California Cannabis Operators File Comments on DCC's Proposed Track & Trace Updates

Jul 19
2 min read

The California Cannabis Operators Association (CaCOA) recently submitted formal comments to the Department of Cannabis Control (DCC) on its proposed Track and Trace Updates, docket DCC-2026-02-R.

This rulemaking touches nearly every licensee in the state. The DCC's own analysis estimates it will affect roughly 5,500 licensed businesses, 97% of them small businesses, and could eliminate approximately 857 jobs while pushing some operators out of the market entirely. Those numbers demanded a serious response, and that's what we filed.

Track & trace: what we support

CaCOA isn't opposing this rulemaking outright. Several provisions genuinely strengthen the system. We back the DCC's efforts to crack down on lab shopping, tighten chain-of-custody protections, improve consumer access to Certificates of Analysis, and modernize parts of Track and Trace.

Diversion, inconsistent reporting, and gaps in testing integrity are real problems, and licensed operators are often the ones hurt most when bad actors exploit them.

Where we pushed back

Three areas concerned us most.

Transfer approvals. The proposal would require every recipient licensee, including retailers, to manually approve transfers before shipping manifests can even be generated. For distributors running same-day and next-day fulfillment, that's not a technicality. It's a structural change that could slow down commerce across the entire supply chain. We asked the DCC to lean on automated exception reporting and risk-based monitoring instead of universal manual pre-approval, and to make sure a Notice to Comply, which is meant to correct minor issues, doesn't automatically strip a business of its auto-approval status.
Retail reporting. The proposed rules would require completion of all nine tax fields in Track and Trace, developed in coordination with CDTFA to help with tax verification. We support accurate reporting. But the record doesn't show why all nine fields are necessary, and retailers are worried compliance will fall on budtenders manually entering data at checkout before point-of-sale systems catch up. We asked the DCC to build in time for software providers to actually build the tools first.
Consumer transparency. We asked the DCC to explicitly recognize QR codes and other digital formats as compliant ways to deliver Certificates of Analysis, instead of requiring paper.

CaCOA's bottom line on cannabis track & trace

California's regulated market only works if licensed businesses can stay in it. Rules that improve accountability without breaking commerce make the legal market stronger. Rules that pile on cost without a matching public benefit do the opposite, and they hand illicit operators an even bigger edge.

That's the case we made to the DCC, and we'll keep pushing for revisions before this rule is finalized.

Want a say in what CaCOA fights for next? Member input shaped this comment letter from the first draft to the last page. Join CaCOA, and help us keep pushing back where it counts.

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