New Mexico is replacing BioTrack with NMS2S, a new state traceability system built by Real Time Solutions under contract with the Cannabis Control Division (CCD). We support the state having a system built for New Mexico — and we are connected to every interface the state has made available to us. But the launch leaves real gaps between what the rules require of you and the tools you've been given to comply, and licensees are the ones carrying that gap.
Regulators answer to elected officials, and elected officials answer to constituents. A short, specific, personal note from a licensed business owner in their district carries more weight than anything a software vendor can say. This kit gives you the verified facts, a set of reasonable asks, the right contacts, and starter templates you can make your own.
1. Know the facts
Stick to what is documented. Everything below comes from the CCD's own public bulletins (including the August 21, 2026 industry bulletin) or from our direct integration work with the state.
Date | What happens |
Aug 25, 5:00 PM | BioTrack becomes unavailable for producers, manufacturers, and labs. |
Aug 25 – Aug 30 | Reporting blackout for non-retail licensees: no state system is available to report to. |
Aug 31 | Non-retail licensees begin gaining access to NMS2S. End-of-day Aug 25 BioTrack data becomes starting inventory. |
Sept 1 – 2 | Retail migration begins Sept 1; retailers expected to have access to their inventory in NMS2S on Sept 2. |
Sept 15 | The state's legacy BioTrack contract expires. The CCD has said it could not reach an agreement to extend it. |
What the state has said
The CCD's August 21 bulletin describes NMS2S as "first and foremost a regulatory tool" for overseeing inventory and administering the cannabis program.
The CCD says it has been preparing for this transition since 2024, and awarded the contract to Real Time Solutions on January 28, 2026 — yet licensees received their final transition instructions only weeks before the cutover.
The bulletin commits to being "responsive and adaptive to ironing out any problems in the days after the launch."
Where the gap is
Wholesale: No API for third-party integrators exists at launch, and no timeline has been published. Producers, manufacturers, and labs must do all compliance work by hand in the NMS2S website — on top of running their operations.
Retail: The launch API accepts sales and voids only. Receiving transfers, inventory adjustments, conversions and repackaging, and partial returns all require manual work in the NMS2S website, duplicating effort and multiplying the chance of honest discrepancies.
The blackout: Non-retail licensees have a multi-day window with no state system at all, and no published written guidance on how recordkeeping from that window will be treated in later audits or enforcement.
Why this matters
A traceability system is mandatory. When the mandatory system doesn't expose the functions a business needs, compliance becomes a manual, error-prone burden — and the businesses trying hardest to comply carry the most risk.
2. Know the asks
This is not a campaign against NMS2S or the people building it. It's a request that the state finish the job it started, and not penalize licensees for gaps the state's own tooling created. Four concrete, reasonable asks:
Publish the wholesale API documentation with a committed timeline. Third-party integrators are ready to build the moment documentation exists. Every week without it is a week of manual double-entry for producers, manufacturers, and labs.
Open the remaining retail endpoints. Receiving transfers, inventory adjustments, conversions/repackaging, and partial returns are daily retail operations, not edge cases. Until they're supported, every store does the same work twice.
Establish a written good-faith enforcement window. While required functions are unavailable through the system or its API, licensees making documented good-faith efforts to reconcile — including through the blackout week — should not face citations for discrepancies those gaps create.
Commit to regular public status updates and a working group. A published monthly status report on API and feature progress, plus a standing group that includes licensees and integrators, would replace rumor with information.
Pick the one or two that hit your operation hardest and lead with those. A letter with one clear ask beats a letter with ten.
3. Find your contacts
Your state legislators
Highest impact per minute spent — you are their constituent, and they will still be legislating when this launch is history.
Find your senator and representative (you have one of each) at nmlegis.gov/members/find_my_legislator or by address at nmlegis.gov/members/Find_By_Address. Each member's page lists their email and phone.
Office of the Governor
The Regulation & Licensing Department reports to the executive. Volume of individual constituent contact is what gets noticed here.
Phone: (505) 476-2200 · Toll-free: (833) 520-0020
Mail: Office of the Governor, 490 Old Santa Fe Trail, Room 400, Santa Fe, NM 87501
Cannabis Control Division (RLD)
Keep the regulator in the loop on every concern you escalate — it shows good faith, and they need the specifics.
General: [email protected] · (505) 476-4995
Compliance questions: [email protected]
NMS2S transition page: rld.nm.gov/cannabis/nms2s
If you belong to an industry association or chamber, ask whether they're coordinating a joint letter — individual notes plus one signed group letter is a strong combination.
4. Write it — templates to make your own
These are starting points, not scripts. Officials' offices discount identical form letters; they pay attention to specific, local, first-person detail. Replace every [bracketed] item, cut what doesn't apply to you, and add one concrete detail from your own operation.
