Both paper and electronic batch records are legal under the Cannabis Regulations. The difference is not legality, it is how much work each one makes you do to prove the record is trustworthy when Health Canada is standing in your facility.
An electronic batch record (EBR) is a digital, system-enforced version of the batch production record: the document that proves a single lot of product was made, tested, and released exactly as its master template requires, with every entry time-stamped, attributed, and locked into an audit trail.
For cannabis manufacturers, both paper and electronic records are legal under Canada’s Cannabis Regulations. An electronic batch record does not change what you must prove; it changes how much manual discipline it takes to prove it. Paper leans on human diligence to keep entries legible, initials correct, and nothing missed. A validated electronic batch record moves that burden into the system, where attribution, version control, backups, and environmental logging happen by default rather than by memory.
This complete guide covers what an electronic batch record is, how the FDA, EU GMP, and Health Canada rules treat it, how an electronic batch record system is built, how to evaluate electronic batch record software, and how to move a licensed producer off paper without breaking compliance. For the full GMP-aligned framework, you can also download our free cannabis batch record guide.
What Is an Electronic Batch Record?
An electronic batch record is the digital form of a batch production and control record: a computer-managed document that captures, in real time, every material, step, check, deviation, and signature involved in making one specific batch, replacing the hand-written paper batch record with a validated system that enforces the sequence and locks the data. Defined against the regulation rather than the marketing, a batch record under FDA rules is “An accurate reproduction of the appropriate master production or control record, checked for accuracy, dated, and signed” (21 CFR 211.188), plus documentation that each significant production step was actually accomplished. It is that record, executed and stored electronically under 21 CFR Part 11 and the EU’s Annex 11.
Three terms sit close together and are worth separating in one line each:
- Master batch record (MBR) is the approved, version-controlled template a batch reproduces (21 CFR 211.186).
- Batch production record (BPR), also called a batch manufacturing record (BMR), is the executed copy filled in for one specific batch.
- Electronic batch record (EBR) is either of the above, created, executed, and retained electronically.
For the full disambiguation, see what a batch manufacturing record contains and master batch record vs batch production record vs EBR. Regulated industries rely on this record because it is the primary GMP evidence that a batch is safe and made to specification. Electronic enforcement matters because it removes the gaps paper leaves. You will also see the record called electronic batch recording, eBR, or eMBR; they all point at the same thing, a batch record managed by software instead of a binder.
The Regulatory Landscape: FDA, EU GMP, and Health Canada
No major regime requires you to keep batch records electronically, but all three that matter to cannabis manufacturers (the US FDA, EU GMP, and Health Canada) set the same bar for what a batch record must prove, and each governs electronic records once you choose to go digital. Most guides that rank for this topic cover only one jurisdiction, usually US pharma. Cannabis producers that export to the EU or run to Good Production Practices in Canada need all three threaded together, because the same lot record often has to satisfy more than one regulator.
| Jurisdiction | Batch-record duty | Electronic records, audit trail, and e-signature rule |
|---|---|---|
| US, FDA | 21 CFR 211.188 (batch production and control record = an accurate reproduction of the master record plus documentation of every significant step); 21 CFR 211.186 (master production and control record) | 21 CFR Part 11: section 11.3 defines electronic records and electronic signatures; section 11.10(e) requires secure, computer-generated, time-stamped audit trails that “shall not obscure previously recorded information” |
| EU, GMP | EudraLex Volume 4 GMP (batch documentation) | Annex 11: section 9 audit trails (reason for a GMP-relevant change documented, regularly reviewed); section 14 electronic signatures (same impact as hand-written, permanently linked to the record, carrying time and date); section 15 Qualified Person batch release by electronic signature; section 8.2 batch-release printouts must show if data changed since original entry |
| Canada, Health Canada | Cannabis Regulations (SOR/2018-144) s.231(1)(a): a document for each lot or batch sold or exported demonstrating production per Parts 5 and 6 | s.221 is medium-neutral: records retained so an audit “can be made in a timely manner”; s.231(2)(a): retain for at least two years after the last sale or export |
The audit-trail rule is the clearest single expectation across all three regimes, and the FDA states it verbatim.
