Waste, Returns, Recall, and Destruction Rules

Anything that leaves your shelves without being sold, including damaged product, expired product, customer returns, or products flagged for recall, becomes a regulated event.

OCM tracks waste the same way it tracks sales, and inspectors review these logs during every inspection.

This page explains how to log waste, store it, destroy it, and prove compliance.

Returns (Customer to Quarantine)

New York does not allow reselling returned cannabis — ever.

When a customer returns product:

Do not place it back into inventory
Move it into Quarantine immediately
Log the return in the POS system
Create a quarantine or waste package in METRC
Store it in a separate, labeled, restricted area
Destroy it using approved methods

Returned products are automatically considered waste.

What Goes Into Quarantine

You must place the following items into quarantine:

Returned products
Opened packages
Damaged packaging
Products past the labeled expiration date
Products with broken seals
Products suspected of contamination
Any item flagged during inspection
Products subject to recall

The quarantine area must be:

Clearly labeled “Quarantine — Not for Sale”
Physically separated from sellable inventory
Restricted to authorized staff only

Waste Rules (Physical and METRC)

Waste must be tracked both physically and in METRC.

You must:

Create a waste package in METRC
Record batch or lot number
Record weight or quantity
Record product type
Record the reason for waste
Update physical inventory to match METRC
Store waste securely
Destroy product before closing the METRC waste package

If METRC shows waste but the product still exists physically, it will be flagged.

Destruction Rules

Destruction must make the product:

Irreversible
Unrecognizable
Unusable

You must document:

Staff present
Pre-destruction weight
Post-destruction weight
Date and time
Method used
Final disposal documentation

Best practice is to use two staff members during destruction.

Disposal Methods You Are Allowed to Use

Grind and Mix Method (Standard)

Cannabis waste must be mixed with a non-cannabis material until unusable.

Approved materials include:

Cat litter
Sawdust
Cardboard pulp
Coffee grounds
Food waste

The final mixture must be at least fifty percent non-cannabis by volume.

Licensed Solid Waste Facility

You may dispose of the final mixture at:

Licensed solid waste transfer stations
Landfills
Waste-to-energy facilities

All receipts and disposal documentation must be retained.

Cannabis Waste Disposal Vendors

You may use a licensed vendor if they:

Are legally authorized
Provide disposal manifests
Issue certificates of destruction

Recalls (Voluntary and Mandatory)

A recall may be initiated by:

Office of Cannabis Management
Processor
Distributor
Testing laboratory
Your dispensary (voluntary)

Retailer responsibilities include:

Immediately stopping sales of affected product
Moving product into quarantine
Blocking the product in the POS system
Following all OCM instructions
Documenting each step
Destroying or returning product as directed

You may be required to provide OCM with:

Product counts
Batch numbers
Removal dates
Final disposal records
Consumer notification, if required

Recordkeeping Requirements

You must retain the following records for at least five years:

Return logs
Quarantine logs
Waste and destruction logs
METRC waste entries
Disposal facility receipts or vendor manifests
Recall notices
Staff destruction sign-offs
Inventory discrepancy reports

All records must be on-site and accessible during inspections.

Inspection Expectations

Inspectors routinely check:

Quarantine area labeling and access
Physical waste versus METRC entries
Expired or damaged products on shelves
Waste and destruction logs
Destruction documentation
Whether returned or damaged items are mixed into sellable inventory

Expect to provide METRC reports and verify counts on request.

Common Violations

Frequent violations include:

Placing returned items back on shelves
Failing to log damaged or expired products
Leaving METRC waste packages open too long
Destroying product without documentation
Disposing cannabis in regular trash
Failing to label or restrict quarantine areas
Destroying product without a witness
Physical and digital inventory mismatches

Why This Matters

Mishandling waste, returns, or recalls can result in:

Failed inspections
Fines or stop-sale orders
Compliance warnings
Delays in operational approvals
Increased inspection frequency
License risk

This is one of the most common and avoidable sources of violations.

Source Material

MRTA
9 NYCRR Waste and Disposal Regulations
METRC New York Waste Guide

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