Every OCM update, translated into what you have to do.

If you hold a manufacturing endorsement and run extractions, that leftover plant material sitting in your storage after a run is not automatically waste anymore. Depending on volume, treating it as sellable spent biomass instead of destroying it could turn a disposal cost into revenue, or at minimum stop you from paying to destroy something a buyer would take off your hands.

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The catch is in the paperwork. OCM is explicit that this only works if the leftover material is separated and recorded in Metrc as spent cannabis biomass through a processing job, done correctly, at the time of extraction. Get that step wrong, or skip it, and OCM already told you what happens: it's waste, and destroying inventory you could have sold is the kind of mistake that's expensive to notice after the fact.

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• Confirm your manufacturing endorsement actually covers this activity before you change how you handle post-extraction material.
• Review how your Metrc processing jobs are currently logging spent material, this is exactly the kind of setup that's easy to get subtly wrong.
• Line up a buyer or transfer partner before counting on this as a revenue stream, since spent biomass can't go to retail.

If you cultivate or manufacture and your process generates kief, which category your product lands in now determines what testing it needs and who you can sell it to, and that comes down to something as specific as whether the material came from one strain and one harvest or got mixed across batches.

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Cultivators can't combine kief flower packages themselves, only manufacturers can turn kief flower into kief concentrate by combining it. Get the category wrong in Metrc, whether by mislabeling single-batch kief as concentrate or the reverse, and you risk a batch that either skips testing it needed or gets held up in testing it didn't need, either one can delay a sale or create a compliance problem you didn't see coming.

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• Check how your current Metrc setup is categorizing kief output today, this memo changes the item types you should be using going forward.
• Confirm with your team which harvests and strains are being combined during processing, since that's the deciding factor between the two categories.
• If you sell kief to another license holder for further processing, make sure both sides agree on which category it's moving as.

If you send product out for extraction, pre-treatment (reducing contaminants before testing), or remediation (fixing product that failed testing), stop using the sell-and-buy-back workaround. Instead, create the Metrc transfer using the Processing transfer type and attach a completed Service Transfer Form as a PDF. The business initiating the transfer submits the form.

For remediation, you still need an OCM-approved remediation plan before the product moves. Update your transfer SOPs and any processing contracts so pricing reflects fair market value for the service. Metrc Support Bulletin 73 covers the system steps.

Retailers: product past its expiration date cannot be sold and must be destroyed. Product past its best-by date can still be sold, but check with the cultivator or manufacturer about freshness and potency first. Build expiration checks into receiving and regular inventory audits.

Cultivators and manufacturers: print the correct date on every retail label and make Metrc match it, using the use by field for best-by dates and the expiration field for expiration dates. After one year, bulk flower and concentrate count as untested. Untested flower can be destroyed or extracted into concentrate for retesting, untested concentrate can be resubmitted for testing but can't go into a final product until it passes. Remediation does not reset the clock. Metrc Support Bulletins 71 and 72 cover the details.

Walk your storefront. Count every sign visible from outside, including door decals, blade signs, and parking lot signs, and get down to two fixed exterior signs. Remove feather flags, sandwich boards, neon window signs, inflatables, banners, and outward-facing posters or window wraps.

Then audit your ads, social posts, and printed materials for the exact OCM warning language, which differs for cannabis and hemp products. Pop-up web ads are not allowed, and you must verify customers are 21+ before any direct or location-based advertising. Violations can lead to penalties up to license suspension or revocation, and anyone can report a business through OCM's complaint form.

Before you buy hemp concentrates or HDCPs, plan for approval time. Submit the matching OCM request form (HDCP transfer or hemp concentrate transfer) for each batch, and wait for OCM's email approval and instructions before adding it to inventory.

Approved hemp concentrates must then pass Minnesota compliance testing before you manufacture with them. HDCPs containing THC must be added to your Metrc inventory and tested in Minnesota before sale. HDCPs containing only CBD, CBG, CBN, or CBC can use out-of-state labs until May 1, 2027. Build these steps into purchasing timelines so product is not stuck waiting.

Check that every location covers all five required items. You can meet the requirement three ways: on product labels, posted in the store, or on a handout given at purchase. The simplest route is to post OCM's guide and keep printed copies at the counter.

If you use your own materials instead, compare them line by line against Minnesota Statutes, section 342.63, subdivision 6. Train budtenders on where the information lives, and consider stocking translated versions if your customers need them.