This Metrc Support Bulletin applies to Metrc (Minnesota) and explains how Minnesota Office of Cannabis Management (OCM) sampling requirements translate into day-to-day Metrc workflows, including how to size a compliance representative sample by batch size, create a lab test sample package in Metrc, and split out retention and stability samples before transferring the laboratory analysis sample to a testing facility.
Bulletin overview and why it matters in Minnesota Metrc
OCM issued this guidance to expand on sampling requirements in Minnesota’s Cannabis Technical Authority (CTA), focusing on two operator pain points: how much to sample from different sized batches and how to document those samples correctly in Metrc so test packages, retention samples, and stability samples all reconcile with the source batch.
Practically, this bulletin affects how you plan labor, surveillance time, packaging/tag inventory, and testing timelines. If the Metrc package quantities do not mirror what you physically pulled and what the lab expects to receive, you increase the risk of lab intake delays, test submission errors, or inventory discrepancies that can trigger compliance follow-up.
Key definitions used in the bulletin (CTA-aligned)
What Minnesota considers a “batch” for sampling
The bulletin reiterates that “batch” is a defined concept in Minnesota law and the CTA, and the sampling rules are applied at the batch level rather than at an arbitrary Metrc package size.
Plant batch concept (cultivation): A specific quantity of cannabis plants cultivated from the same seed or plant stock, cultivated together, intended to be harvested together, and receiving identical propagation and cultivation treatment.
Flower batch concept (post-harvest): A specific quantity of cannabis flower harvested together that is uniform, intended to meet specifications for identity, strength, purity, and composition, and receiving identical sorting, drying, curing, and storage treatment.
Manufacturing batch concept: A specific quantity of a cannabis product (including lower-potency hemp edible, artificially derived cannabinoid products, hemp-derived consumer products, and hemp-derived topicals) made at the same time using the same methods, equipment, and ingredients; uniform; intended to meet specifications for identity, strength, purity, and composition; and manufactured/packaged/labeled under a single batch production record (Minnesota Statutes, section 342.01, subdivision 7).
Sampling terms you must operationalize in Metrc
Increments: Discrete portions of sample pulled from various locations in a batch. The compliance representative sample is built from the required number of increments.
Laboratory analysis sample: The main portion of the representative sample sent to a testing facility for compliance analysis (CTA, page 2).
Retention sample: A portion of the representative sample held by the licensee until six months after the product expiration date (CTA, page 3).
Stability sample: A portion of the representative sample taken from the first batch of a cultivation or manufacturing process and held by the license holder or testing facility to evaluate shelf life over defined timepoints.
Critical sizing rule: The laboratory analysis sample size is always the compliance representative sample size minus the retention sample size.
Metrc setup recommended by OCM: retention and stability sub-locations
OCM recommends creating dedicated Metrc sub-locations such as Retention Samples and Stability Samples before you begin sampling. This is an operations-control step: it makes it easier to find these packages later, reduces mis-shipments, and supports internal audits when a regulator or lab asks where retained material is stored.
If you need help creating sub-locations, the bulletin directs operators to use Metrc Expert or contact Metrc Support (877-566-6506) through https://support.metrc.com.
How to calculate Minnesota compliance sample sizes (and increments)
The bulletin explains that sample size is driven by overall batch size and that you must pull a required number of increments to build a compliance representative sample. If you also request homogeneity and stability evaluation, you must include enough additional material in the compliance representative sample to cover homogeneity testing and each stability timepoint.
Homogeneity and stability: plan quantities with your testing facility
It is the license holder’s responsibility to coordinate with the testing facility so both sides agree on the total sample mass/units needed for the requested analyses and timepoints.
What is tested at each stability timepoint: Potency and microbial content are evaluated at each timepoint; for vape devices, heavy metals are also evaluated.
Minimum material for microbial testing per stability timepoint (as stated in the bulletin): • 10 g flower • 5 g concentrate • 10 g infused non-edible • 25 g infused edible
Concentrates and vapes: sample size requirements
Batch mass ≤ 10 lbs (≤ 4.5 kg): Compliance representative sample is 10 increments totaling 32 g; laboratory analysis sample is 22 g; retention sample is 10 g.
Batch mass 10–14 lbs (4.5–6.4 kg): Compliance representative sample is 12 increments totaling 32 g; laboratory analysis sample is 22 g; retention sample is 10 g.
Batch mass > 14 lbs (> 6.4 kg): Compliance representative sample is 12 increments totaling 0.5% of batch mass; laboratory analysis sample is 0.5% of batch mass minus the retention sample; retention sample is 10 g.
Flower and infused products (excluding beverages): sample size requirements
Batch volume ≤ 100 gal: Compliance representative sample is 4 increments totaling 8 units; laboratory analysis sample is 4 units; retention sample is 4 units.
Batch volume 100–940 gal: Compliance representative sample is 4 increments totaling 12 units; laboratory analysis sample is 8 units; retention sample is 4 units.
Batch volume 940–1550 gal: Compliance representative sample is 6 increments totaling 14 units; laboratory analysis sample is 10 units; retention sample is 4 units.
Batch volume 1550–3100 gal: Compliance representative sample is 8 increments totaling 16 units; laboratory analysis sample is 12 units; retention sample is 4 units.
