- Title
- State of Vermont Cloud Hosted Cannabis Laboratory Information System (LIMS)
- Pdf Text
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Department of Buildings and General Services Agency of Administration
Office of Purchasing & Contracting
133 State Street, 5th Floor | Montpelier VT 05633-8000
802-828-2211 phone |802-828-2222 fax
http://bgs.vermont.gov/purchasing
SEALED BID
REQUEST FOR PROPOSAL
State of Vermont Cloud Hosted Cannabis Laboratory
Information System (LIMS)
ISSUE DATE October 16, 2026
QUESTIONS DUE October 26, 2026 – 4:30pm (ET)
RFP RESPONSES DUE BY November 6, 2026 – 4:30 PM (ET)
PLEASE BE ADVISED THAT ALL NOTIFICATIONS, RELEASES, AND ADDENDUMS ASSOCIATED
WITH THIS RFP WILL BE POSTED AT:
http://www.bgs.state.vt.us/pca/bids/bids.php
THE STATE WILL MAKE NO ATTEMPT TO CONTACT INTERESTED PARTIES WITH UPDATED
INFORMATION. IT IS THE RESPONSIBILITY OF EACH BIDDER TO PERIODICALLY CHECK THE
ABOVE WEBPAGEFOR ANY AND ALL NOTIFICATIONS, RELEASES AND ADDENDUMS
ASSOCIATED WITH THIS RFP.
STATE CONTACT: Kyle Emerson, State Purchasing Agent
E-MAIL: SOV.ThePathForward@vermont.gov
USE SUBJECT : VCCB LIMS
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1. OVERVIEW:
1.1. SCOPE AND BACKGROUND: Through this Request for Proposal (RFP) the State of Vermont Cannabis
Control Board (CCB) (hereinafter the “State”) is seeking to establish contracts with one or more
companies that can provide a Cloud Hosted Cannabis Laboratory Information System (LIMS).
1.2. CONTRACT PERIOD: Any Contract(s) arising from this RFP will be for a period of three years with an
option to renew for up to two additional twelve-month periods. The State anticipates the start date for
such contract(s) will be December 12, 2026.
1.3. SINGLE POINT OF CONTACT: All communications concerning this RFP are to be addressed in writing
to the State Contact listed on the front page of this RFP. Actual or attempted contact with any other
individual from the State concerning this RFP is strictly prohibited and may result in disqualification.
1.4. QUESTION AND ANSWER PERIOD: Any bidder requiring clarification of any section of this RFP or
wishing to comment on any requirement of the RFP must submit specific questions in writing no later than
the deadline for question indicated on the first page of this RFP. Questions may be e-mailed to the point
of contact on the front page of this RFP. Questions or comments not raised in writing on or before the last
day of the question period are thereafter waived. At the close of the question period a copy of all
questions or comments and the State's responses will be posted on the State’s web site
http://www.bgs.state.vt.us/pca/bids/bids.php . Every effort will be made to post this information as soon as
possible after the question period ends, contingent on the number and complexity of the questions. All
information provided by vendors during this process will be public and bidders shall not provide
confidential information, except as described in 4.1 below.
1.5. CHANGES TO THIS RFP: Any modifications to this RFP will be made in writing by the State through the
issuance of an Addendum to this RFP and posted online at http://www.bgs.state.vt.us/pca/bids/bids.php .
Modifications from any other source are not to be considered.
2. DETAILED REQUIREMENTS/DESIRED OUTCOMES:
2.1. The State of Vermont is interested in obtaining bids to meet the following business need(s):
The State of Vermont CCB Quality Control Laboratory is anticipated to open in November 2026. The
laboratory will provide testing for cannabis potency, shelf-life, and the presence of pesticides and
pathogens; the CCB Compliance team requires these testing services to ensure product safety and quality
standards.
The outcome of this RFP is to select and contract with a vendor to provide the State with a cloud Hosted
LIMS (Laboratory Information Management System), configured with a cannabis targeted module, to allow
the State to meet the basic requirements of effectively managing the operations of a modern laboratory.
