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The panel follows the rolling, not the selling. Whoever processes the product owes the panel. Buy pre-rolls already made and packaged by a producer and you are not retesting anything, their panel covers it. Roll them yourself and the panel is yours.

One panel, not two. Pre-rolls made from bulk flower need a panel of their own, because the flower's Certificate of Analysis does not carry over and the rolling itself can introduce something the flower panel never saw. Packaging the finished pre-rolls does not trigger a second panel.

Two conditions, both have to hold. Under 16.8.7.15(E), product acquired from another licensee is exempt from retesting only while the batch is in present form and its Certificate of Analysis is under 90 days old. The 90 days runs from the issue date printed on the source COA. Change the form or run out the clock and the exemption is gone.

A pre-roll run is one batch. The 15 pound batch cap applies to harvested flower. A manufactured product batch is defined by one strain, one protocol and one production window, not by weight, so a large run is one panel. Separate runs are separate batches.

Rolling in house requires manufacturing licensure. A retail only license cannot make pre-rolls. If a required panel never happens there is no citation, the product simply cannot be sold.

Pesticides, answered. The Division confirmed the rule requires pesticides on every category, including concentrate with added ingredients, and that the old exemption is gone. It also confirmed NMS2S was built before the amendment and does not currently assign pesticides to infused pre-rolls or infused cannabis material made from two inputs that each passed. Laboratories perform the panel the system assigns. The Division intends to update the system.