BlogCompliancy

How to read a COA

By May 29, 2020 No Comments

Before we begin, please note none of this information should be taken as legal advice. These are general guidelines and the information presented are anecdotal examples used to illustrate the principles discussed. You need to consult your own legal counsel and work with your state’s representatives to confirm any decisions you make based off COAs or to determine the legal standing of any crop or product.

 

COA stands for Certificate of Analysis and the term is an official document that is required under federal law to verify regulatory compliance for THC levels.  The COA is used to show buyers the actual cannabinoid content of the crop, and subsequently grants the authorization to harvest, transport and sell the flower or biomass as hemp.

Each COA has several standard components with some labs offering more detailed analysis. In this article, we will focus how to  read and understand COAs so you have a better idea of how to evaluate different products.

There are two reasons you will need a COA as a farmer; to prove compliance and to show potential potency. This means you may get two different COA’s for a single genetic variety that you are considering growing. As a farmer, it is a good idea to have more than one for your finished product.

A compliance COA will be necessary to prove you are meeting the state harvest and usability regulations. This test is often done directly by the state you are licensed in. This is the COA that will prove your compliance to the Farm Bill regulations for hemp containing no more than 0.3% THC.

These tests from the state are typically only pass/ fail and will only report your THC numbers being compliant or not. They will not report CBD or any other cannabinoids, terpenes, heavy metals etc. It is also a good idea to take your own sample the same day the state inspector comes and have it third party tested at your own expense to verify state accuracy and have internal documentation of compliance. You should begin weekly testing of your crop starting in September to track cannabinoid progression to ensure you schedule the state inspector in the right window to prevent a “hot crop” coming in over 0.3% total THC while also maximizing your CBD or CBG levels.

 

STATE EXAMPLE

  1. Measured for TOTAL THC (beware, even though it says delta-9 here, some states measured for TOTAL THC.)
  2. State contracted lab returned a result of 0.27% TOTAL THC which is a passing result for all current regulations.
  3. Notice the collection date was 10/1. This was late in the season and two weeks before planned harvest.
  4. It took the state those two weeks to run the sample and this field was already harvested due to the threat of an incoming snowstorm. Check with your local regulations to see if you are allowed to harvest without the COA to save your crop.

COMPLIANCE EXAMPLE

  1. The lab provided a calculation, based on legal formula, of TOTAL THC.
  2. A result of 0.25% TOTAL THC is a crop pass for all existing rules.
  3. Took this private lab about a week to process and return results.

 

A potency COA on the other hand, is a test you should conduct after the crop is harvested, dried and cured. This test will have higher percentages and will showcase the concentration of cannabinoid and terpene after the product is cured. I would also suggest testing for heavy metals and pesticides. This is currently not mandatory but will help sell your product and stay ahead of any coming rule changes. Put yourself ahead of the pack by proving you care about producing a clean product.

Your flower that was 8% CBD, 0% delta-9 THC and 0 0.3% THCA (therefore <0 0.3% Total THC) when tested prior to harvest can, if properly dried cured and trimmed, turn into finished smokable flower that’s 20% CBD, 0.1% d9-THC and 0.8%THCA when it goes to market. At that point, the THC-A (and the Total THC) is legally irrelevant. Under Federal law, all that matters for possession and sale is the delta-9 THC in order to comply with CSA.

When deciding on a variety to plant, keep in mind that the Compliance COA is primarily useful in jurisdictions where the authorities require evidence that the variety you’re planting is compliant hemp. For purposes of choosing which variety to buy, you’ll want to know the ratio of CBD:THC. If it’s at least 25:1 then you can have a reasonable expectation that your crop will have at least 8% CBD when it’s 0 0.3% Total THC, and likely a fair bit more when harvesting 15, 28 or 30 days after testing (depending on your state’s testing window requirements). 8% CBD is a good threshold for reasonable market value in the extraction market. If you’re going for smokable flower, once you’ve dried, cured and trimmed your top-grade flower there’s a good chance your finished product will test at double that, and still be well under 0 0.3% delta-9 THC.

Your hemp was legally produced if it was grown and tested as required by your state. After the crop has been harvested and designated compliant, then whether your crop is turned into extract or dried, cured and trimmed for smokable flower or pre-rolls, 0.3% delta-9 THC becomes the legal standard, without regard to post-decarboxylation methods. That’s because the Controlled Substances Act defines hemp solely on the basis of delta-9 THC. So as long as the tincture bottle, pre-roll or jar of smokable flower you’re putting on the market is <0.3% delta-9 THC, in its current form (i.e. not after any specific form of testing), then under Federal law it cannot be legally considered a Controlled Substance any more than a bag of table grapes can count as wine.

POTENCY EXAMPLE

This is the same exact crop from the state example! This is after hanging and drying the plants for just under 2 weeks.

  1. Lab reported TOTAL THC at 0.541% which would be considered “hot” if this were for a crop still in the field. This same crop passed the state test at 0.27%. As you can see in the previous compliancy example, which was just 9 days before actual harvest. That said, a one-day delay in state testing could have put this crop past the threshold. Test early and test often.
  2. Notice the delta-9 THC is still non detectable which means this flower qualifies as a legal hemp product because it meets the federal qualifications of 0.3% delta-9 THC and can be sold and distributed.
  3. This sample was dropped off at the lab 12 days after harvest, so almost 2 weeks of hang drying then bin storage.
  4. Notice the CBD numbers have climbed to almost 15%.

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