2.2. Functional and Non-Functional Requirements – Detailed functional and non-functional, assay, and
implementation requirements are provided in Exhibit A – Vermont Cannabis Control Board Business Rules,
Exhibit B – Vermont Cannabis Control Board Laboratory Assay List, and Exhibit C – Bidder Response Form
(Part 3: Functional Requirements, Part 4: Non-Functional Requirements). These exhibits are incorporated
into this RFP and, together, define the detailed requirements against which proposals will be evaluated.
2.2.1.Functional Requirements: The proposed solution shall provide the functionality necessary to
support the CCB QC Laboratory’s sample management, laboratory analysis, reporting, and LIMS
administration needs. Requirements include, but are not limited to, sample intake and tracking;
sample identification, labeling, and photography; assay and analyte management; laboratory run and
test-result management; instrument integration; quality control and review workflows; Certificate of
Analysis (COA) generation, review, and release; notifications and reporting; configurable
specifications, users, labels, and COA layouts; and the ability to support and scale testing capabilities
as regulatory and laboratory needs evolve. The solution shall support the cannabis testing
requirements identified by CCB, including potency, pesticides, pathogens, mycotoxins, and residual
solvents, and shall enable CCB-branded COAs
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2.2.2.Non-Functional Requirements: The proposed solution shall meet the State’s technical, operational,
authentication, and security requirements, including, but not limited to, hosting and data center
requirements; backup, recovery, data retention, and disaster recovery; application management and
service-level expectations; integration with the State’s identity providers and authentication standards;
and documented security practices, controls, monitoring, and compliance.
2.2.3.Data Compliance
2.2.3.1. Solutions must adhere to applicable State and Federal standards, policies, and laws based
on the type of data that will be stored, accessed, transmitted and/or controlled by the solution.
2.2.3.2. Data Compliance requirements are included in Exhibit C – Bidder Response Form part
4.5. The boxes in the table that are checked are applicable to the solution
2.2.3.3. The system will hold pre-released test results, OOS findings that trigger enforcement, and
licensee identity (sole-proprietor cultivators are individuals)
3. GENERAL REQUIREMENTS:
3.1. PRICING: Bidders must price the terms of this solicitation at their best pricing. Any and all costs that
Bidder wishes the State to consider must be submitted for consideration. If applicable, all equipment
pricing is to include F.O.B. delivery to the ordering facility. No request for extra delivery cost will be
honored. All equipment shall be delivered assembled, serviced, and ready for immediate use, unless
otherwise requested by the State.
3.1.1.Prices and/or rates shall remain firm for the initial term of the contract. The pricing policy submitted by
Bidder must (i) be clearly structured, accountable, and auditable and (ii) cover the full spectrum of
materials and/or services required.
3.1.2.Cooperative Agreements. Bidders that have been awarded similar contracts through a competitive
bidding process with another state and/or cooperative are welcome to submit the pricing in response
to this solicitation.
3.2. STATEMENT OF RIGHTS: The State shall have the authority to evaluate Responses and select the
Bidder(s) as may be determined to be in the best interest of the State and consistent with the goals and
performance requirements outlined in this RFP. The State of Vermont reserves the right to obtain
clarification or additional information necessary to properly evaluate a proposal. Failure of bidder to
respond to a request for additional information or clarification could result in rejection of that bidder's
proposal. To secure a project that is deemed to be in the best interest of the State, the State reserves the
right to accept or reject any and all bids, in whole or in part, with or without cause, and to waive
technicalities in submissions. The State also reserves the right to make purchases outside of the awarded
contracts where it is deemed in the best interest of the State.
3.2.1.Best and Final Offer (BAFO). At any time after submission of Responses and prior to the final
selection of Bidder(s) for Contract negotiation or execution, the State may invite Bidder(s) to provide a
BAFO. The state reserves the right to request BAFOs from only those Bidders that meet the minimum
qualification requirements and/or have not been eliminated from consideration during the evaluation
process.
3.2.2.Presentation. An in-person or webinar presentation by the Bidder may be required by the State if it
will help the State’s evaluation process. The State will factor information presented during
presentations into the evaluation. Bidders will be responsible for all costs associated with providing
the presentation.
