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Minnesota Metrc OCM Stability Testing Guide

Minnesota
November 24, 2025
Link to Metrc Bulletin
TL;DR

• Minnesota requires stability testing to support shelf life dates, but requesting timepoint tests can freeze your entire batch.

• Only request Stability Study T0 on your initial lab sample package alongside compliance testing to avoid locking inventory.

• Demonstrated shelf life is the last passing timepoint; failed stability results can unfinish derived packages already in circulation.

Metrc (Minnesota) Support Bulletin MN_IB_0053 explains how Minnesota’s Office of Cannabis Management (OCM) expects licensees to establish shelf life through stability testing, how to handle stability study packages in Metrc, and how results can affect batch status, derived packages, and day-to-day operations.

Bulletin scope: Minnesota OCM stability testing in Metrc

Bulletin: Metrc Support Bulletin MN_IB_0053

Distribution date: 05/27/2026

Effective date: 11/24/2025

Subject: OCM Stability Testing Requirements

Under Minnesota rules described by OCM’s Cannabis Technical Authority, cannabis and hemp operators must be able to support the “best if used by” or “expiration” dating placed on labels. Metrc’s bulletin focuses on how to set up the initial stability study sample(s), how stability timepoint packages should be stored and tested, and how to avoid Metrc actions that can inadvertently lock inventory.

Labeling impact: “best if used by” vs. expiration dates

Minnesota requires date labeling tied to product type.

• Flower must be labeled with a “best if used by” date.

• Concentrates and infused products must be labeled with an expiration date.

OCM expects those dates to be supported by a stability study that demonstrates the product’s shelf life in its final packaged form.

What OCM expects: demonstrating shelf life with a stability study

The bulletin states that a cannabis or hemp business must demonstrate stability by submitting a portion of sample material from the first batch of a manufacturing or cultivation process for shelf-life stability analysis by a licensed testing facility.

Practically, this means operators should treat stability as a product-level validation effort: once completed for a product in its final packaging configuration, the demonstrated shelf life becomes the basis for dating future batches of that same product (so long as the product and packaging remain consistent with what was studied).

How to set up stability testing in Metrc without freezing product

Use the initial lab sample package for compliance testing and T0

Metrc’s bulletin instructs licensees to prepare a representative lab sample package and to request both required compliance testing and the stability study baseline test on that same initial submission.

Key rule: Only request “Stability Study T0” on the initial lab sample package along with the required compliance tests for that product category.

The bulletin warns that assigning stability testing to timepoint packages (for example, requesting T1, T2, etc. as “required testing”) can potentially freeze the entire batch of products until the stability study completes. For operations, that risk can translate into delayed sales, delayed fulfillment, and complications for downstream distribution and retail readiness.

What “Submit for Testing” should look like in practice

When submitting the initial lab sample package in Metrc, select the normal required compliance test type(s) for the item category (for example, an infused edible category test panel) and also select the “Stability Study T0” option that corresponds to the packaged product type.

Additional optional panels can be selected if the business needs them, but the bulletin’s operational focus is to keep stability timepoint testing out of the “required testing” workflow for later packages to avoid unintended batch locks.

Roles and communication: what the business vs. the lab must do

The bulletin repeatedly emphasizes coordination between the licensee and the testing facility, including steps that occur outside Metrc.

Business responsibilities: Prepare the representative sample and timepoint stability packages, assign required compliance testing plus “Stability Study T0” on the initial lab sample package, and coordinate with the lab so sufficient material is provided for both compliance and stability analysis.

Joint business and lab responsibilities: Communicate outside of Metrc to define storage conditions and logistics, report compliance results and “Stability Study T0” on the initial lab sample package so compliant results can release the batch, and test stability timepoint packages at agreed intervals.

For day-to-day operations, this means your SOPs should cover who schedules timepoints, where timepoint packages are physically stored, what packaging configuration is being studied, and how manifests will be documented so the lab can confidently match each package to the correct timepoint and source batch.

How stability study results affect Metrc batch and package status

Metrc explains that additional stability timepoints are not requested by the business in Metrc as required tests. Instead, they are reported by the testing facility at the agreed time intervals.

Based on the reported stability outcomes, the testing status for the batch may change. If a product fails at a stability timepoint, the testing status could be updated to “Test Failed,” which can affect the original batch and child packages derived from it.

Operational implication: Stability results can create downstream disruptions if product has already been further processed, transferred, or marked finished. Plan stability programs early, keep traceability tight, and avoid unnecessary transformations from a source batch if there is a realistic possibility the product will not pass later stability intervals.

