Four Years, Not Two: NJ Cannabis Transport Record Retention
N.J.A.C. 17:30-13.3(a)(1) for distributors. 17:30-14.5(a)(1) for retailers. Four years.
Plenty of operators believe it is two. That belief usually comes from another state's rule or from a vendor's default retention setting, and it is an expensive thing to be wrong about — a record you cannot produce is indistinguishable from a record that never existed.
What has to survive four years
- Transport requests and manifests
- The chain of custody for each load
- Vehicle records for the vehicles used
- Driver credentials as they were on the transport date
- Insurance certificates in force on that date
- Delivery confirmations and signatures
- Records of refused or returned product
The part that catches people
Credentials as they were at the time. Not current status — status then.
If a driver's Cannabis Business Identification Card expired in June and you carry a load in July, "we renewed it in August" is not an answer. The question is what was true on the day.
Same for insurance. Same for vehicle registration.
That means retention is not just archiving documents. It is keeping a record of what was true when, which most document management does not do.
Practical implications
Four years of GPS trails, temperature logs, signatures and scans is a lot of data, and it has to remain retrievable, not merely stored. A backup you cannot search is not a record.
It also has to survive staff turnover. The person who knows where the signature folder is will leave within four years.