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3.3. CONFLICTS OF INTEREST:
3.3.1.Organizational Conflict of Interest (OCOI): An OCOI arises when a bidder as a business entity has
interests (for example, customers, partners, contracts) that could undermine, or reasonably be
perceived to undermine, its faithful and unbiased performance of a contract with the State that may
result from this solicitation.
3.3.2.Personal Conflict of Interest (PCOI): A PCOI arises when an interest held by an individual, agent or
employee of a bidder could undermine, or reasonably be perceived to undermine, its faithful and
unbiased performance of a contract with the State that may result from this solicitation.
3.3.3.Requirements: The State does not seek to contract with any individual or business entity having a
conflict of interest which cannot be mitigated to the State’s satisfaction. To ensure the State’s
awareness of actual, potential, or reasonably perceived PCOIs and OCOIs, bidders shall:
a) Prior to submitting a proposal, conduct an internal review of its current affiliations and activities and
identify actual, potential, or reasonably perceived PCOIs or OCOIs relative to a contract with the
State that may result from this solicitation.
b) Disclose in your proposal any actual or potential PCOI or OCOI or the existence of any facts that
may cause a reasonably prudent person to perceive a PCOI or OCOI with respect to a contract
with the State that may result from this solicitation. Disclose, also, any actions proposed to mitigate
the PCOI or OCOI.
3.3.4.The State shall have sole discretion to determine whether a PCOI or OCOI can be mitigated to the
State’s satisfaction and may discuss the conflict with the bidder if and to the extent the State deems
discussion necessary to its determination. The State reserves the right to (a) reject from further
consideration any proposal having a PCOI or OCIO that cannot be mitigated to the State’s full
satisfaction and (b) terminate a contract upon discovery that a contractor failed to disclose facts
pertaining to a PCOI or OCOI in its proposal, or otherwise misrepresented relevant information to the
State.
3.4. WORKER CLASSIFICATION COMPLIANCE REQUIREMENTS: In accordance with Section 32 of The
Vermont Recovery and Reinvestment Act of 2009 (Act No. 54), Bidders must comply with the following
provisions and requirements.
3.4.1.Self Reporting: For bid amounts exceeding $250,000.00, Bidder shall complete the appropriate
section in the attached Certificate of Compliance for purposes of self-reporting information relating to
past violations, convictions, suspensions, and any other information related to past performance
relative to coding and classification of workers. The State is requiring information on any violations
that occurred in the previous 12 months.
3.4.2.Subcontractor Reporting: For bid amounts exceeding $250,000.00, Bidders are hereby notified that
upon award of contract, and prior to contract execution, the State shall be provided with a list of all
proposed subcontractors and subcontractors’ subcontractors, together with the identity of those
subcontractors’ workers compensation insurance providers, and additional required or requested
information, as applicable, in accordance with Section 32 of The Vermont Recovery and
Reinvestment Act of 2009 (Act No. 54). This requirement does not apply to subcontractors providing
supplies only and no labor to the overall contract or project. This list MUST be updated and provided
to the State as additional subcontractors are hired. A sample form is available online at
http://bgs.vermont.gov/purchasing-contracting/forms. The subcontractor reporting form is not
required to be submitted with the bid response.
3.5. EXECUTIVE ORDER 05-16: CLIMATE CHANGE CONSIDERATIONS IN STATE PROCUREMENTS:
For bid amounts exceeding $25,000.00 Bidders are requested to complete the Climate Change
Considerations in State Procurements Certification, which is included in the Certificate of Compliance for
this RFP.
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After consideration of all relevant factors, a bidder that demonstrates business practices that promote
clean energy and address climate change as identified in the Certification, shall be given favorable
consideration in the competitive bidding process. Such favorable consideration shall be consistent with
and not supersede any preference given to resident bidders of the State and/or products raised or
manufactured in the State, as explained in the Method of Award section. But, such favorable
consideration shall not be employed if prohibited by law or other relevant authority or agreement.
3.6. METHOD OF AWARD: Awards will be made in the best interest of the State. The State may award one or
more contracts and reserves the right to make additional awards to other compliant bidders at any time if
such award is deemed to be in the best interest of the State.
