On Thursday, the Missouri Division of Cannabis Regulation issued guidance for marijuana operators in the state outlining how to handle recalled product.

In the announcement, DCR addressed the storage, return, and handling of recalled cannabis products within dispensary facilities.

DCR states that this guidance aims to provide clear instructions to dispensary licensees on the appropriate procedures to follow in the event of a product recall.

Do Dispensary Licensees Need to Store Marijuana Product Returns from Recalls?

One of the primary inquiries addressed by the DCR is whether dispensary licensees are mandated to store marijuana products that have been returned by patients or consumers due to a recall. According to the guidance outlined in the document, dispensary licensees are not obligated to store marijuana products that are returned as part of a recall. The regulations outlined in 19 CSR 100-1.180(2)(G) specify that returned marijuana products should only be accepted for the sole purpose of disposal. This emphasis on disposal rather than storage is intended to ensure the swift removal of potentially unsafe products from circulation.

Processing Recalled Products in Compliance with Regulations

Dispensary licensees seeking to handle recalled products in compliance with the established regulations are encouraged to reach out to Metrc Support for guidance and assistance in the processing of these products. Importantly, the document clarifies that products returned due to a recall will not be counted towards a patient’s purchase limit. This provision aims to encourage dispensaries to actively participate in the recall process without worrying about potential impacts on their customers’ purchasing capabilities.

Obligations Regarding Marijuana Products on Administrative Hold

In the interest of maintaining public safety and adhering to regulatory standards, the guidance underlines that dispensary licensees are required to uphold their responsibility in storing marijuana products placed on administrative hold. This requirement is in alignment with the stipulations outlined in 19 CSR 100-1 and the Notice of Administrative Hold issued to licensees on August 3, 2023. The document advises that licensees must continue to quarantine these products as per the provided guidelines until they receive written guidance from the DCR indicating the next steps.

Future Guidance and Support from the Division of Cannabis Regulation

Acknowledging the challenges and complexities associated with the recall process, the DCR assures all stakeholders that they are committed to providing ongoing guidance regarding the handling of marijuana products on administrative hold. This commitment is particularly relevant in light of the recall initiated on August 2, 2023. The DCR acknowledges the patience of dispensaries and other stakeholders as they navigate through this evolving process. Any responses, queries, or requests for additional information related to the guidance document are expected to be addressed by the DCR.

The full document can be found here.


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