The Department of Cannabis Control (DCC) has adopted emergency regulations to implement track-and-trace requirements imposed by Assembly Bill 195. These regulations require retail sales made via delivery to be recorded in the California Cannabis Track and Trace system (CCTT).

To allow for the development and implementation of technical changes to meet these requirements (for example, third-party software development), the regulations require that delivery-specific information be entered into CCTT beginning no later than April 1, 2023. Prior to April 1, 2023, the regulations provide more flexibility for retailers to record required information related to deliveries—though deliveries must still be entered into CCTT (in the same manner as other retail sales) within 24 hours.

The complete text of DCC’s regulations can be found on the DCC website. The requirements addressed in this guidance can be found in sections 15049.3 and 15418.

This guidance is intended to assist licensees in understanding these new regulatory requirements but does not alter those requirements in any way.

Specifically, this guidance explains:

• What delivery information must be entered into CCTT beginning no later than April 1, 2023
• How licensees can comply with these regulatory requirements between now and April 1, 2023, if they are not immediately able to begin recording deliveries in CCTT

Requirements beginning April 1, 2023

Beginning April 1, 2023, all retail sales made via delivery must be entered into CCTT as follows:

Creating an inventory delivery ledger

Retailers conducting deliveries must create a delivery inventory ledger in CCTT for each delivery trip. The ledger must be created before a delivery employee leaves the licensed retail premises for that delivery trip.

CCTT will prompt users to enter the information required to create a delivery inventory ledger. Specifically, CCTT will prompt users to enter:

• The delivery employee’s name, employee ID, and driver’s license number.
• The delivery vehicle’s make, model, and license plate number.
• The UID(s) assigned to those cannabis goods, and the number of units associated with each UID on the delivery inventory ledger. The item name and category of each cannabis good to be carried on the delivery trip will automatically be associated to each UID.
• The UID(s) of any cannabis goods ordered by customers and processed by the licensed retailer prior to the delivery employee leaving the licensed retail premises.

After the required information is entered, CCTT will generate an electronic delivery inventory ledger containing that information.

When the delivery employee begins the delivery trip the date and time must be entered into CCTT. The delivery inventory ledger will be updated with the departure information.

Updating the delivery inventory ledger and CCTT:

Delivery employees must have an accurate delivery inventory ledger at all times during the delivery trip. In particular, the delivery inventory ledger must reflect current inventory in the vehicle. The delivery inventory ledger must be updated after each delivery.

The ledger may be maintained in CCTT, or outside of CCTT in electronic or hard copy.

If the delivery inventory ledger is maintained in CCTT (which means that CCTT must be updated after each delivery), the following information must be entered into CCTT after each delivery:

• Date and time of the delivery
• Required information concerning whether the delivery was made to an adult-use cannabis customer or a medicinal-cannabis patient
• UID and quantity of each cannabis good sold
• Purchase price of each cannabis good sold
• County in which the delivery was made

Once the above has been entered, the delivery inventory ledger will be automatically updated in CCTT.

If the delivery inventory ledger is maintained outside CCTT (in electronic or hard copy), it must be updated with the same information required by CCTT.

By the end of each calendar day, all the information recorded in the delivery inventory ledger must be entered in CCTT.

Obtaining additional inventory for delivery:

A delivery employee may return to the retailer’s licensed premises to obtain additional cannabis goods without having to create a new delivery inventory ledger in CCTT if:

(1) This occurs on the same day;
(2) Involves the same delivery employee; and
(3) Involves the same delivery vehicle

Remember: your delivery inventory ledger must be accurate. When obtaining additional cannabis goods, retailers may wish to have their employees verify the physical count of cannabis goods in the vehicle against the ledger.

Ending a delivery trip:

A delivery trip must be ended in CCTT when one of the following occurs:

• The delivery employee returns to the licensed retail premises after completing all deliveries for that delivery trip. This does not apply if the delivery employee is returning to obtain additional goods for delivery and chooses to continue the same trip.
• If the delivery employee does not return to the licensed retail premises after completing all deliveries (for example, if the employee plans to go straight home), after the final delivery on the delivery trip

If there are any cannabis goods remaining in the delivery vehicle after completing all deliveries, the delivery employee must return to the licensed retail premises.

When there are unsold cannabis goods remaining after a delivery trip, those cannabis goods must be removed from the delivery inventory ledger for that trip and returned to the retailer’s inventory in CCTT.

Remember: your delivery inventory ledger must be accurate. When remaining cannabis goods are removed from a delivery inventory ledger and returned to the retailer’s inventory in CCTT, retailers may wish to have their employees verify the physical count of those cannabis goods against the information on the ledger.

Providing the delivery inventory ledger upon request:

The delivery employee must provide the delivery inventory ledger to the Department or any law enforcement officer upon request.

Pre-order requirement eliminated

A retailer is no longer required to have received and processed at least one delivery order before a delivery employee can leave the licensed premises to conduct deliveries.