3.6.1.Evaluation Criteria: Consideration shall be given to the Bidder’s project approach and methodology,
qualifications and experience, ability to provide the services within the defined timeline, cost, and/or
success in completing similar projects, as applicable, and to the extent specified below:
Evaluation Factors Total Points for
This Factor
Ability to meet functional and non-functional requirements 25%
Total Cost 25%
Timeline for implementation 20%
Qualifications and Experience in Cannabis LIMS solution 15%
Project approach and methodology 15%
3.7. CONTRACT NEGOTIATION: Upon completion of the evaluation process, the State may select one or
more bidders with which to negotiate a contract, based on the evaluation findings and other criteria
deemed relevant for ensuring that the decision made is in the best interest of the State. In the event State
is not successful in negotiating a contract with a selected bidder, the State reserves the option of
negotiating with another bidder, or to end the proposal process entirely.
3.8. COST OF PREPARATION: Bidder shall be solely responsible for all expenses incurred in the preparation
of a response to this RFP and shall be responsible for all expenses associated with any presentations or
demonstrations associated with this request and/or any proposals made.
3.9. CONTRACT TERMS: The selected bidder(s) will be expected to sign a contract with the State,
including the Standard Contract Form, Attachment C and Attachment D as attached to this RFP for
reference. If you are unable to agree to the contract or supplemental terms and conditions, please
identify them in your RFP response. Please note that these provisions are standard for State
contracts and generally cannot be modified.
3.10.Business Registration. To be awarded a contract by the State of Vermont a bidder (except an individual
doing business in his/her own name) must be registered with the Vermont Secretary of State’s office
https://sos.vermont.gov/corporations/registration/and must obtain a Contractor’s Business Account Number
issued by the Vermont Department of Taxes http://tax.vermont.gov/ .
3.10.1. The contract will obligate the bidder to provide the services and/or products identified in its bid, at
the prices listed.
3.11.Payment Terms. Percentage discounts may be offered for prompt payments of invoices; however, such
discounts must be in effect for a period of 30 days or more in order to be considered in making awards.
3.12.Retainage. In the discretion of the State, a contract resulting from this RFP may provide that the State
withhold a percentage of the total amount payable for some or all deliverables, such retainage to be
payable upon satisfactory completion and State acceptance in accordance with the terms and conditions
of the contract.
3.13.Quality. If applicable, all products provided under a contract with the State will be new and unused, unless
otherwise stated. Factory seconds or remanufactured products will not be accepted unless specifically
Revised February 13, 2026
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requested by the purchasing agency. All products provided by the contractor must meet all federal, state,
and local standards for quality and safety requirements. Products not meeting these standards will be
deemed unacceptable and returned to the contractor for credit at no charge to the State.
3.14.DEMONSTRATION: An in-person or webinar demonstration by the Bidder may be required by the State if
it will help the State’s evaluation process. The State will factor information presented during
demonstrations into the evaluation. Bidder will be responsible for all costs associated with the providing
the demonstration.
3.15.INDEPENDENT REVIEW: Certain State information technology projects require independent expert
review as described under 3 V.S.A. § 3303(d). Such review, if applicable, will inform the State’s decision to
award any contract(s) resulting from this RFP.
4. Exhibit D - Requirement for Bidders to Disclose AI usage in Proposals: Bidders are responsible for
reviewing and considering all requirements and information contained in Exhibit D as part of preparing their
proposal. Bidders shall ensure that their proposed solution and approach address all applicable requirements
identified in Exhibit D.
5. CONTENT AND FORMAT OF RESPONSES: The content and format requirements listed below are the
minimum requirements for State evaluation. These requirements are not intended to limit the content of a
Bidder’s proposal. Bidders may include additional information or offer alternative solutions for the State’s
consideration. However, the State discourages overly lengthy and costly proposals, and Bidders are advised to
include only such information in their response as may be relevant to the requirements of this solicitation.
5.1. Unsolicited Bidder-Confidential Information Prohibited. Bidders are hereby expressly directed not to
include any confidential information in their proposal submissions, except as specifically permitted below.