To your state legislator
Subject: Constituent in your district — cannabis traceability transition (NMS2S)
Dear [Senator/Representative Last Name],
My name is [name] and I [own / operate / manage] [business name], a licensed cannabis [producer / manufacturer / retailer] in [city], in your district. We employ [number] New Mexicans.
I support the state operating its own traceability system, and my team is doing everything asked of us in the transition to NMS2S. I'm writing because the system launched without the tools licensees need to comply efficiently:
The state has not released a wholesale API, so [producers/manufacturers like us] must enter every compliance action by hand in the state website, on top of our operational records.
The retail API accepts only sales and voids, so routine work like receiving transfers and inventory adjustments must be done twice.
Non-retail licensees had a multi-day window with no state system available at all, and no written guidance on how records from that window will be treated.
For my business specifically: [one or two sentences — e.g., hours per week of duplicate data entry, staff pulled from other work, risk of honest discrepancies].
I'm asking you to urge the Regulation and Licensing Department to [pick 1–2: publish the wholesale API documentation with a committed timeline / open the remaining retail endpoints / put a good-faith enforcement window in writing while the gaps persist].
I'd welcome the chance to walk you or your staff through what this looks like on the ground. Thank you for your time and your service.
Respectfully,
[Name]
[Business, license number]
[Address, phone, email]
To the Governor's office
Subject: Licensed cannabis operators need the tools to comply with NMS2S
Dear Governor Lujan Grisham,
I [own / operate] [business name], a licensed cannabis [license type] in [city], employing [number] New Mexicans. We have reported to the state's traceability system in good standing since [year].
I am not writing to oppose NMS2S. I am writing because the transition has left licensees responsible for requirements the system does not yet give us the tools to meet: there is no wholesale API for the software the industry runs on, the retail API supports only sales and voids, and non-retail licensees went days with no state system available and no written guidance on how that gap will be treated.
The Cannabis Control Division's own bulletin describes NMS2S as first and foremost a regulatory tool. We respect that — but a mandatory system also has to be one that working businesses can feasibly comply with. Right now the burden of that difference falls entirely on licensees.
I ask your office to direct the Regulation and Licensing Department to publish the wholesale API documentation with a committed timeline, complete the retail endpoints, and put a good-faith enforcement policy in writing while those gaps persist.
New Mexico's licensed operators want this system to succeed. Give us the tools and we will use them.
Respectfully,
[Name, business, license number, city, contact information]
To the Cannabis Control Division
Subject: Licensee feedback on the NMS2S transition — [license number]
Dear Cannabis Control Division,
Thank you for the August 21 bulletin and for the support resources during the transition. I'm writing as a licensed [license type] to put my operational concerns on the record and to ask for specific information.
Wholesale API: When will documentation be published for third-party integrators, and can the Division commit to a date? Until it exists, every compliance action at my facility is manual double-entry.
Retail endpoints: What is the timeline for receiving transfers, inventory adjustments, conversions, and partial returns to be supported through the API?
Blackout-window records: Will the Division issue written guidance on how licensee records from the Aug 25–30 window will be treated in audits and enforcement?
Good-faith compliance: While these gaps persist, will the Division state in writing that documented good-faith reconciliation efforts will be considered before citations are issued?
Specific to my operation: [one or two concrete examples — packages reconciled by hand, hours of duplicate entry, discrepancies created by the migration].
I appreciate the Division's stated commitment to being responsive after launch, and I'm glad to participate in any licensee working group or feedback session you convene.
Respectfully,
[Name, business, license number, contact information]
Thirty-second phone script
Hi, my name is [name]. I'm a constituent in [city / district] and I [own / work at] a licensed cannabis business.
I'm calling about the state's new cannabis traceability system, NMS2S. My business wants to comply, but the state launched it without the software interfaces licensees need — so we're doing our compliance work by hand, twice.
I'm asking [the Senator / the Representative / the Governor] to urge the Regulation and Licensing Department to publish its API documentation with a real timeline, and to put a good-faith enforcement policy in writing until the system is complete.
Can I leave my name and number for a follow-up? Thank you.
Do's and don'ts
Do
Identify yourself as a constituent and a licensed, compliant operator.
Lead with one or two asks, not ten.
Include one specific, first-person detail from your operation.
Stay courteous — the goal is a working relationship, not a viral post.
Follow up in two weeks if you get no response.
Don't
Attack CCD staff or the vendor personally, or speculate about motives.
Send an unedited template — identical letters get counted, not read.
Overstate: stick to the documented facts in section 1.
Threaten lawsuits or non-compliance.
Stop reporting — keep reporting everything you can, and document what you can't.
Provided by GrowFlow as a convenience to our New Mexico customers. It reflects publicly available information and our direct integration experience as of August 2026 and is not legal advice. Whether and how you contact public officials is entirely your choice; your voice as a licensee and constituent is your own. For questions about GrowFlow's NMS2S integration status, contact our support team.