Washington, DC: from cultivation center to shelf, what the label has to show

Step by step: Washington, DC

1. Step 1: Homogeneous batch, tracked in Metrc (Cultivation center) An ABCA-licensed cultivation center grows the plants, and every product it handles must be entered in Metrc, the District’s seed-to-sale tracking system. Under 22-C DCMR 6503.1, product is divided into homogeneous batches, because a lab sample only means something if it matches the rest of its batch. The cultivation center becomes the label’s producer.
2. Step 2: Batch held until tested (Cultivation center) Under D.C. Code 7-1671.05, harvested cannabis must be split into batches that are segregated and held from sale until a licensed lab has tested them, its results are in, and the cultivation center has confirmed they meet the ABC Board’s sale requirements. Since 16 August 2024, untested product cannot move to a manufacturer, retailer or internet retailer.
3. Step 3: The lab obtains the sample (Licensed testing lab) ABCA makes the licensed lab set out written procedures for obtaining and transporting samples from licensees, and the District’s earlier rules had the lab collect them. A sample that is not homogeneous with its batch may be treated as a violation or an improper test. Samples a licensee picks for quality assurance or research never count toward required testing.
4. Step 4: Independent licensed lab (Licensed testing lab) ABCA licenses the lab, which may not hold a cultivation, manufacturing, retail, internet retail or courier license. By statute it reports THC and CBD concentrations plus mold, mildew, pests and any mycotoxin, pesticide or heavy metal above Board limits, such as the 1.0 ppm cap on the synergist PBO (22-C DCMR 6409.5). Results go back to the cultivation center or manufacturer.
5. Step 5: Pass, remediate or never (ABCA / ABC Board) Under rules the ABC Board adopted as final on 3 December 2025, cannabis oil or dried plant material that fails a microbial, mycotoxin, heavy metal or residual solvent test may be remediated and retested; a pass means the batch need not be destroyed. A pesticide failure cannot be remediated or turned into oil, though other failed plant material may be processed into oil.
6. Step 6: Package + label (Cultivation center) Labels follow 22-C DCMR 5607, which the ABC Board reads as requiring the producer, the seller, the quantity of cannabis, THC and other cannabinoids, potential allergens, chemical additives and health and safety advisories. By statute the package must be child-resistant (16 C.F.R. Part 1700) and may not appeal to anyone under 21, including the word candy.
7. Step 7: Retailer, tested product only (Retailer) Only tested product reaches a licensed retailer or internet retailer, which becomes the label’s seller. Because patients can now self-certify, the Board’s technical rules dropped the authorized practitioner’s name from the label. The Board can also summarily close an unlicensed shop that sells cannabis no District-licensed lab has tested, and the District can seize its stock.
8. Step 8: Patients can test too (ABCA / ABC Board) Since the Medical Cannabis Clarification and Program Enforcement Amendment Act of 2024, a registered patient may have a licensed lab test a product bought from a licensed retailer or internet retailer. It gives patients a direct way to check that what the label promises matches what is actually inside the package.