By submitting a proposal in response to this RFP, vendors acknowledge and agree to abide by the terms
and conditions outlined in this document, including the prohibition on submitting confidential information.
This prohibition reduces the burden on the State while preventing vendor-confidential information from
entering the public record.
5.2. Disclosure under Public Records Act. All information received by the State in response to this
solicitation will become part of the contract file and subject to public disclosure in accordance with the
State’s Public Records Act, 1 V.S.A. § 315 et seq. The State may also choose to publicly post responses
to this solicitation and the resulting agreement(s), following conclusion of this procurement process.
5.3. Unsolicited Confidential Materials. This RFP does not solicit bidder confidential information and bidders
are expressly prohibited from providing confidential information in response to this RFP. All materials
furnished by bidders in response to this RFP, including those marked as confidential by bidders, are
subject to disclosure if requested under the Public Records Act, or public posting.
5.4. State Not Responsible for Disclosure of Unmarked Bidder-Confidential Information. It is the
sole responsibility of the bidder to ensure that, other than where specifically directed or permitted by this
RFP and accordingly marked as described below, no information that should not be publicly disclosed is
included in their proposal materials, including any 1) trade secrets or intellectual property, 2) proprietary
financial or business information, 3) personal information, or 4) any other information that should not be
disclosed to the public. For example, bidders should avoid including specific details of their proprietary
technologies or methodologies that they consider confidential, and any references to previous client
engagements should be presented in a manner that does not disclose the client's confidential information.
5.5. The bid should include a Cover Letter and Technical Response and Price Schedule.
5.6. COVER LETTER:
5.6.1.Exceptions to Contract Terms and Conditions. Bidders are expected to accept State terms,
conditions, and templates as set forth in the sample contract attached to this RFP. By submitting a
proposal in response to this RFP, bidders are confirming their concurrence unless, and then only to
the extent bidder proposes exceptions in the Bidders Response Form attached to this RFP (if one is
used) or otherwise in the cover letter to bidder’s proposal. However, the State is not bound to accept
any exceptions and taking such exceptions may cause a proposal to be not in the best interests of the
State. If exceptions are not noted in the response to this RFP but raised during contract negotiations,
the State reserves the right to cancel the negotiation if deemed to be in the best interests of the State.
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5.7. TECHNICAL RESPONSE. In response to this RFP, a bidder shall:
5.7.1.Provide details concerning your form of business organization, company size and resources.
5.7.2.Describe your capabilities and particular experience relevant to the RFP requirements.
5.7.3.If you have experience working with the State of Vermont, identify all current or past State projects.
Provide the name of the Vermont department or agency and the project title or a brief description of
the work. Do not include references or statements from State of Vermont agencies or employees.
5.7.4.Identify the names of all subcontractors you intend to use, the portions of the work the subcontractors
will perform, and address the background and experience of the subcontractor(s), in response to the
questions described above in this section.
5.8. REFERENCES. Provide the names, addresses, and phone numbers of at least three companies with
whom you have transacted similar business in the last 12 months. You must include contact names who
can talk knowledgeably about performance. Do not list a State of Vermont agency or employee as a
reference.
5.9. REPORTING REQUIREMENTS: Provide a sample of any reporting documentation that may be applicable
to the Detailed Requirements of this RFP.
5.10.PRICE SCHEDULE: Bidders shall submit their pricing information in the Price Schedule included in the
Bidder Response Form.
5.11.STATE OF VERMONT BIDDER RESPONSE FORM: This form must be completed and submitted as part
of the response for the proposal to be considered valid. The State of Vermont Bidder Response Form
provides a standard format and content for bidder proposals. When required, this form will prompt Bidders
to supply the information required in the above RFP sections 5.6 through 5.9 Note: In addition to
completing the State of Vermont Bidder Response Form, Bidders are required to provide the specific
attachments that are described within the Bidder Response Form.
6. SUBMISSION INSTRUCTIONS:
6.1. CLOSING DATE: Bids must be received by the State by the due date specified on the front page of this
RFP. Late bids will not be considered.