The live EU GMP Annex 11 for cannabis producers cluster covers the European computerised-systems rules in depth, including Annex 11 computerised systems validation and security and Annex 11 audit trails, so this guide points there rather than repeating them. The takeaway is consistent everywhere: the duty to keep a complete batch record is medium-neutral, and the electronic rules only tell you how to make a digital record trustworthy once you have chosen software.
Are Electronic Batch Records Required for Cannabis?
No. Neither Health Canada, the FDA, nor EU GMP mandates the electronic medium. The regulation mandates the outcome, a complete, attributable, retained, audit-ready record, not the format. Paper and electronic are both legal, and the electronic rules only apply once you choose to go digital.
In Canada, there is no clause in the Cannabis Regulations (SOR/2018-144) that requires electronic batch records over paper. Section 221 is medium-neutral: records must be retained so that an audit “can be made in a timely manner” and be available at the licensed site. Section 231 sets the batch-record duty itself, a document for each lot or batch demonstrating production per Parts 5 and 6, retained for at least two years after the last sale or export. A binder and a validated EBR system can both satisfy that duty.
The same conditional logic holds elsewhere. In the US, 21 CFR Part 11 governs electronic records and electronic signatures if you keep them electronically; it is not a mandate to go electronic. In the EU, Annex 11 governs computerised systems used in GMP, again conditional rather than compulsory. The nuance the industry keeps missing is that the standard is identical for paper and digital. An EBR does not lower the bar. It simply shifts the compliance burden off human discipline and onto the system.
Paper vs Digital Batch Records: The Compliance Comparison
Paper and electronic batch records are held to the same standard, but they distribute the work differently: paper puts the burden on human discipline (legible entries, correct initials, nothing missed), while a validated EBR moves that burden into the system. The table below compares the two across the five attributes that matter most to a QAP and an inspector. Read it as a risk-and-effort comparison, not a legal-versus-illegal one.
| Attribute | Paper batch records | Electronic batch records |
|---|---|---|
| Compliance risk | Higher. Legibility varies by author, pages go missing, and corrections introduce ambiguity. Demonstrating who entered what and when relies on initials and dates that are easy to forget under production pressure. | Lower. Audit trails, version control, and automated backups capture who changed a value, the old value, the new value, and the timestamp, without anyone having to remember to write it down. |
| Retrieval speed | Slow. Pulling a lot for an inspector means a physical search through binders and archive boxes, often across rooms or sites. | Instant. Records are searchable by batch, date, product, or personnel, so a full lot history surfaces in seconds rather than hours. |
| Environmental data capture | Manual entry. Staff transcribe temperature, humidity, and irrigation readings by hand, which is time-consuming and a frequent source of gaps in the log. | Auto-populated. Sensor readings flow into the batch record automatically with alert triggers on excursions, so environmental logs stay continuous without manual transcription. |
| QAP sign-off | Physical signature. The Quality Assurance Person signs and dates the batch release record in ink. | Electronic signature. The QAP signs digitally, and the e-signature must meet electronic-signature requirements (unique to the signer, securely linked to the record, and attributable in the audit trail). |
| Cost | Low upfront, high ongoing labour. No software to buy, but staff hours spent on transcription, filing, searching, and assembling records for audits add up. | Software investment upfront, lower ongoing labour. A platform is a recurring cost, offset by the staff time saved on data entry, retrieval, and audit preparation. |
The pattern across every row is the same. Paper can satisfy the regulation, but the producer carries the discipline. Digital satisfies the same regulation with the system carrying more of it.
This is exactly where paper records fail at audit: a missing initial, an illegible entry, a transcription error copying a sensor reading by hand, a lot that cannot be retrieved within a timely manner, an environmental gap discovered only at review when it is too late to explain.
Vendor case studies from suppliers such as MasterControl and IDBS report large reductions in batch-review time and data-entry errors after moving to an electronic batch record, but those figures are vendor-reported rather than independently established, so the durable point is the mechanism, not the number: the system eliminates the transcription steps where paper breaks, so the disciplined outcome becomes the default rather than the exception.
GrowerIQ Digital MBR
One click from live data to audit-ready EBR
GrowerIQ’s Digital Master Batch Record assembles the complete, audit-ready electronic batch record automatically from live seed-to-sale data, with no manual batch-history assembly and no missing initials.
