This guidance is intended to assist licensees in understanding the regulatory requirements for delivery sales. The complete text of DCC’s regulations can be found in the California Code of Regulations, Title 4, sections 15000 through 17905. The requirements addressed in this guidance can be found in sections 15049.3 and 15418.
Specifically, this guidance explains:
- What delivery information must be entered into the California Cannabis Track and Trace system (CCTT)
- How licensees can comply with regulatory requirements associated with delivery sales
Creating a delivery inventory 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. If the driver is delivering sales that have already been recorded in Metrc, the Sales Delivery Manifest (Sales Receipt) will suffice as the Ledger for these pre-sold items. For details on how to create a Ledger in Metrc, please visit the Metrc bulletin archive for California and find the link named California Bulletin 2022-08-Tracking Retailer Deliveries. A link has been provided below:
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:
- This occurs on the same day;
- Involves the same delivery employee; and
- 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.
FAQ
If I update CCTT as deliveries are made, do I also have to maintain a physical copy of the delivery inventory ledger?
No. If you update CCTT immediately after each delivery, the delivery inventory ledger maintained in CCTT is the only inventory ledger you need.
If I am unable to update CCTT as deliveries are made, do I have to maintain a physical copy of the delivery inventory ledger?
Yes. You must maintain an electronic or hard copy delivery inventory ledger that contains all the information required on the CCTT delivery inventory ledger. You must update it after each delivery.
Is an active internet connection needed while conducting deliveries?
No. If you do not have an active internet connection while conducting deliveries, you can update CCTT at the end of the calendar day after you have completed your deliveries and have an active internet connection. However, if you are not updating CCTT after each delivery, you must maintain a delivery inventory ledger in electronic or hard copy. You must update that ledger after each delivery.
What should I do if a law enforcement officer asks to see my delivery inventory ledger during a traffic stop?
State law requires you to provide the delivery inventory ledger to the Department or any law enforcement officer upon request.
Can I change delivery drivers during a delivery trip?
No. You may not change the delivery driver once a trip has begun. To change drivers the current trip must be ended within CCTT, and a new trip must be created in CCTT with the new driver. This will require you to return to the licensed retail premises and create a new delivery inventory ledger.
Do I have to include the full quantity of a package in the delivery inventory ledger?
No. CCTT will ask you how many units of a package you are including in the delivery vehicle for the delivery trip. The delivery inventory ledger will show the quantity associated to that specific trip, not the full package quantity.
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