6.1.1.The State may, for cause, issue an addendum to change the date and/or time when bids are due. If a
change is made, the State will inform all bidders by posting at the webpage indicated on the front
page of this RFP.
6.1.2.There will not be a public bid opening. However, the State will record the name, city and state for any
and all bids received by the due date.
6.2. ELECTRONIC BIDS ONLY: All bids under this RFP must be submitted electronically in accordance with
the submission requirements herein.
6.2.1.Electronic bids will be accepted via email submission to SOV.ThePathForward@vermont.gov. The
subject line of the email submission must reference the Project Title as indicated on the front page of
this RFP.
6.2.1.1. Bids must consist of a single email with a single, digitally searchable PDF attachment
containing all components of the bid. Multiple emails and/or multiple attachments will not be
accepted.
6.2.1.2. There is an attachment size limit of 40 MB. It is the Bidder’s responsibility to compress the PDF
file containing its bid if necessary in order to meet this size limitation. It is also the Bidder's
responsibility to ensure that their own email system can send and receive messages up to this
size.
Revised February 13, 2026
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7. BID SUBMISSION CHECKLIST:
Cover Letter
Redacted Technical Response, if applicable
Exhibit C State of Vermont Bidder Response Form and Attachments
o Technical Response (included in Bidder Response Form)
o References (included in Bidder Response Form)
o Price Schedule (included in Bidder Response Form)
8. ATTACHMENTS:
8.1. Worker Classification Compliance Requirement; Subcontractor Reporting Form
8.2. Exhibit A – Vermont Cannabis Control Board Business Rules
8.3. Exhibit B – Vermont Cannabis Control Board Laboratory Assay List
8.4. Exhibit C – State of Vermont Bidder Response Form
8.5. Exhibit D – Requirement for Bidder to Disclose AI Usage in Proposal
8.6. Standard State Contract with its associated attachments
8.7. Attachment C – Standard State Provisions for Contracts and Grants (February 13, 2026)
8.8. Attachment D – Information Technology System Implementation Terms and Conditions (rev. 12/09/2025)
Revised February 13, 2026
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RFP/PROJECT:
DATE:
SUBCONTRACTOR REPORTING FORM
This form must be completed in its entirety and submitted prior to contract execution and updated as
necessary and provided to the State as additional subcontractors are hired.
The Department of Buildings and General Services in accordance with Act 54, Section 32 of the Acts of 2009 and for
total project costs exceeding $250,000.00 requires bidders to comply with the following provisions and requirements.
Contractor is required to provide a list of subcontractors on the job along with lists of subcontractor’s subcontractors
and by whom those subcontractors are insured for workers’ compensation purposes. Include additional pages if
necessary. This is not a requirement for subcontractor’s providing supplies only and no labor to the overall contract
or project.
Subcontractor Insured By Subcontractor’s Sub Insured By
Date:
Name of Company: Contact Name:
Address: Title:
Phone Number:
E-mail: Fax Number:
By: Name:
Failure to adhere to Act 54, Section 32 of the Acts of 2009 and submit Subcontractor Reporting: Worker
Classification Compliance Requirement will constitute non-compliance and may result in cancellation of contract
and/or forfeiture of future bidding privileges until resolved.
Send Completed Form to: State Contracting Entity
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Attachment C is included in this RFP for reference
ATTACHMENT C: STANDARD STATE PROVISIONS
FOR CONTRACTS AND GRANTS
REVISED FEBRUARY 13, 2026
“Attachment C: Standard State Provisions for Contracts and Grants” (revision version dated February 13,
2026) constitutes part of this Agreement and is hereby incorporated by reference as if fully set forth herein
and shall apply to the Contractor and to the purchase of all goods and/or services by the State under this
Agreement. A copy of this document is available online at: https://bgs.vermont.gov/purchasing-
contracting/forms.
ADS Business Transformation Office | CCB LIMS | Business Rules
Version 1.0
updated 11/4/2025
Exhibit A - Vermont Cannabis Control Board Business Rules
Business Rule Title Business Rule Rule Owner Origin Date Source
Vermont Cannabis Control Board Adopted Rule 2
Cultivators must have their products tested in accordance with rules and guidance established in
Section 2.9 of the State of Vermont CCB Adopted Rule 2. Testing for potency of a crop must take place within the three-week
period preceding a harvest. Other testing will occur in accordance with the relevant regulations
and policies. Test results shall be saved for no less than 1 year.