Important Metrc behavior: results may propagate and “unfinish” packages

The bulletin notes that when stability study results are entered for a batch package, the results may populate to child or derived packages. If any of those derived packages were finished, the new test result entry may unfinish them. If that occurs, the operator can use Metrc’s “Finish” action again after reviewing the situation and confirming the correct compliance status.

Operational implication: Train inventory and production teams to recognize unexpected “unfinished” statuses as a possible stability-result side effect, not only as a data entry error.

How to calculate shelf life and set expiration dates for future batches

Once the stability study is complete, each product has a demonstrated stability lifetime.

Definition used in the bulletin: The product stability lifetime is the last passing stability test result. If a product passes at 9 months but fails at 12 months, the demonstrated stability lifetime is 9 months.

Metrc instructs businesses to calculate the expiration date for new batches by adding the demonstrated stability lifetime to the date of product batch release testing (the compliance testing release date).

Example provided by Metrc: If a product’s demonstrated stability lifetime is 372 days and a later batch completes compliance testing on July 1, the expiration date for that batch would be April 1 of the following year.

For entering item expiration date information in Metrc, the bulletin directs operators to Metrc Bulletin 37.

Submitting completed stability studies to Minnesota OCM

After completing the stability study, the business must communicate to the office that the stability study is complete and state the shelf life demonstrated for each product. The bulletin indicates the completed study must be submitted to OCM through the Stability Testing form.

Operational implication: Treat the stability report as a controlled compliance record. Ensure product specs (formula, packaging, storage assumptions, and labeling) match what was studied, because that alignment is what supports the dates you apply in ongoing production.

Stability sample storage options described in the bulletin

Option 1: The licensed business stores timepoint packages

Metrc describes a workflow where the license holder creates the stability packages for each timepoint and stores them until each timepoint occurs.

• Metrc recommends creating a sublocation such as “Stability Sample” to keep these packages segregated and easy to audit.

• At each timepoint, the business creates a transfer manifest to the lab and includes notes identifying the source package number and the timepoint being tested.

The testing facility then uploads results using “Stability Study T1,” “Stability Study T2,” and so on, to the package tag that was tested. The bulletin cautions that these timepoint packages are not lab sample packages and should not have testing requested as required tests, because requesting stability tests (for example, requesting T1) may lock the source package and its child packages.

Option 2: The testing facility stores timepoint packages

Metrc also allows a workflow where the license holder sends the timepoint stability packages to the testing facility at the same time the initial lab sample package is sent.

• On the manifest, include notes indicating which package corresponds to which timepoint(s).

• The testing facility stores the packages and performs testing at the predetermined intervals.

Results are uploaded by the lab using the appropriate stability timepoint test types (T1, T2, etc.) to the specific package tag tested, again without the business requesting those timepoint tests as required testing in Metrc.

Metrc configuration note: stability tests apply to packaged products

The bulletin notes that stability testing test types are only available for packaged product categories, because stability must be demonstrated for products in their final packaged form. For operators, this is a reminder that changes to packaging format, container, closure, or labeling storage assumptions can trigger the need to re-evaluate whether an existing stability study still supports the dates used on the label.

Day-to-day compliance takeaways for Minnesota operators

Metrc’s stability study workflow is as much about avoiding unintended inventory restrictions as it is about documenting shelf life.

• Build stability into product launch timelines so the first batch is set up correctly and future batch dating is defensible.

• Keep stability timepoint packages segregated (physically and in Metrc locations) and documented with clear manifest notes.

• Avoid requesting timepoint stability tests as “required testing” in Metrc to reduce the risk of freezing a batch until study completion.

• Train teams on result propagation and the possibility that packages may become “unfinished” after labs enter stability results.

Label execution: keeping packaging dates and Metrc IDs consistent

Once shelf life is established, operators still need to reliably reflect those dates on packaging and retail labels while staying aligned with Metrc package identifiers and retail workflows.

DistruLabels: DistruLabels is a 100% free tool for creating compliant packaging and retail labels, including support for Metrc Retail ID compliance so operators can keep retail label identifiers consistent with Metrc-tracked inventory.

DistruERP: For larger multi-department operations, DistruERP is Distru’s comprehensive Cannabis ERP platform designed to manage the full supply chain, helping teams coordinate inventory, manufacturing, labeling, transfers, and compliance processes alongside Metrc requirements.

Where Metrc points you for help

Metrc directs users to platform support and training resources.

Metrc Support Portal: https://support.metrc.com

Metrc Learn: Metrc’s training platform is referenced in the bulletin as a way to build facility-specific user skills and system familiarity.

For Minnesota stability programs specifically, keep documentation aligned across OCM submissions, lab schedules, and Metrc package actions so your “best if used by” and expiration dates remain defensible and your inventory stays saleable.

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