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How an Electronic Batch Record System Works: The Anatomy
An electronic batch record system is built in layers: a master template layer that defines how a batch should be made, an execution layer that captures what actually happened, and a governance layer (audit trail, electronic signatures, and review by exception) that makes the record trustworthy and fast to release. Understanding those layers is what separates buying an electronic batch record system from buying a document scanner.
The master template layer (master batch record)
The master batch record is the approved, version-controlled template each batch reproduces. Under 21 CFR 211.186, a master production and control record must be “prepared, dated, and signed (full signature, handwritten) by one person and independently checked, dated, and signed by a second person.” Changing the template is a controlled event, and version control prevents silent drift from one batch to the next. When you need the full comparison of the template against the executed record, the master batch record vs batch production record vs EBR breakdown covers it.
The execution layer (the batch production record)
The system instantiates the template into an executed batch production record and enforces sequence, mandatory fields, and in-process limits as operators work, capturing weights, equipment and line identifiers, in-process checks, and results in real time as required by 211.188. In cannabis this layer has to span cultivation, harvest, processing, packaging, and release in one continuous record, which is exactly what pharma-only MES tools cannot do. See what a complete cannabis lot record must contain for the full section-by-section anatomy.
The audit trail
The audit trail is the system-generated, time-stamped, attributable record of every create, modify, and delete action. FDA 21 CFR 11.10(e) requires that record changes “shall not obscure previously recorded information,” and EU GMP Annex 11 section 9 adds that the reason for any GMP-relevant change or deletion should be documented and that audit trails should be regularly reviewed. This is the single feature that makes an electronic batch record defensible. The Annex 11 audit trails deep dive and the ALCOA++ data integrity hub carry the detail, so this guide keeps the audit-trail treatment short.
Electronic signatures
Electronic signatures are how a record becomes authorized. Annex 11 section 14 sets three expectations: an electronic signature must have the same impact as a hand-written signature within the company, be permanently linked to its respective record, and include the time and date it was applied. Section 15 adds that only Qualified Persons may certify batch release, using an electronic signature. Those requirements carry straight into the QAP sign-off discussed further down.
Review by exception
Review by exception is the efficiency layer. Under the review-by-exception model used in modern MES and EBR systems, manufacturing and quality data are screened so that only critical process exceptions, values that are out of specification or otherwise flagged, are surfaced for a reviewer to disposition. Instead of re-reading every page of a completed batch record, a reviewer dispositions only the entries the system flagged. An electronic batch record can run standalone or as part of a manufacturing execution system (MES); in cannabis it typically lives inside the seed-to-sale platform that already runs cultivation and manufacturing.
Quality data belongs inside the record
The layer most stacks bolt on, quality, should be part of the record from the start. Because deviations, CAPAs, and sensor readings originate in the same system that runs production, they can be pulled into the batch record automatically at review time instead of being reconciled by hand.
The question worth asking of your own operation is simple: how many systems do you have to open to answer one deviation question at batch release? The typical stack pairs an electronic batch record or seed-to-sale tool with a separate quality system (a standalone eQMS, spreadsheets, or paper), which forces someone to cross-reference deviation logs and CAPA status against the batch record before a lot can be released.
When quality management is native to the same platform, that reconciliation step disappears, and the deviation and CAPA history is already part of the electronic batch record.
Why Electronic Batch Records Lower Compliance Risk
An electronic batch record lowers compliance risk by moving four things that paper leaves to human discipline (attribution, version control, backups, and environmental capture) into the system, where they happen automatically and cannot be silently skipped. Each maps directly to the ALCOA principles of Attributable, Legible, Contemporaneous, Original, and Accurate that underpin how Health Canada assesses record trustworthiness.
Audit trails make every entry attributable
An audit trail records who entered or changed a value, what the value was before and after, and the exact time it happened. On paper, attribution depends on a legible initial and a remembered date. In an electronic batch record it is automatic and tamper-evident, which directly serves the Attributable and Contemporaneous parts of ALCOA and satisfies 21 CFR 11.10(e) and Annex 11 section 9. When an inspector asks who recorded a harvest weight at 14:32 on a given day, the system answers without anyone reconstructing it from memory.
Version control prevents silent overwrites
The data integrity rule for batch records is that you never white out, delete, or overwrite an entry. Errors get a single strikethrough, initials, the date, and a reason. Version control enforces that rule structurally: the original value is preserved, the correction is logged as a new version with its reason, and nothing is silently lost, which is exactly what 11.10(e) means by not obscuring previously recorded information. This is the same discipline the cannabis batch record data integrity spoke covers in depth, applied automatically rather than by hand.
