Chain of custody in cannabis logistics refers to the documented and verifiable trail of cannabis products as they move through every stage of the supply chain, from cultivation and manufacturing to distribution and retail. This concept ensures that cannabis products remain secure, unaltered, and compliant with state and local regulations throughout their journey. By maintaining an unbroken chain of custody, operators can protect against product diversion, contamination, theft, and regulatory violations.
In cannabis, chain of custody involves a series of recorded transfers between licensed entities. Each transaction is documented with details such as date, time, location, quantity, product identifiers (e.g., RFID tags or METRC UID tags), and the individuals responsible for the transfer. According to the National Cannabis Industry Association (NCIA), robust chain of custody documentation is vital for ensuring compliance with state seed-to-sale tracking systems like METRC or BioTrack, which are designed to prevent illicit market activity and promote transparency (NCIA, 2024).
The process typically begins at cultivation, where each plant or batch is assigned a unique identifier. As products are harvested, processed, tested, and packaged, the identifiers are updated to reflect any changes in form—such as trimming flower, creating extracts, or infusing edibles. These identifiers must follow the product through every transfer, ensuring traceability.
Once products are ready for distribution, licensed transporters pick them up for delivery to retailers or other licensed facilities. Each step of this journey must be logged, including vehicle GPS data, signatures of individuals receiving and releasing custody, and any deviations from the planned route or delivery schedule. These records are required by regulators in most legalized states, including California, Colorado, and Nevada, where seed-to-sale tracking systems are mandatory for licensees (Leafly, 2024).
Standard protocols for chain of custody vary by jurisdiction but share common elements such as:
- Unique identification of cannabis products.
- Comprehensive logging of each custody transfer.
- Secure transport with limited, authorized personnel.
- Integration with state-mandated track-and-trace systems.
- Retention of records for regulatory audits.
Some states like Oregon and Michigan specify chain of custody protocols directly in their cannabis regulations, requiring that each transfer includes manifest documentation signed by both the sender and recipient. Other states may allow digital-only documentation but still require immediate data input into approved systems like METRC.
In practice, operators who fail to maintain proper chain of custody face steep penalties, including fines, license suspensions, or permanent revocation. According to the Cannabis Compliance Board of Nevada (2024), inadequate chain of custody documentation is one of the most common violations leading to disciplinary action.
Ultimately, an unbroken and well-documented chain of custody is the backbone of a compliant cannabis logistics operation. It not only protects license holders from regulatory issues but also helps ensure product safety for patients and consumers. As the industry matures, more standardized protocols and technology integrations are expected to streamline chain of custody practices nationwide, enhancing security and compliance for all stakeholders.
