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Quality Assurance FAQs

Updated

OVERVIEW

The following is a list of the most frequently asked questions regarding Nabis QA

 

What are the Reasons for Products Needing to be Quarantined?

The product is quarantined for being non-compliant and unsellable to the DCC's standards. These are the most common reasons for quarantine (most common to least common):

  • Expired: COA expired or labeled as past best by date

  • Non-compliant: Missing label, incorrect label, Metrc issue, batch label issue

  • Damaged: Broken container, broken tamper seal, leaking

  • Return from Retailer: Mold, insects, contamination, quality issues

 

When do we consider a product expired?

  • If the COA is passed 12 months from the release date, the product will be quarantined, and it can no longer be transferred to any other license type unless approved by the DCC.

  • If the labeled expiration/best by date has passed, BUT the COA has not passed 12 months from the release date, we will quarantine the units in our expired quarantine area. Retailers can not sell products that have passed the labeled expiration/best by date, but we can still transfer these units to a distribution, manufacturing, or cultivation license to be remediated or relabeled.

 

Should we quarantine products if they expire soon?

  • No. We are an agnostic distributor, we allow our brands to do whatever they’d like with their inventory if it is compliant. When a product is expiring soon, at times brands will flash sale or even donate the product to avoid needing to destroy it. If we were to quarantine a product before it expires, and a brand wanted to donate or sell it at a discount, and the product was no longer available to place orders with, we would directly be responsible for the loss of their sale or even force an unnecessary destruction fee.

 

Does the brand get reimbursed for damaged products? – This is dependent on the situation.

  • If Nabis caused the damage, we would reimburse the brands. If we directly damage the product, the brand will no longer be able to make money on that product which we would be responsible for. If the product is in our possession, and was damaged, but no evidence on who caused the damage, it was likely Nabis' fault. To get the cost we would need to reimburse the brand, we will take the price of the unit entered our Nabis portal and multiply it by the number of damaged units.

  • If a product was damaged either by the brand, manufacturer, or retailer, we would not reimburse the brands for this damage. These instances are usually very clear and are discovered upon pickup, intake, or delivery of the product.

 

When do we communicate that products are getting quarantined?

  • We try to communicate these movements as soon as possible, ideally on the same day, but at times by the end of the week. If a product is being quarantined for a reason that is fixable, we will reach out as soon as possible with all the ways we can accommodate fixing the problem. If the product is being quarantined for reasons that aren’t fixable, like damaged or expired, we will aim to reach out as soon as possible, but might be a little delayed. Our Quarantine Associates handle most of the communication for products that go into our quarantine space daily. If products are quarantined during a cycle count, it will be communicated in our inventory report communications.

 

Can Expired Inventory be Transferred?

  • If the COA is older than a year - No, once a COA has passed 12 months from its release date, it is considered expired and can not be distributed to any other license type, unless approved by the DCC or retested, which will need to be approved by the DCC.

    • Subsection (b) is a new subsection that has been added to require that in order to transport cannabis goods to another licensee with the certificate of analysis, the certificate of analysis must be less than 12 months old. This is necessary to place an end date on the time frame during which cannabis goods can be transported from licensed distributor to licensed distributor without undergoing new testing. The Bureau determined that 12 months is necessary because it assures that the results found on the certificate of analysis are accurate. BCC - Final Statement of Reasons.pdf (page 33)

  • If the product is labeled as expired or past best by date, but the COA is still valid – This product can be transferred back to another license, but not a retail license. If the product is labeled as expired or past best by date, they will be quarantined regardless of the COA expiration.

  • Subsection (e) is a new section that specifies that cannabis goods cannot be transported if they have exceeded their best-by, sell-by, or expiration date if one is provided. This is necessary to ensure the safety of consumers by prohibiting expired cannabis goods from being transported to retail. BCC - Final Statement of Reasons.pdf (page 33)

 

Can Quarantined Inventory Be Transferred?

  • If the product is not expired, you can transfer quarantined inventory to another license regardless of its condition. We don’t suggest transporting damaged beverages or glass containers, but if the brands insist, we will allow it.

 

Can I Relabel my Product at Nabis?

With our license type, when it comes to compliance labels, we can only label potency at our facility. If a brand wants to apply a retailer-requested label that isn’t required by the DCC we can arrange that. This is a list of labels we CANNOT apply at our facility, and it is required that products come to us already labeled with this information:

  • P65 or Government warning

  • Tamper Seals

  • Expiration dates or manufacturing/ packaging dates

  • Ingredients, nutritional facts, allergens, and artificial food colorings

  • Batches or UIDs

  • Licensee name and contact information

  • Universal symbols

  • Product Identity or “Cannabis-Infused”

  • Net weights

  • Instructions for use

  • “Keep refrigerated” or “For Medical Use Only”



Do I Have the Correct P65 Warning?

Proposition 65 Warnings are not a DCC-mandated label, this warning is required by the state of California for all products. Almost every product sold in California is required to have a P65 Warning. This is what 99% of P65 warnings should be formatted as:

 

WARNING: Cancer and reproductive harm - www.p65warnings.ca.gov

The symbol consists of a black exclamation point in a yellow equilateral triangle with a bold, black outline. It must be to the left of the warning text and no smaller than the word WARNING. If the label is not printed in yellow, black and white is allowable. Link to symbol and requirements.

The word WARNING must be bold and in all capital letters. The only other substitution for this word is “ATTENTION” or “NOTICE”, which still must be bold and in all caps.

We will always suggest that both Cancer and Reproductive Harm is used in the P65 warning to avoid any rejections. However, this isn’t necessarily required for all products, but can be very open to interpretation, and that is why we always suggest having both listed.