Automated backups protect the Original and the retention duty
A paper record exists in exactly one place until someone photocopies it, and a flood, fire, or misfiling can take it permanently. Annex 11 section 7.2 expects that “Regular back-ups of all relevant data should be done.” Automated backups keep the Original safe and make Canada’s two-year retention duty under s.231(2)(a) defensible, because the record cannot quietly disappear from an archive box. Retention is its own subject, covered in the cannabis record retention spoke.
Sensor auto-population closes the most common gap
Gaps in environmental logs are one of the most frequent batch-record deficiencies, because manual transcription of temperature, humidity, VPD, and irrigation data fails the moment production gets busy. Sensor auto-population removes the human step entirely. Readings land in the batch record continuously, alert triggers flag excursions, and the Contemporaneous and Accurate requirements are met by default rather than by diligence.
What Must an Electronic Signature Satisfy for QAP Sign-Off?
For a Quality Assurance Person’s release signature to hold up, an electronic signature must do exactly what a hand-written one does and a little more: be uniquely tied to the signer, be permanently linked to the specific record it approves, and carry a tamper-evident time and date in the audit trail. The QAP batch release signature is the single most important entry in the record, because it is the step that authorizes a lot for sale. A missing QAP release signature means the product is technically not authorized, regardless of how clean the rest of the record is.
The legal bar is identical to a wet-ink signature; the system just has to enforce it. The FDA defines an electronic signature as “the legally binding equivalent of the individual’s handwritten signature” (21 CFR 11.3), and EU GMP Annex 11 section 14 sets the three practical expectations already noted: same impact as a hand-written signature, permanently linked to the record, and stamped with time and date.
Annex 11 section 15 adds that only Qualified Persons may certify batch release by electronic signature. A shared login or an unattributable click is not a valid electronic signature, and an inspector will treat it as a deficiency.
For cannabis, this QAP sign-off is what demonstrates the s.231 proof-of-production duty was met before release, and the decision itself is covered in the cannabis batch release and QAP sign-off spoke. The point is not that electronic signatures are harder; it is that they have to be implemented properly to earn the trust an ink signature carries by convention.
How Do You Evaluate Electronic Batch Record Software?
Evaluate electronic batch record software against seven things: validation and GAMP category, Part 11 and Annex 11 audit trail and e-signature support, ALCOA++ data integrity, integrations, cannabis-specific reporting, review by exception, and the question most buyers miss, whether quality management is native or a bolt-on integration. Framed as questions to put to a vendor, the checklist looks like this:
- Validation and GAMP category (IQ, OQ, PQ). Is the electronic batch record system validated, what GAMP category does it fall in, and who documents the installation, operational, and performance qualification?
- Audit trail and electronic signatures. Does it deliver 21 CFR 11.10(e) and Annex 11 section 9 audit trails and section 14 electronic signatures out of the box, or do they need configuration?
- Data integrity and ALCOA++. Is every entry Attributable, Legible, Contemporaneous, Original, Accurate, and then Complete, Consistent, Enduring, and Available? The ALCOA++ data integrity hub is the reference standard to test against.
- Integrations. Does it connect to environmental sensors, LIMS or lab systems, and ERP, and does environmental data auto-populate the batch record rather than being keyed in?
- Cannabis-specific reporting. Does it produce Health Canada CTLS and B300 reporting, and does it trace lineage from mother plant to release?
- Review by exception. Can reviewers disposition only the flagged exceptions, or must they re-read the whole record?
- Native QMS vs bolt-on integration. The differentiating question: are deviations, CAPAs, and quality records part of the electronic batch record from the start, or a separate system you reconcile at release?
Costs on this category run high because most electronic batch record software is sold into pharma, where per-seat and per-system pricing reflects it. A cannabis-native platform that already captures the production data changes that maths. For a worked head-to-head against a manufacturing-focused option, see our cannabis manufacturing software comparison.
Cannabis-Specific EBR Requirements
A cannabis electronic batch record has to do everything a pharma batch record does and then span the parts pharma never touches: mother-plant lineage, harvest and drying, extraction lots, and Health Canada’s per-lot reporting, all in one continuous record from clone to release. This is the gap every pharma-only guide leaves open, and it is where the seed-to-sale model fits naturally.
