Frequently Asked Questions
This page contains commonly received questions about data reporting, timing and transitioning to CCRS. Please see some of the most commonly asked questions below.
- Data Elements
- Data Quality
- Data Reporting
- Public Records
- System Support
- Technical Details
Q: Will price data be included for wholesale and retail sales activity?
A: Sales data will be collected. Details can be found in the user guide on what content is required to be reported in the sales report fields. Please see the user guide located on the CCRS Resources page.
Q: Will there be a fixed list of inventory types? Or just broad 'equivalence' categories (eg, Clone/Seed, Plant, Bulk Material, Product)?
A: This information can be found in resources provided on reporting submittals and data field detail on the CCRS Resources page.
Q: What date should be entered for Harvest Date if the harvest date is not yet known?
A: If the harvest date is not yet known, leave a NULL or a blank entry in the Harvest Date. This is not a required field for data submission.
Q: How are infused Pre-Rolls categorized in CCRS?
A: Infused pre-rolls are to be categorized as Concentrates in CCRS and thus are subject to the serving/transaction limits of concentrates.
Q: How will an integrator access the new system to send or review data?
A: Please refer to the Third Party Integrators section of the CCRS website.
Q: Is there a file size limit?
A: Files over 2GB will not be accepted by the system. If a file is too large, the system will generate an error message to the submitter.
Q: What is the definition of "weekly reporting"?
A: Week is defined as Sunday - Saturday. After the transition period, all licensee weekly reporting will be expected by no later than Sunday for the previous week. Reporting more frequently than weekly is allowed.
Q: Is there any expectation for license holders to submit historical data to CCRS?
A: To start using CCRS, there is an initial upload for required reports. The reports will be “point-in-time” from the date of upload forward.
Q: Are CBD materials are required to be entered into the system?
A: Yes. Imported CBD is required to have the necessary tests to allow it to be added to cannabis and the records and reporting requirements continue.
Q: Will labs still be required to report their information to this system within 24 hours?
A: Reporting requirements have not changed. It is recommended that labs use the .CSV report as a per Certificate of Analysis submittal for reporting.
Q: Will the laboratory need to provide COA documents to the LCB?
A: Labs are required to provide the test results to LCB via the reports established for that purpose. Record maintenance and access remain the same for both the labs and licensees. No changes have been made on the requirement to produce the records if requested by LCB.
Q: For those that only grow during the summer, will they need to submit a .CSV file weekly during the winter months when there are no changes?
A: The User Guide on the CCRS Resources page provides more detail on the required frequency of reporting. For Seasonal Growers, it is expected that reports are submitted when there are actions, updates and changes weekly (if those activities have occurred). It is not the expectation that reporting be submitted when there is no activity to report. A reminder that the LCB will be monitoring reporting activity. If information does not support weekly report submissions, the LCB will also be reaching out to confirm the reason for lack of reporting.
Q: Why does the Area specification mention that IsQuarantine is only for imported CBD? How is that related to Area data?
A: There are no quarantine requirements for cannabis products. You will have an entry as FALSE. For imported CBD: quarantine rules are required until passing tests results as outlined in WAC 314-55-109 are on hand. Imported CBD must be put into its own room/area and marked TRUE until passing results are received. This information is available in the Upload User Guide on the CCRS Resources page.
Q: What happens if an Update operation is performed prior to an Insert operation, will it default to inserting that case? If so, can we just always specify the operation to be Update even if it is an Insert?
A: The record doesn't exist, so an error message would be received.
Q: Can a Lab sub-contract out their testing? If they do, who is responsible for reporting the test result?
A: Labs may subcontract samples for a limited suite of tests and circumstances. The primary lab is responsible for reporting the test results directly to CCRS for the applicable product tested. WAC 314-55-102 (5) and WAC 314-55-102 (5) address referencing and subcontracting.
Q: What is the process for seeing what has previously been reported to CCRS for a given license, so that we can align our future .CSV imports to use the same external identifiers?
A: Licensees will need to request CCRS records through a Public Records request if seeking licensee specific information. There is no direct access to the data that has already been reported. The original licensee records still fall under the archive requirements found in WAC 314-55.
Q: For the inventory sheet, is ‘total cost’ the individual unit cost * quantity in stock, or the unit cost for each item in stock?
A: The Upload User Guide on the CCRS Resources page explains the following: TotalCost is the total cost associated with a licensee's inventory and stock.
Q: If a retailer incorrectly enters the ‘FromInventoryExternalIdentifier’ when they are receiving, how will they correct this?
A: They would perform an "Update" operation. That would update the record and correct the error.
