Metrc (Minnesota) issued Support Bulletin MN_IB_0071 to clarify how to build a compliant sampling workflow in Metrc when a batch requires lab testing, retention samples, and stability studies, including how to enter these sample packages and transfers correctly.
What this Minnesota Metrc bulletin changes in practice
This guidance reinforces a specific Metrc workflow that impacts day-to-day operations: your first “lab sample package” created in Metrc must contain enough material to cover the primary compliance test sample and any additional samples you must retain or hold for studies.
Because retention and stability packages must be created as “child” packages from the lab sample package (not directly from the original source package), operators should plan sampling quantities up front. If the lab sample package is created too small, you may be forced into rework that can delay testing, transfers, and product finishing.
Key concept: one lab sample package first, then derive the rest
Metrc’s required order of operations is the core of the bulletin.
1) Create a compliance representative sample total (planning step): Determine the total amount of product you must pull from the batch to satisfy compliance testing plus any required retention, homogeneity, and stability needs.
2) Create the Metrc lab sample package from the source package: In Metrc, use “Submit for Testing” on the source batch package to generate a new lab sample package tag with the full, planned sample quantity.
3) Create retention and stability packages from the lab sample package: Use “New Packages” on the lab sample package to create child packages for retention and each stability sample/timepoint you intend to hold.
4) Transfer only what belongs at the lab: Send the lab analysis sample (and stability samples only if the testing facility will store them) on a Transfer Manifest to the licensed Testing Facility. The retention sample must remain with the originating licensee.
Definitions used by OCM and Metrc (Minnesota)
These terms drive both physical handling and Metrc entry.
Batch: A defined quantity produced under uniform conditions, including cultivation batches (plants grown together and harvested together), flower batches (harvested and processed together), and manufactured product batches made at the same time with the same methods, ingredients, and a single batch record (Minnesota Statutes section 342.01, subd 7).
Compliance representative sample: A small portion of a larger sample or product that accurately reflects the characteristics of the entire sample or product (Minnesota Rules part 9810.0200, subpart 51).
Retention sample: A portion of the representative sample taken from each batch and held by the licensee until six months after the product expiration date (CTA Sections 2 and 7.2).
Stability sample: A portion of the representative sample taken from the first batch of a cultivation or manufacturing process that is held by the license holder or testing facility for evaluation of the product shelf life.
Calculating total sample quantity (why this step matters)
The bulletin directs businesses to calculate the total representative sample quantity first, using the Cannabis Technical Authority (CTA) Section 7.2. In practice, this calculation should include all material needed for the testing facility’s required analyses plus any additional required pulls that are still part of compliance (for example, homogeneity testing and each stability testing timepoint if applicable).
Operationally, this means your sampling plan should be confirmed with the testing facility before you create anything in Metrc so the lab sample package is not undersized. The licensee is responsible for communicating sample size requirements to the lab for homogeneity and stability expectations.
How to create the Metrc lab sample package (Submit for Testing)
After calculating total sample quantity, the source package is used to generate a lab sample package in Metrc.
Metrc action: Select the source batch package and choose Submit for Testing to create a new lab sample package tag for the full planned sample weight/quantity.
Select the appropriate test batch/panel: Choose the correct testing request(s) based on the product type being sampled.
Stability study selection (important constraint): If you are initiating a stability study, select only Stability Study T0 at submission. The bulletin explains that requesting additional stability timepoints in Metrc can lock the product until the stability study is completed.
Practical implication of stability results: Stability entries can affect testing status at the parent level. If a stability timepoint fails, the testing status for the parent package may update to Test Failed, which can impact child packages derived from the original batch. Also, entering stability results may cause finished child or derived packages to become “unfinished,” requiring the business to use Metrc’s Finish function again to close the package.
Why the parent package “locks”: Creating the lab sample package sets the source package testing state to SubmittedForTesting, which limits certain actions until testing workflows are completed. This is normal behavior and should be planned for in production scheduling.
How to create retention and stability packages (New Packages from the lab sample)
Once the lab sample package exists, all retention and stability samples must be created as child packages from that lab sample package.
Metrc action: Open the lab sample package and choose New Packages to create each retention package and each stability sample package.
Same item requirement: The bulletin instructs users to confirm Same Item so the derived package matches the sampled item and stays consistent for compliance traceability.
Inventory accounting impact: Each child package created reduces the quantity remaining in the lab sample package by the same amount, so recorded weights in Metrc should match the physically measured weights for each created package.
Timing requirement: Create retention and stability child packages before you place the lab sample package on a manifest to the testing facility, so your in-facility retained/stability quantities are correctly reserved in Metrc prior to shipment.
Facility organization tip: The bulletin notes that businesses may set up dedicated locations or sublocations such as Retention Samples and Stability Samples to keep storage and audits clean.
Transferring samples to a licensed testing facility in Minnesota Metrc
After the lab sample package and any needed child packages are created, the lab transfer is done via a Transfer Manifest.
Transfer only lab sample packages for compliance testing: Ensure the packages being shipped for compliance testing are the Metrc lab sample packages (they display as lab samples in Metrc). This matters for the testing facility’s intake workflow and for correct compliance visibility in the track-and-trace record.
Stability sample transfers depend on storage agreement: Stability packages are not entered as lab sample packages in Metrc, and whether they travel with the initial shipment depends on whether the business or the testing facility will store them until the agreed test dates.
• If the testing facility will hold stability samples, include those stability packages on the same Transfer Manifest as the initial compliance lab analysis sample shipment.
• If the business will hold stability samples, keep them onsite and transfer them later on a separate manifest, specifying the stability testing requested for that shipment.
Retention samples never go to the lab: The retention package stays with the originating licensee and must be held through the required retention period.
Operational compliance takeaways for cultivation and manufacturing teams
Sampling is a production planning task, not just a QA task: Because the first Metrc lab sample package must “fund” retention and stability packages, sampling quantities affect available sellable inventory and timing for when lots can be finished and released.
Coordinate stability study design outside Metrc: Metrc is used to initiate the study using Stability Study T0, but the business and lab still need to agree on timepoints, storage conditions, and responsibilities. Over-requesting timepoints in Metrc can slow operations by locking product.
Be prepared for downstream status changes: Stability results can propagate risk to parent/child package status, potentially requiring re-finishing packages or changing release decisions depending on your internal QA and regulatory interpretation.
Labeling and retail traceability support (Distru tools)
While this bulletin focuses on sampling packages and transfers, operators should also ensure their post-test packaging and retail labeling stays aligned with Metrc requirements, especially as products transition into packaged units and retail-ready forms.
DistruLabels: DistruLabels is a 100% free tool for creating compliant packaging and retail labels, and it can help teams stay consistent with Metrc Retail ID expectations by producing clear, standardized labels that match the data you maintain in Metrc.
DistruERP: For larger operators who need end-to-end supply chain management beyond sampling workflows, DistruERP is Distru’s comprehensive Cannabis ERP platform designed to manage inventory, production, sales, and operational data across the full operation.
Where to get Metrc help and training
Metrc Support: Use https://support.metrc.com (also accessible from the Metrc system’s Support menu) to open cases and access state-specific guidance.
Metrc Learn: Training is available through https://learn.metrc.com and via the in-app “Sign up for Training” option.
Metrc Expert: Use the in-app knowledge base widget to find step-by-step system guidance while you work.