The Health Canada duty is specific. Section 231(1)(a) requires a document, for each lot or batch sold or exported, demonstrating production per Parts 5 (Good Production Practices) and 6 (Cannabis Products). Section 224 requires a per-lot inventory record covering harvest, drying, and packaging dates plus cannabinoid and terpene test data, retained for two years.
Section 232 requires the standard operating procedures that govern the batch to be documented in the same system. A compliant cannabis electronic batch record therefore has to trace the mother plant through clone or seed, harvest, drying, extraction or processing lots, packaging, and release as one connected lineage, and feed Canada’s CTLS and B300 reporting obligations that pharma records never have to touch. Pharma MES tools structurally start at the manufacturing step and cannot see the cultivation history, which is why a seed-to-sale platform is the natural home for a cannabis EBR.
The cannabis record retention spoke covers how long each of these records must be kept, and the free cannabis batch record guide walks the full lot anatomy.
Implementing EBR: Moving From Paper to Digital
Moving from paper to an electronic batch record is a validation project, not a file conversion: you re-express your master batch records as configured templates, qualify the system (IQ, OQ, PQ), migrate in a controlled cutover, and manage the change so operators adopt it instead of working around it. The most common failure is not technical. It is a system that is technically live but quietly bypassed by staff who kept a parallel paper log.
A realistic implementation has four parts. First, template configuration, turning each master batch record into a configured, version-controlled template in the system. Second, validation, documented installation, operational, and performance qualification so the system is proven fit for use. Third, a controlled cutover, often a parallel run where paper and digital are kept together for a period before paper is retired. Fourth, change management, training and workflow design that make the electronic batch record the path of least resistance so operators do not invent workarounds. Enterprise pharma implementations are often quoted in six-figure bands, but those figures are vendor-reported and pharma-scaled, so treat them as an order of magnitude rather than a cannabis benchmark.
The decision to move is rarely about a single audit finding; it is about scale. A small producer running one or two lots a quarter can keep a clean paper file with a disciplined team.
Add product lines, simultaneous batches, and a higher cadence of Health Canada interaction, and the manual labour of paper compounds: more transcription, more filing, more time assembling records for every request, and more surface area for an undated entry or a missing page to become a data integrity finding. An electronic batch record earns its cost where the ongoing labour of paper exceeds the recurring cost of a platform, which for most multi-lot producers arrives quickly.
GrowerIQ is cannabis seed-to-sale and operations software used by licensed producers in more than 24 countries, and a cannabis-native platform shortens implementation because the batch record is generated from data you are already capturing seed-to-sale, with no separate MES to stand up.
Electronic Batch Records for Cannabis: The GrowerIQ Approach
GrowerIQ generates the complete electronic batch record, the Digital Master Batch Record, in one click from live seed-to-sale data, with quality management already inside it, so the audit-ready record assembles itself instead of being compiled by hand at release. Because the platform runs cultivation, manufacturing, and quality in one place, the record does not have to be stitched together from separate systems.
The Digital Master Batch Record compiles in real time from any batch, lot, package run, or vessel, pulling from the modules that already hold the data:
- Activity tracking: every action, timestamp, and room movement.
- Cultivation history: clone or seed through harvest, with multi-tier lineage back to mother plants.
- Quality workflows: deviations, CAPAs, and lab results, native to the same system.
- Inventory: splits, merges, transfers, and packaging.
- Document appendix: PDFs and images inline, with a complete audit trail and user attribution.
Because the QMS is built into the same platform, deviation reports, CAPAs, and sensor readings land in the batch record automatically, which is GrowerIQ’s unique strength among cannabis platforms. The output aligns across all three regimes this guide covered: it maps to s.231(1)(a) because GrowerIQ is that proof-of-production document, generated automatically; to 21 CFR 11.10(e) and Annex 11 section 9 because the audit trail is system-generated, timestamped, and attributable; and to Annex 11 sections 14 and 15 because QAP and Qualified Person release is captured as a linked, time-stamped electronic signature. The compliance alignment stated for the platform spans Health Canada Good Production Practices, EU GMP including Annex 11 electronic records, and GACP, with 256-bit encryption and 24/7 data access.
Key Takeaways
An electronic batch record is a validated digital version of the batch production record: legally optional but operationally decisive for cannabis manufacturers.
