Group Tagging of Cannabis Plants
In accordance with Government Code section 11346.8(c) and section 44 of title 1 of the California Code of Regulations (CCR), the Department of Cannabis Control (Department) hereby provides notice of modifications to the proposed regulation text that was the subject of public hearings on July 28, 2026. The text of the regulations with proposed modifications is attached to this Notice.
Written Comment Period
The written comment period begins on September 17, 2026 and ends on October 2, 2026. Any interested person, or their authorized representative, may submit written comments relevant to the proposed text modifications by mail or email to:
Department of Cannabis ControlLegal Affairs Division
2920 Kilgore Road
Rancho Cordova, CA 95670
E-mail: publiccomment@cannabis.ca.gov
All written comments received by October 2, 2026 that pertain to the proposed text modifications will be considered by the Department and summarized and responded to in the Final Statement of Reasons.
Summary of, and Rationale for, Proposed Modifications to Regulation Text
Section 15048.3. Receipt of Tags.
The Department proposes to modify subsection (a)(2) by replacing “of receipt” with “after receipt” in the requirement to record the receipt of plant or package tags in the track-and-trace system. This non-substantive modification improves the clarity and readability of the provision by specifying that the seven-calendar-day period is measured from the date the tags are received. The modification does not change the timeframe for recording receipt of the tags.
Section 15048.4. Tagging of Cannabis Plants.
The Department proposes to modify subsection (a) to require different tags based on how plants are tracked in the track-and-trace system.
These modifications are necessary to align the regulations with the track-and-trace system changes needed to implement group tagging. To expedite implementation, the track-and-trace system will maintain the existing tracking pathways for immature plant groups and individually tagged plants and establish a new pathway for mature plant groups. This ensures that each plant tag is associated with the appropriate functionality in the track-and-trace system.
Maintaining existing system functionality while establishing a separate pathway for mature plant groups reduces the development and testing needed to implement group tagging. A different system configuration would require more extensive system changes and significantly delay implementation. The proposed modifications therefore allow group tagging to be implemented sooner, providing cultivation licensees with the anticipated reductions in labor, costs, and administrative burden without unnecessary delay.
The Department also proposes to specify in subsection (a) that the particular plant tag type will be assigned by the Department’s track-and-trace system designee. This modification is necessary because plant tags may change based on system or operational needs. Specifying the types of tags in regulation could require regulatory amendments each time a different type of tag is used without providing a corresponding regulatory benefit. Allowing the specific tags to be assigned by the Department’s track-and-trace system designee provides flexibility to accommodate system changes. The Department intends to inform licensees of the applicable tags through guidance or other communications.
The Department also proposes to repeal proposed subsection (b)(1), which requires plants within a group to be uniform in strain or cultivar if the licensee elects to identify the strain or cultivar of the group in the track-and-trace system. The Department did not intend for this provision to require all plants within a group to be the same strain or cultivar. However, during the public comment period, several commenters interpreted it as imposing such a requirement. Because reporting strain or cultivar information is optional and uniformity in strain or cultivar is not necessary for regulatory oversight, the Department has determined that retaining the provision may create unnecessary confusion. Removing the provision clarifies that plant groups may contain multiple strains or cultivars. Licensees may continue to record strain or cultivar information in the track-and-trace system or maintain that information through other means.
The Department further proposes to modify subsection (d) to clarify when a new plant tag must be assigned as immature plants transition to the mature growth phase. Under proposed subsection (d)(1), a licensee must assign a new plant tag when an immature plant or immature plant group located outside a designated canopy area is moved into a designated canopy area upon flowering. The addition of “upon flowering” clarifies that moving an immature plant or immature plant group into the designated canopy area before flowering does not, by itself, require assignment of a new plant tag. If a licensee moves a plant or plant group into the designated canopy area while the plants are still immature, the existing plant tag may remain until the plant or one or more plants within the group begin flowering.
Under proposed subsection (d)(2), when one or more plants within an immature plant group already located within a designated canopy area begin flowering, the licensee may assign a new plant tag to each individual mature plant pursuant to subsection (d)(2)(A), assign a new mature plant group tag to the entire immature plant group pursuant to subsection (d)(3)(B), or establish one or more mature plant groups and assign a new mature plant group tag to each group pursuant to subsection (d)(3)(C), provided each group meets the requirements of subsection (b). Plants that have not begun flowering may remain in the existing immature plant group.
These modifications clarify that the requirement to assign a new plant tag is associated with a plant’s transition to the mature growth phase, rather than its location within the canopy alone. For plants and plant groups located outside the canopy, moving them into the canopy upon flowering requires a new plant tag. Plants and plant groups moved into the canopy before flowering may retain their existing plant tag until flowering begins. The modifications also address circumstances in which plants within an immature plant group do not begin flowering at the same time. Allowing a licensee to transition the entire immature plant group or establish one or more mature plant groups from the flowering plants provides flexibility to accommodate natural variation in flowering while maintaining the group requirements in subsection (b).
The modifications are also necessary to align the tagging requirements with the track-and-trace system configuration described above. An immature plant group transitioned to the mature growth phase must be assigned the appropriate plant tag for mature plant groups so that it can be transitioned in the track-and-trace system. An individually tagged plant must also be assigned a new plant tag upon flowering but will continue to use the appropriate plant tag used for individual plants regardless of growth phase. Requiring the appropriate plant tag ensures that each plant or plant group is associated with the correct functionality in the track-and-trace system.
Section 15049.1. Additional Requirements for Recording Cultivation Activities.
The Department proposes to modify subsection (a)(2) to add a reference to section 15048.4(b). This modification clarifies that the requirement to record commencement of planting a group of plants applies to plant groups established in accordance with the requirements of section 15048.4(b). The modification does not change the existing three-calendar-day timeframe for recording the activity.
The Department also proposes to add subsection (a)(3) to require licensees to record the movement of a plant or plant group to another location on the licensed premises within three calendar days. This modification expands the existing reporting requirement for movement of immature plants to a designated canopy area to apply to movement of any plant or plant group between locations on the licensed premises. Recording these movements is necessary to ensure that the location information maintained in the track-and-trace system accurately reflects the physical location of plants and plant groups on the licensed premises.
The Department further proposes to add subsection (a)(4) to require licensees to record the assignment of a new plant tag pursuant to section 15048.4(d) within three calendar days. This modification ensures that the track-and-trace system reflects changes in plant tags required as immature plants and plant groups transition to the mature growth phase while already located within a designated canopy area. The assignment of a new plant tag is a separate reportable activity from movement of a plant or plant group under subsection (a)(3). Accordingly, when a plant or plant group is both moved to another location and assigned a new plant tag, both activities must be recorded in the track-and-trace system.