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Testing for Product Form - General Harvest Lot All cultivars must be individual tested for potency and pathogens. Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Testing for Product Form - Smokable Flower Smokable flower must be test for water activity; up to five simultaneously submitted cultivars may be comingled by the laboratory
for pesticide testing. Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Testing for Product Form - Mechanically Extracted
or Infused Process Lots For mechanically extracted or infused process lots, final potency of extract must be tested. Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Required COAs for Mechanically Extracted or
Infused Process Lots For mechanically extracted or infused process lots, harvest lot pesticide and pathogen COAs must travel with extract.
Testing for Product Form - Solvent Extracted
Process Lots
For all solvent extracted lots: the following must be tested:
- Pesticides
- Residual solvents
- Potency
- Heavy Metals
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Testing for Product Form - Finished Edible Products
For finished edible products, The following must be tested:
i. Final product potency
ii Potency consistency/homogeneity (tier and product dependent)
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Required COAs for Finished Edible Products For finished edible products, harvest lot or process lot COAs must travel with the products.
Required COAs for Manufactured Process Lots For manufactured process lots, COAs from all process lots in the manufacturing process lot must be associated with the
manufacturing process lots. Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Transfer Requirements
All cannabis harvest lots, process lots, and products must be tested in accordance with the Laboratory Testing Action Limits and
Parameter Guidance prior to transfer or sale. Licensees are responsible for submitting samples to a certified laboratory for
required testing and obtainment of necessary Certificates of Analysis (COAs).
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
COA for Transfer: Mechanically-Extracted Solvents For mechanically-extracted solvents, all COAs from underlying flower must be appended to the transfer form in inventory tracking. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
COA for Transfer: Edible Products For edible products, all COAs from underlying flower or concentrate must be appended to the transfer form in inventory tracking. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
COA for Transfer: Solvent-Extracted Solvent For solvent-extracted concentrates, all COAs from underlying flower must be appended to the transfer form in inventory tracking. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
COA for Transfer: Topical Products For topical products, all underlying flower or concentrate COAs must be appended to the transfer form in inventory tracking. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
COA for Transfer: Edible Products For edible products, all COAs from underlying flower or concentrate must be appended to the transfer form in inventory tracking. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Water Activity Testing Cannabis Flower must have a Water Activity test of .65 or lower to be registered as a smokable flower. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Potency Testing All cannabis and cannabis products must undergo potency testing before registration for retail sale. Flower for retail sale may not
exceed 30% THC. Solid concentrates offered for retail sale may not exceed 60% THC. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Pathogen Testing All flower must be tested for pathogens. All mechanically extracted concentrates to be sold at retail must undergo pathogen
testing. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Pathogen Testing - Required Tests
The following human pathogens will be measured, and the limits set, in accordance with guidance issued by the Vermont CCB:
- Shiga, toxin producing Escherichia coli (STEC)
- Salmonella
- Aspergillus
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Pathogen Testing - Microbial Testing Methods
Microbial testing for cannabis and cannabis products shall be analyzed by the following allowable methods:
1) a validated method using guidelines for food and environmental testing put forth by the USP, FDA, and AOAC Appendix J and
cannabis as a sample type; or
2) Another approved AOAC, FDA, or validate method using cannabis as a sample type. This can include molecular methods such as
qPCR.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Aspergillus Testing Initial aspergillus testing must analyze for both live and free DNA. Initial testing may not eliminate free aspergillus DNA from the
sample. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Aspergillus Testing - Positive Samples
If first sample is positive for aspergillus, licensee may submit up to 2 additional samples for confirmation testing. Of the 2 additional
samples, one positive test result will confirm the product is positive for aspergillus. If both additional samples test negative, the
product will be confirmed negative for aspergillus. Confirmation testing must be performed by the laboratory that tested the
original sample.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Aspergillus Testing - Negative Samples If first sample is negative for aspergillus, product may move through the channels of trade. Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Metals Testing
The following metals will be measured and the limits set in accordance with guidance issued by the Vermont CCB:
- Arsenic
- Cadmium
- Lead
- Mercury
- Chromium
- Copper
- Nickel
- Zinc
Specific Action Limits for each required metal test can be found in the Laboratory Testing Action Limit and Parameter Guidance .