Q: Can you confirm that concentrate for inhalation is an intermediate product versus an end product?
A: For a detailed explanation of all Product types, refer to Table 2 in the Upload User Guide on the CCRS Resources Page.
Q: What is the correct way to enter a product's weight in .CSV submissions?
A: UnitWeightGrams is the weight of the sellable product unit (not including packaging). Any one sellable product may never exceed the individual carry limit allowed for a consumer.
Sellable product = 2 grams of flower - UnitWeightGrams = 2 grams
Sellable product = 1 pre roll - UnitWeightGrams = 1 gram
Sellable product = 1 package of edibles - UnitWeightGrams = 10 grams
Sellable product = 1 concentrate for inhalation cartridge - UnitWeightGrams = 2 grams
Q: What is the expectation of licensees using CCRS?
A: Please see the user guide located on the CCRS Resources page and information presented during the webinar on 9/8/2021.
Q: Does CCRS apply to all licensees, including retailers?
A: Yes. This applies to all cannabis license types and to certified labs.
Q: How do we do a plant ID in CCRS?
A: The plant ID will not be generated by the state software system. Licensees will need to establish/choose an inventory numbering system and then assign ID's to plants. A reminder that requirements to tag plants has not changed; plants must still be tagged. The plant tag will now be the ID a licensee assigns to that plant and has recorded in the appropriate CSV file.
Q: What time zone should dates/times be documented in?
A: For reporting purposes, the file name should be referenced in PST.
Q: How should a licensee create a Sample to send to the Labs?
A: The sample sent to the lab should be the same external identifier for the lot that was created original. This way the Lab results are attached to the larger batch. Keep IDs from original external ID, do not break them out as this will cause issues with required testing of all your products.
Q: Does CCRS provide an integration sandbox for integrators to develop against?
A: The LCB provides all cannabis licensees, labs and integrators access to the PREproduction CCRS environment for training and testing.
Q: How will an integrator gain access to CCRS to report on behalf of licensees?
A: Once an integrator is approved through the Cannabis Examiners Unit, licensees will have the option to assign themselves that integrator through CCRS. Integrators do not have the ability to adjust licensee assignment.
Q: How will licensee software vendors authenticate on behalf of licensees?
A: Integrators will be assigned a specific ID and will need to use the SecureAccess Washington (SAW) to authenticate and report on behalf of a licensee.
Q: Does the integrator need to be preliminarily approved or validated by LCB before it is added to the system by the licensee to enable the integrator to upload reports on the licensee’s behalf?
A: Yes. Integrators providing reporting services for licensees will need to be added to the approved integrator list in order for licensees to assign them reporting permissions. The steps for approval are listed on the CCRS Third Party Integrator Approval Process page.
Q: If any licensees were to add an integrator within the PREproduction environment, do they need to do so again on the live site?
A: Yes. These environments are autonomous and do not share administration or reporting data.
Q: Can only one user be associated with our CCRS integrator account?
A: Two users can be associated with your integrator account.
Q: What filename format does an integrator use when uploading on behalf of a lab?
A: Integrators uploading files on a Lab's behalf would use the same Lab CSV file that the labs would use. The CCRS specification file has the naming conventions.
Q: If an integrator is submitting .CSV reports on behalf of a licensee, should we expect that only the integrator will be notified of errors via email, or does the licensee receive an email notification as well?
A: Yes, the individual (integrator) uploading the .CSV file would be notified of any errors, but the licensee will not receive an email.
Q: Can licensees use Manifests generated by their integrator or Point of Sale (POS) systems?
A: No, the only accepted Manifests are the PDF generated by submitting the CCRS Manifest.CSV or the Contingency Manifest per WAC 314-55-085.
Q: Will licensees be able to access analytics from CCRS?
A: Licensees will be able to request information by submitting a public records request.
Q: Can the LCB make a copy of the entire Leaf database available once it is turned off, similar to FOIA public records requests, but with full export?
A: Public records requests will be managed following existing processes. Full publishing of the entire backup is not likely based on specific types of data restrictions.
Q: Can we get access to all the CCRS data including products sold (in order to assess trends)? Or will the data at least be public for sales figures by license, similar to what we can access currently?
A: Public records requests will be managed following existing processes.
Q: What is the process for seeing what has previously been reported to CCRS for this given license so that we can align our future .csv imports to use the same external identifiers?
A: Licensees would request CCRS records through a Public Records request if seeking licensee specific information. There is no direct access to the data that has already been reported. The original licensee records still fall under the archive requirements found in WAC 314-55.
Q: Will there be explicit rules on what can be transported between licensees?