Batch volume > 3100 gal: Compliance representative sample is 12 increments totaling 28 units; laboratory analysis sample is 24 units; retention sample is 4 units.
Beverage shooters (< 3 oz): sample size requirements
Batch volume ≤ 1,000 units: Compliance representative sample is 6 increments totaling 16 units; laboratory analysis sample is 10 units; retention sample is 6 units.
Batch volume 1,000–5,000 units: Compliance representative sample is 8 increments totaling 18 units; laboratory analysis sample is 12 units; retention sample is 6 units.
Batch volume > 5,000 units: Compliance representative sample is 12 increments totaling 30 units; laboratory analysis sample is 24 units; retention sample is 6 units.
Collecting the compliance representative sample (physical sampling)
The bulletin directs licensees to follow the CTA’s Sampling section (CTA, page 16) for the physical sampling method. Operationally, this means you should stage the full batch in a clean area under video surveillance, then pull the required number of increments from across the batch so the final compliance representative sample reflects the entire batch package.
OCM also emphasizes selecting a container that will not contaminate or damage the product during transport. Because labs may have intake preferences (jar type, seals, labeling, etc.), coordinating container specs with the testing facility helps prevent rejected samples.
How to enter sampling in Metrc (Minnesota): packages you must create
The bulletin’s workflow is built around a clear Metrc package lineage: source package → test sample package (compliance representative size) → retention and stability packages split from the test sample package → remaining lab analysis sample transferred to the lab.
Step 1: Create the test sample package using “Submit for Testing”
After physically pulling the compliance representative sample, select the source/batch package in Metrc and use Submit for Testing to create a new test sample package equal to the full compliance representative sample size.
In the Submit for Testing window, complete the required fields (new package tag, location, quantity, unit, and the lab test batch). The bulletin instructs operators to select Same Item so the test package retains the correct item identity.
Stability selection in Metrc: If requesting stability testing, select Stability Study T0 (and not additional stability tests at this step).
Step 2: Split out retention and stability packages from the test sample package
Before shipping anything to the lab, remove the retention and stability portions from the Metrc test sample package by creating new packages from it.
Retention sample in Metrc: Select the test sample package and use New Packages to create a retention package equal to the required retention quantity. Assign it to your Retention Samples sub-location to keep retained inventory segregated and easy to audit.
Stability samples in Metrc: Using the same New Packages function, create one stability package per timepoint (or per lab instruction) and note that it is a stability sample. Assign these to a Stability Samples sub-location unless the lab will store them (in which case they may be transferred).
Practical implication: This “split-before-ship” approach prevents a common error where the entire compliance representative amount is manifested to the lab even though part of it is legally required to remain with the licensee as a retention sample.
Worked example from the bulletin (converted from screenshots)
The bulletin’s example uses a flower batch with a total dry weight of 45 kg (45,000 g). In that scenario, the compliance representative sample is 225 g, the retention sample is 20 g, and the laboratory analysis sample sent to the testing facility is 205 g (225 g minus 20 g). Stability sample quantities and the number of timepoints are determined in coordination with the testing facility.
Transferring the lab analysis sample to the testing facility
After the retention and any stability packages are created, the remaining test sample package represents what you intend to send for compliance analysis. The bulletin instructs the licensee to manifest (transfer) the laboratory analysis sample package to the testing facility.
If the business and testing facility agree that the testing facility will hold the stability samples, include the stability packages on the same manifest so chain-of-custody is documented in Metrc.
The bulletin references Metrc Bulletin 28 for transfer manifest creation and notes that an OCM-licensed transporter should be used to move the sample(s) to the testing facility.
Day-to-day operational implications for Minnesota licensees
Inventory accuracy depends on sampling accuracy: In Metrc, every gram/unit you sample must come out of a source package and be represented in child packages. If you “sample off-book” or mis-size packages, you create reconciliation issues that are hard to fix after lab results are reported.
Testing timelines depend on upfront coordination: Stability and homogeneity can materially increase sample needs. Building that into the compliance representative sample up front helps avoid resampling events that can delay release-to-sale.
Storage controls matter: Retention samples must be held until six months after expiration. A dedicated sub-location supports SOP compliance, reduces accidental consumption/transfer, and speeds retrieval during investigations or consumer complaint follow-up.
Labeling and Metrc Retail ID compliance tools (Distru)
Sampling and testing are only one part of staying compliant through to sale. Once products are packaged and prepared for retail, labels often must align with Metrc identity fields (including Retail ID workflows where applicable), and errors can cause relabeling, returns, or sales delays.
DistruLabels: DistruLabels is a 100% free tool for creating compliant packaging and retail labels, helping operators keep label data aligned with Metrc requirements and support Metrc Retail ID compliance processes.
DistruERP: For larger or multi-site operations that need end-to-end supply chain management, DistruERP is Distru’s comprehensive Cannabis ERP platform designed to connect purchasing, production, inventory, sales, and compliance reporting alongside Metrc workflows.
Metrc support and training resources referenced in the bulletin
Metrc Support Portal: Access support resources and tickets at https://support.metrc.com.
Metrc Learn: Training resources are available at https://learn.metrc.com or through the Support menu inside Metrc (“Sign up for Training”).
Metrc Expert: Use the in-app knowledge base (widget icon) for step-by-step guidance on tasks like sub-locations, package creation, and submitting for testing.