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
ADS Business Transformation Office | CCB LIMS | Business Rules
Version 1.0
updated 11/4/2025
Business Rule Title Business Rule Rule Owner Origin Date Source
Terpene Testing
A terpene test is required for the following products offered for retail sale:
- Concentrates intended for inhalation or vaporization. (Dry sift hash and bubble hash products intended for
inhalation or vaporization do not need a terpene test, unless indicated on the label. All rosin products intended
for inhalation must be tested for terpenes, regardless of whether terpene content is indicated on the label.)
- Any product in which terpenes have been removed and reintroduced.
- Any product with added terpenes.
- Any product that indicates terpene content on the label.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Terpene Testing Limits
The total terpene content of a cannabis product intended for inhalation or vaporization may not exceed 10
percent by weight.
Higher terpene concentration is acceptable only if a manufacturer demonstrates to the Board’s satisfaction that
the concentration was achieved naturally from the source plant without use of any additives.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Residual Solvent Testing
The following solvents will be measured and the limits set in accordance with guidance issued by the Vermont CCB:
- Acetone
- Acetonitrile
- Benzene
- Butane
- Chloroform
- Ethanol
- Heptanes
- Hexanes
- Isopropyl alcohol
- Methanol
- Methylene Chloride
- Propane
- Toluene
- Xylenes
- Any solvent not permitted for extraction
Specific Action Limits for each required residual solvent test can be found in the Laboratory Testing Action Limit
and Parameter
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Pesticide Testing
GT hueidfaonl lcoew i n g pesticides will be measured and the limits set in accordance with guidance issued by the Vermont
CCB:
- Acephate
- Acequinocyl
- Abamectin
- Azoxystrobin
- Bifenazate
- Bifenthrin
- Carbaryl
- Chlorpyrifos
- Cypermethrin
- Etoxazole
- Imazalil
- Imidacloprid
- Myclobutanil
- Pyrethrins I and II
- Spinosyn
Specific Action Limits for each required pesticide test can be found in the Laboratory Testing Action Limit and
Parameter
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Pesticide Testing - Comingled
Sample Results
If a comingled sample results in any quantifiable pesticide detection below the action limit, each individual strain
included in the
comingled sample must be analyzed for pesticides, and only the individual strain test results shall be reported
back to the sample submitter.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Board Reporting by Licensees
Pursuant to Board Rule 2.2.19, licensees must make a prompt report to the Board upon discovery of adulterated
cannabis or cannabis product, regardless of cause or fault. This includes not only cannabis/cannabis products with
test results exceeding action limits, but also samples with pesticide results below the action limit but above the
limit of quantification.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
Actionable Test Results
Notification by Laboratories
Licensed laboratories must promptly notify the Board of non-compliant final test results by emailing
ccb.compliance@vermont.gov
with “Actionable Test Results” in the subject line.
Vermont CCB October 2025 Laboratory Testing Action Limits and Parameters Guidance
New Tests When a laboratory seeks to gain certification for a new test, it must also submit to the Board the
method validation summaries for any new test. Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Proficiency A laboratory must maintain analytical proficiency for each test it administers Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Records In addition to all other relevant disclosure requirements, upon request of the Board or Board designee laboratories
shall provide
full access to all test records.
Vermont CCB 7/15/2025 State of Vermont Cannabis Control Board. Rule 2: Regulation of Cannabis Establishments
Maintenance of Certifications Lab
- Issue Date
- Oct 16, 2026
- Due Date Raw
- 11/13/2026 04:30PM
- Categorized By
- llm-nc
- Detail Fetched
- Yes
- Questions Due Raw
- 10/26/2026 04:30PM
Vermont Buildings & General ServicesIssuing agency·Vermont·via the Vermont BGS purchasing bid board