A: There are no changes to licensee permissions by licensee type and no changes in the types of products that can be transported between licensees.
Q: Will there be explicit rules on 'conversions' from one type to another? How will these be enforced? Leaf allowed anything to be ‘re-typed’ into anything.
A: Rules on valid conversions have not changed per RCW or WAC. CCRS will not “enforce” conversions by the system architecture. The enforcement of conversions will be based on the detail reported to WSLCB and follow up conversations between licensees and their Enforcement Officer/Compliance Consultant.
Q: WAC 314-55-083H still makes reference to "unique identifier generated by the traceability system." Will we be returning to that requirement?
A: The CCRS reports and the LCB will not be generating the IDs. Licensees will need to use reliable inventory tracking methodologies to assign IDs to their inventory and provide the ID (called external identifiers) when reporting via the CCRS reports. It is recommended that where possible to continue to use the existing ID structures. The WAC requirement going forward will be for IDs, not for IDs generated by the State.
Q: How will shifting to the CCRS not place licensees in jeopardy of violation of Washington state law and administrative law in accordance with existing WAC requirements?
A: The CCRS reporting requirements cover the WAC requirements for records retention and requirement to report to the LCB cover the WAC language. Every system used to date by LCB has had the same inherent requirement for licensees to report to be in compliance. The underlying components of reporting remain the same.
Q: Will there be a redefinition of the concept of “failure to maintain traceability” or what it means to maintain compliance given the significant change?
A: No. The change in systems for reporting does not change the underlying concept that reporting is required and that accurate reporting and records maintenance is expected.
Q: When entering the discount and tax information in the Sales.CSV does the detail apply to the individual unit or the whole transaction?
A: For the Sales.CSV in a row entry in which QTY is more than 1, the discount and taxes are reflective of the entire transaction. Unit Price is the price of one unit before discount or taxes. A reminder that other tax is Excise tax and is required for retail sales.
QTY = 3
Unit Price = $5.00
Discount = $3.00
Sales Tax (10%) = $1.20
Other Tax (37%) = $4.44
Q: How are Medical Tax Exemptions applied?
A: The Sale.CSV will record the transaction as a RecreationalMedical sale. The tax for which the qualifying individual is exempt will not be charged and not collected from the individual and is therefore $0.00. A reminder that a tax exemption is not a "discount." The exemption only applies to sales tax, not excise tax.
Q: What support will be available for licensees using CCRS post launch?
A: Please see the user guide and resources located on the CCRS Resources page and information presented during the webinar on 9/8/2021.
Q: In the WAC (314-55-089) it states “the act of keeping data completely up-to-date in the state traceability system fulfills the monthly reporting requirement” - regarding taxes - will that still be the case or will there be a new process?
A: Cannabis retailers are still required to send monthly reports. Reporting requirements have not changed. The statements below are specific to producer/processors (reference 314-55-089(2) and 314-55-089(3).
Cannabis producer/processors do not have a tax obligation to the WSLCB and the Finance Tax and Fee group is not collecting reports from this group of licensees.
Producers and Processors should contact their Enforcement and Education Officer if they have questions regarding how to report their information. To be fully compliant with the LCB, licensed cannabis retailers (reference 314-55-089(4) are required to report using LCB form LIQ1295 (Retailers Sales and Excise Tax) and pay their monthly sales/tax information by the tax due date. Retail licensees are required to submit a report to the LCB each month even if they did not have sales completed. Per WAC 314-55-092(2) failure to report and/or pay will be sufficient grounds for the LCB to suspend or revoke a license.
- Cannabis producer/processors do not have a tax obligation to the WSLCB and the Finance Tax and Fee group is not collecting reports from this group of licensees.
Q: Will CCRS allow integrators to use an API?
A: No. There is no Application Programming Interface (API) for CCRS.
Q: Will the LCB be providing any ‘cloud storage’ to facilitate digital transfer of data between licensees (such as manifests and lab results data)?
A: This service will not be provided.
Q: How will lab results be tracked for retail products?
A: Records requirements have not changed. Licensees must continue to provide the supporting documentation for all products sold at retail. Reports are being built against the CCRS data submitted for LCB’s use in reviewing test results.
Q: Will the LCB require usage of globally unique identifiers (GUIDs) to identify products, and if so can we utilize the ULID standard as recommended by the Traceability 2.0 work group?
A: No. The Traceability 2.0 Work Group recommended that GUIDs not be issued by a central service, but generated dynamically using an approved algorithm by third-party software providers. Agency staff reviewed the universally unique lexicographically sortable identifier (ULID) algorithm and specification suggested by a work group subcommittee which convened in November 2019.