  • Cancer: Always required for any smokable products. Not always required for edibles, since Marijuana Smoke is usually the chemical referred to with the cancer warning, but there are 900+ other chemicals on the P65 list, including β-Myrcene which is commonly found in cannabis.

  • Reproductive Harm: Always required for any product that contains THC or any other cannabinoids that could impair you. Also always required for any smokable product. If an edible product is CBD only (or any other cannabinoid that has no ‘high’), the cannabinoids won’t cause reproductive harm. It will still always be suggested to have reproductive harm listed, as there are many other chemicals on the P65 list that could be found in the product.

IF the business has less than 10 employees, this warning is not required, but we will always suggest it. Retailers will reject, and the brand will have to explain they are less than 10 employees and hope that the retailer understands. Not having the warning would also limit growth for the business.

 

Can a Retailer return Products to Nabis?

We can accept returns from retailers if the product meets all the rules and requirements:

  1. 30-day return policy – We will not accept products back from a customer if it has been in their possession for over 30 days. If a product has been at the retailer for less than 30 days, but has expired, we can not pick these units up. We can be flexible with this and can grant an extension of 45 days for more sensitive brands or retailers.

  2. Metrc tags, Metrc Manifest, and a Nabis Return From Retailer Order is required – We will require physical Metrc tags to pick up product(s) from a retailer, either the original tags we delivered to them, or the retailer’s Metrc tags. If retailers do not have tags to create their own packages in Metrc, we cannot accept the product back. A driver should never pick anything up without being provided both a Nabis Invoice and Metrc Manifest by the Nabis Dispatch team.

  • Why do we need a Nabis Invoice? If a product is delivered, and was left at another license type overnight, the order is considered DELIVERED. This closes out the order and we will need a Return From Retailer order created to coordinate a pickup. We will then need to intake this order so that the product gets received back into our system.

  • Why do we need the Metrc Manifest and tags? Metrc Manifest and tags are required by the state of California to track and trace all cannabis goods.

  1. No returns for products that are expired or need to be destroyed – For expired products, we cannot legally transport any product whose COA is over 12 months old. If the brand wants to return product that has become unsellable and cannot be remediated, so it needs to be destroyed, we should request that the retailer destroy these units themselves. This protects our brand partners from incurring additional costs with Nabis.

  • Destruction Fees: Nabis charges the brand $170 to pick up these units.

    • Cost of destruction example: We are destroying 100 total units at 0.25 per unit, and 20 of those are from a return to retailer order of product that needs to be destroyed. Nabis would charge the brand $5.

  • The brand may decide to credit the retailer for these damaged/expired products instead of creating a Return From Retailer order, but that is for the brand to discuss with the retailer.

  1. We only accept returns as they were delivered – We can only accept the product back as it was delivered, untouched and in full. For example, if we delivered 50 units, and the retailer wants to return 30, we will have to decline. If the retailer puts any labels on the product, we will not be able to pick it up, even if they are removed.

Due to the fees and loss of sales that the brand incurs on Return from Retail orders, we will always get approval from our brands before initiating any Return from Retail order.

 

Can I Pick up Samples/Products From Nabis?

  • If a C11 Distribution license is provided, a brand can pick up the product from our facility, but a ‘Brand Picks up from Nabis’ order must be submitted. Orders that are picked up from us, must be done so in a company vehicle, not a personal vehicle.

 

Can Nabis Retest a Brand’s Product?

  • Nabis as a company prefers not to handle any retesting events, and we don’t suggest having any consumable products retested. Not only do we see high rejection rates for products that are 9 months past the manufactured date, but if the product has already been at our facility for 12 months, we don’t want to store it any longer.

    • If the brand feels strongly about retesting their product, we will ask that they submit a remediation plan to the DCC for the product to be sent to another license to be retested or remediated.

 

What is the Cost of Destruction?

  • The cost of destruction will vary greatly depending on the company we use for destruction, the amount of product we can confirm for destruction, and the overall cost of the destruction event. Cost of destruction per unit can vary between $1/unit to $0.25/unit.

  • We charge our brands based on the amount of product they need to destroy compared to the total amount of units that will be destroyed. So if ‘Cannabis Company’ has 100 units that need to be destroyed, and we are destroying a total of 1,000 units total, and the destruction event costs $1,000, we would charge ‘Cannabis Company’ $100. Due to us facilitating larger destruction events, it is more cost-effective for the brand to facilitate a destruction event through our license.

 

How Do I Start Testing Through Nabis?

  • Brands usually let us know they want Nabis to test our product when they are onboard, but at times, tenured brands will request testing at our facility. We like to make this as easy and streamlined as possible for our brands. We will just ask that they email compliance@nabis.com the order number for the first shipment that they send us that needs testing, and let us know the lab they prefer. We will add this data to our testing tracker and handle the testing from there. The brands will need to set up their inventory as usual and create proper batches with all the correct information, but skip adding the COA.

  • Our Quarantine team will keep an eye out for all future intakes from brands we test for and set up the test event as soon as the product is fully taken into our system if there is no compliance or Metrc issues. We already work with a lot of the California labs, but if we do ever work with a new lab, we will have to reach out to understand their processes and might have to set up an account in their portal. Once the COA’s are released, we will upload the COA into our portal, make the inventory live, and notify the brand.

 

What is a Return From Retailer?

  • Return From Retailer Orders are placed when Nabis delivers products that the retailer signed for, and the retailer requests to return the product back to Nabis Distribution.

  • This differs from a Rejection, which is when a product is taken to the retailer, the retailer does not accept it, and the driver brings the product back to Nabis the same day.

  • Please note that the order types above are not considered a Nabis Mispack, which is when there is a discrepancy upon delivery in the quantity and/or product ordered, and a swap or redelivery needs to take place.

    • These order types can only be submitted by Nabis Admins, not brand users.

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