- An electronic batch record is the digital form of a batch production and control record, capturing every material, step, check, and signature for one lot.
- No regime that matters to cannabis (Health Canada, the FDA, or EU GMP) mandates the electronic medium, but all three hold paper and digital to the same standard.
- An electronic batch record system is built in three layers: a master-template layer, an execution layer, and a governance layer of audit trail, electronic signatures, and review by exception.
- The audit trail (21 CFR 11.10(e) and Annex 11 section 9) is what makes the record trustworthy, because it captures every change without obscuring what came before.
- The buyer’s differentiating question is whether quality management is native to the record or a bolt-on system reconciled at release.
- A cannabis electronic batch record must span cultivation to release in one continuous record, which pharma-only tools structurally cannot do.
GrowerIQ Validated GxP-Compliant by RQC
RQC renewed GrowerIQ’s independent GxP validation in December 2025, confirming compliance with EudraLex Annex 11 and PIC/S. GrowerIQ is designed and controlled to SOC 2 standards alongside EU GMP.
READ THE ANNOUNCEMENTFrequently Asked Questions
Are electronic batch records required for cannabis producers in Canada?
No. The Cannabis Regulations (SOR/2018-144) do not require electronic batch records. They require that a licensed producer keep records sufficient to reconstruct how each lot was produced, tested, and distributed, retain them for at least two years, and produce them in a timely manner when Health Canada requests them. Both paper and digital records can satisfy that duty. An electronic batch record is an operational upgrade that makes the same standard easier to meet and defend, not a legal requirement that paper fails.
Is an electronic batch record required by GMP?
No. No GMP regime (the FDA, EU GMP, or Health Canada) requires the electronic medium. GMP requires a complete, attributable, retained, audit-ready batch record. 21 CFR Part 11 and EU GMP Annex 11 govern electronic records and electronic signatures only once you choose to keep them electronically. They set the conditions a digital record must meet, not an obligation to abandon paper.
What is an electronic batch record system?
An electronic batch record system is a validated software system that creates, executes, and stores batch records electronically. It is built from three layers: a master-template layer that holds the approved master batch record, an execution layer that captures what actually happened during the batch, and a governance layer of audit trail, electronic signatures, and review by exception that makes the record trustworthy and fast to release. In cannabis, it usually lives inside the seed-to-sale platform that already runs cultivation and manufacturing.
What is the difference between an EBR and an MBR?
The master batch record (MBR) is the approved, version-controlled template that defines how a batch should be made. The electronic batch record (EBR) is the executed, electronic record of one specific batch produced from that template. In short, the MBR is the blueprint and the EBR is the completed, signed evidence that the blueprint was followed. The master batch record vs batch production record vs EBR breakdown covers all three terms.
Is a paper batch record still compliant for cannabis?
Yes. A disciplined paper batch record that is legible, signed and dated where required, free of white-out or overwrites, and complete across cultivation, testing, release, packaging, and distribution can pass a Health Canada audit. The compliance risk with paper is higher because legibility, lost pages, and correction errors all depend on human discipline, but a well-run paper system is not non-compliant. The record simply has to meet the same standard a digital one does.
What must an electronic signature meet for a QAP batch release sign-off?
An electronic QAP signature must meet electronic-signature requirements to carry the same weight as a physical signature. It must be uniquely attributable to the individual QAP, securely linked to the specific record being signed so it cannot be moved to another record, and captured in the audit trail with a timestamp. Annex 11 sections 14 and 15 and 21 CFR 11.3 set these expectations. A shared login or an unattributable approval click does not qualify and will be treated as a deficiency.
Does switching to electronic batch records change the two-year retention requirement?
No. The minimum two-year retention requirement under the Cannabis Regulations (s.231(2)(a)) applies regardless of medium. What changes with an electronic batch record is how the duty is met. Automated backups keep records retrievable and protected against the loss, flood, or misfiling that can destroy a paper archive, and digital search makes producing a specific lot in a timely manner straightforward. The retention period itself is unchanged, but defending it becomes easier.
Get the Full Cannabis Batch Record Guide
Related reading across the batch-record cluster: what a complete cannabis lot record must contain, cannabis batch record data integrity, cannabis batch release and QAP sign-off, and cannabis record retention.
Last updated: July 2026
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