Fat Nugs Magazine · Sources

What a Cannabis COA Cannot Tell You About Your Products

Fat Nugs Magazine

From RN Collins, selected work

The article, the sources and the image credits behind this post, each linked to the original.

The articleRead RN's full article in Fat Nugs Magazine fatnugsmag.com

Research cited

  1. Massachusetts Cannabis Control Commission, Protocol for the Sampling and Analysis of Finished Marijuana Products and Marijuana Products, implemented March 11, 2021, revised December 30, 2021 masscannabiscontrol.com
  2. Massachusetts Cannabis Control Commission, news release, Massachusetts Cannabis Control Commission to Begin Auditing THC Potency on Labels, May 22, 2026 masscannabiscontrol.com
  3. Massachusetts Cannabis Control Commission, news release, Massachusetts Cannabis Control Commission Releases Potency Audit Results, August 13, 2026 masscannabiscontrol.com
  4. California Department of Cannabis Control, Cal. Code Regs. tit. 4, section 15719, Residual Pesticides Testing (text as published by Cornell Legal Information Institute) law.cornell.edu
  5. California Department of Cannabis Control, Cal. Code Regs. tit. 4, section 15725, Terpenoid Testing (text as published by Cornell Legal Information Institute) law.cornell.edu
  6. New York State Office of Cannabis Management, Sampling Guidance, August 17, 2022 (revised August 24, 2022) cannabis.ny.gov
  7. Nevada Cannabis Compliance Board, Final Order including Findings of Fact, Conclusions of Law, and Imposing Discipline, State of Nevada CCB v. Cannex Nevada, LLC, now known as LettuceTest, LLC, Case No. 2020-27, March 4, 2024 ccb.nv.gov
  8. Schwabe AL, Johnson V, Harrelson J, McGlaughlin ME, Uncomfortably high: Testing reveals inflated THC potency on retail Cannabis labels, PLOS ONE 18(4):e0282396, April 12, 2023 (CC BY 4.0) doi.org

Other sources

  1. Sebastian Krawiec, Result Manipulation: From THC Inflation to Aspergillus, Cannabis Science and Technology 8(2):27-29, March/April 2025 cannabissciencetech.com
  2. Sarah Robertson, Burning questions plague cannabis testing industry, The Shoestring, March 6, 2025 theshoestring.org

Images, slide by slide

Slide 1
The cover page of the Massachusetts Cannabis Control Commission document titled Protocol for the Sampling and Analysis of Finished Marijuana Products and Marijuana Products, implemented March 11, 2021 and revised December 30, 2021.Source: Mass. CCC, protocol, p. 1Photo record
Slide 2
Section 4.2.2 of the Massachusetts protocol, Cannabinoid Profile Testing. It says product labels must give the cannabinoid profile, at a minimum the percentage by dry weight of delta-9 THC, CBD, THCa and CBDa, and that other cannabinoids may be included at the licensee's discretion.Source: Mass. CCC, protocol, PDF p. 16Photo record
Slide 3
The start of California Code of Regulations title 4, section 15719, Residual Pesticides Testing. Subsection (b) says the laboratory shall indicate pass or fail on the COA, and subsection (d) says when a sample is deemed to have passed.Source: Cal. DCC, 4 CCR 15719Photo record
Slide 4
California Code of Regulations title 4, section 15725, Terpenoid Testing. Subsection (a) begins "If requested, the licensed laboratory shall analyze" a sample's terpenoid profile; subsection (b) says the result goes on the COA.Source: Cal. DCC, 4 CCR 15725Photo record
Slide 5
Section 5.0 of the Massachusetts protocol, Sampling Program Design. The second paragraph begins "Because it is not possible to test all Marijuana, Licensees must collect representative samples" for the Commission's licensed testing laboratories.Source: Mass. CCC, protocol, PDF p. 18Photo record
Slide 6
A page of the Massachusetts protocol, section 5.3. It says homogenization of finished plant material may be difficult to accomplish before sampling because of its heterogeneous nature, and cites guidance on sampling loose leaf tea and botanicals.Source: Mass. CCC, protocol, PDF p. 20Photo record
Slide 7
Part of page 2 of the New York Office of Cannabis Management sampling guidance of August 2022. Item (d)(2) says to obtain sample increments from random and varying locations of the unpacked harvest batch, both vertically and horizontally. A table lists how many increments to take by batch size.Source: NY OCM, guidance, p. 2Photo record
Slide 8
Page 7 of the 2023 PLOS ONE paper by Schwabe and colleagues, starting at the Discussion. It says the observed values differed significantly from the labels and that 13 of 23 tested samples had values more than 30 percent lower than the lowest reported value.Source: PLOS ONE, Schwabe et al., p. 7Photo record
Slide 9
Part of the Massachusetts Cannabis Control Commission news release of May 22, 2026. It says that if a product's THC is beyond 75 to 125 percent of what the label reflects, it would be considered out of compliance and removed from the market through administrative action.Source: Mass. CCC, release, May 22, 2026Photo record
Slide 10
Part of the Commission's news release of August 13, 2026. A paragraph says the Commission selected 63 cannabis flower products from 62 producers off retail and dispensary shelves, rated compliant products green or yellow, and rated thirteen samples red for falling outside the acceptable range.Source: Mass. CCC, release, Aug. 13, 2026Photo record
Slide 11
Part of page 47 of the Nevada Cannabis Compliance Board Final Order in Case No. 2020-27. It says the laboratory worked with its clients to increase the potency reported, and that it used retesting in an attempt to control its potency results and avoid reporting lower results to the Department.Source: Nevada CCB, Final Order, p. 47Photo record
Slide 12
Page 53 of the Nevada Cannabis Compliance Board Final Order. The Board imposes a 180-day suspension of license numbers L006 and RL006 and a total civil penalty of $57,500, payable within 30 days.Source: Nevada CCB, Final Order, p. 53Photo record
Slide 13
The definition of Independent Testing Laboratory in the Massachusetts protocol. The laboratory must be licensed, accredited to ISO 17025 by a third-party accrediting body, independent financially from any licensee, and qualified to test under Massachusetts law.Source: Mass. CCC, protocol, PDF p. 6Photo record
Slide 14
The opening paragraphs of the Commission's August 13, 2026 news release. The first paragraph says most samples fell within an accurate range. Later paragraphs explain why the Commission began the audit.Source: Mass. CCC, release, Aug. 13, 2026Photo record

I'm taking on clients for storytelling strategy and content production and operations. DMs are open.