ColoradoSuspensionHigh severity

Colorado MED Suspends Cultivator License Over METRC Inventory Discrepancies (March 2025)

Colorado's Marijuana Enforcement Division issued an emergency 30-day suspension to a Front Range cultivator after routine audit revealed over 400 untracked plants in the state METRC seed-to-sale system. The licensee has been ordered to reconcile all inventory before reinstatement proceedings may begin.

Robert Hoban

Principal & Managing Attorney, Hoban Law Group

Colorado Bar

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Agency
Colorado Marijuana Enforcement Division
Action type
Suspension
Published
March 14, 2025
Effective
March 14, 2025
License type
cultivator
Party
MSO Cultivator A (anonymized)
Citation
1 CCR 212-3, Rule R 402; C.R.S. § 44-10-601

Background

The Marijuana Enforcement Division (MED) conducted a scheduled compliance audit at a licensed cultivation facility in Weld County on March 11, 2025. Investigators from the MED Compliance Enforcement Unit identified 412 cannabis plants with no corresponding METRC plant tags and 38 pounds of dried flower not logged in the state tracking system.

Enforcement Action

Pursuant to 1 CCR 212-3, Rule R 402, the MED issued an Emergency Suspension Order effective March 14, 2025. The order requires the licensee to:

  1. Immediately cease all cultivation and transfer operations.
  2. Submit a complete reconciliation report accounting for all untracked inventory within 14 calendar days.
  3. Cooperate fully with MED investigators during the reconciliation review.

Key Regulatory Citations

  • 1 CCR 212-3, Rule R 402 — Inventory tracking and METRC compliance requirements
  • C.R.S. § 44-10-601 — License suspension authority for tracking violations

Implications

Cultivators operating in Colorado must maintain real-time METRC synchronization. Discrepancies exceeding 5% of total inventory or any untagged plants may trigger emergency suspension without prior notice. License reinstatement requires a full audit pass and a compliance plan approved by MED.

Attorney Commentary

This action reflects the MED's zero-tolerance posture on METRC integrity heading into Q2 2025. Licensees should conduct internal METRC audits quarterly at minimum and ensure all harvest activities are logged within the 24-hour statutory window.

Hoban Law Group

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