This bulletin applies to Metrc (Maryland) and introduces a new, optional item category for processors: Infused Liquid Edible - Bulk. Metrc’s intent is to support more accurate, volume-based tracking of infused liquid edible work-in-progress (WIP) that is produced and stored in bulk before it is packaged into final retail units.
Bulletin reference: MD_IB_0119 (Distributed 12/12/2025). The bulletin states this functionality begins on 01/06/2026; operators should follow that start date for implementation planning, even though the table header lists an earlier effective date.
What changed in Maryland Metrc
Starting 01/06/2026, Maryland processors can optionally select a new item category in Metrc: Infused Liquid Edible - Bulk. This category is designed specifically for intermediary bulk infused liquid edible material that will later be packaged into final form for sale.
Who should use the “Infused Liquid Edible - Bulk” category
This category is intended only for Processor licensees creating bulk infused liquid edible inventory during manufacturing. It is meant for WIP/intermediary packages (for example, a large batch of infused syrup or infused beverage base stored in a container/tank and tracked as a package by volume).
- Use it for: Bulk infused liquid edible material held prior to packaging into individual consumer units.
- Do not use it for: Final packaged goods intended for retail sale.
Key compliance rules for Infused Liquid Edible - Bulk in Metrc
1) WIP-only: not for retail transfer or sale
Metrc specifies that Infused Liquid Edible - Bulk packages must remain within Processor licenses during intermediary production. These bulk packages should not be transferred or sold to a retailer. When product is ready to move into the commercial supply chain (including transfer to a retailer), processors must use the appropriate non-bulk item category with all required details for that finished product type.
2) Volume-based tracking
Unlike many manufactured items that are tracked as “each” or by weight, Infused Liquid Edible - Bulk is tracked by volume for inventory purposes (for example, fluid ounces or milliliters). This is particularly relevant for processors who manufacture infused liquids in larger vessels and need inventory controls that match real production flow.
3) Packaging review is not required for bulk WIP
The bulletin states that packages created under this bulk category will not require packaging review. This aligns with the concept that the item is not yet a consumer-facing packaged good.
4) Testing expectations: R&D testing may apply; state compliance testing does not
Metrc indicates that R&D testing may be applied to Infused Liquid Edible - Bulk items, but state compliance testing is not required at the bulk WIP stage.
Important operational implication: Final packaged goods (using the standard Infused Liquid Edible item category) still require state compliance testing. Metrc highlights a key risk rationale: the packaging step (moving from bulk WIP into final retail units) can introduce contaminants, so compliance testing remains required for consumer safety on final goods.
Infused Liquid Edible - Bulk vs. the existing Metrc R&D item category
Metrc draws a clear distinction between these two categories, and choosing the correct one matters for clean inventory records and audit readiness.
Infused Liquid Edible - Bulk (new)
- Product-specific: Designed specifically for infused liquid edible products produced in larger quantities and stored in bulk.
- Purpose: Manufacturing WIP prior to final packaging.
- Testing: May have R&D testing; does not require state compliance testing at the bulk stage.
- Retail status: Not intended for transfer/sale to retailers.
R&D item category (existing)
- Not product-specific: Can be used for multiple product types.
- Purpose: Research and development evaluation (for example, new formulations or ingredient/additive changes).
- Retail status: Products created in the R&D category are not for final retail sale.
Practical day-to-day implications for Maryland processors
This new category is primarily a workflow improvement for processors producing infused liquids at scale. Here’s what changes operationally:
Cleaner WIP tracking for large batches
When you create a large production batch of infused liquid edible material (such as an infused beverage base), you can track that intermediate inventory as a bulk, volume-based package instead of forcing it into a finished-goods structure too early. This can reduce confusion during manufacturing runs and improve reconciliation between physical tanks/containers and Metrc packages.
Clearer separation between WIP and finished goods
Because bulk WIP does not require packaging review and does not require state compliance testing, operators should use this category to reflect the true manufacturing stage. Then, when converting into final consumer units, create the finished product packages under the appropriate Infused Liquid Edible (non-bulk) category and follow the required compliance testing and release steps before transfer.
Better audit posture through accurate naming
Metrc specifically instructs that the Item name must include identifying product information, not just the category. For bulk items, include details such as:
- Product line or brand name
- THC content (as appropriate to how your operation identifies potency targets for the bulk material)
This naming practice supports inventory clarity, reduces internal errors during conversions, and improves defensibility during inspections.
How to create an Infused Liquid Edible - Bulk item in Metrc
To use the new category, processors must create a new Item in Metrc and select the Infused Liquid Edible - Bulk category.
Metrc directs users to the Metrc Expert knowledge base inside the Metrc application for step-by-step guidance. After logging in, look for the white circle with the green shield icon in the bottom-right corner of the screen, then navigate through the guides for Items and Item Approvals as applicable.
Labeling and Retail ID readiness when moving to final goods
Even though bulk WIP is not intended for retail sale, most compliance issues occur when product is converted into final packaged inventory. When you package bulk infused liquid edible material into consumer units, ensure your finished goods labels and Metrc Retail ID workflows stay aligned with Maryland rules and your internal QA processes.
DistruLabels is a 100% free tool for creating compliant packaging and retail labels, and it helps operators stay organized when printing labels that support Metrc Retail ID compliance during final packaging runs. This is especially useful when transitioning from bulk, volume-tracked WIP into many individual retail units where labeling consistency and traceability are essential.
For larger operators that need end-to-end operational control beyond labeling, DistruERP is Distru’s comprehensive Cannabis ERP platform built for complete supply chain management, helping multi-department teams coordinate manufacturing, inventory, sales, and compliance processes at scale.
