumb that is easy to implement into the cultivation workflow is to tag the plant when it is moved to the canopy grow room. A more technical guidance is, once the plant exceeds 10” in height from the soil, tag it.

II. Immature plants bought from nursery

In the case of a nursery, the most common case is to buy immature teens. These teens will have 1 METRC tag per 100 units of the same strain and each pot will have some kind of tag or label that has the same barcode as the METRC tag in the shipping manifest. When these plants are taken into a facility, they are almost always moved into a canopy grow room. For this case our suggested workflow is

1 – Count the plants and verify against the shipping manifest

2 – Put a new METRC tag on each plant as it is being moved to the grow room.  

Plant tagging is a necessary step in regulatory track and trace for the cannabis industry. Although it is a labor-intensive process, it can easily be added into the cultivation workflow. A small investment in time to figure out where this process fits your operation best will save you headaches, aggravation and liability during regulatory body inspections of your facility.