As the summer rolls on, the requirements and regulations for California cannabis are becoming more clear and understandable. While in the midst of all things Phase II, it’s a good time to answer questions about testing, Certificates of Analysis (CoA), what to do with product tested in Phase I and how to prepare for Phase III. If you are a cultivator or manufacturer, it’s time to get your product compliant and ready for Phase III to avoid testing failures and state lab hiccups. In the meantime, let’s get some answers from our Compliance Team.
What is the difference between Phase I, II, and III testing?
Come December 31, 2018, Phase III testing becomes the requirement for all product. In addition to the current panel for testing, all products will be tested for Terpenoids, Mycotoxins, Heavy Metals, and Water Activity.
Can products with a CoA 1 still be purchased/sold in the marketplace?
Yes. Per the BCC regulations section 5715 phase in of required laboratory testing; because they were tested during Phase I, their CoA continues to be compliant.
E.g. – A product was harvested in February, has a CoA 1, but was not sold until after July 1. The CoA 1 continues to be acceptable.
If I have product that was manufactured or harvested before July 1 and haven’t had it tested yet, which CoA does it need to have?
CoA 2. As we move forward, all product is tested for the required specifications of that phase.
E.g. – A product was manufactured in May and was not tested until mid-July = Will be tested under Phase II requirements.
Does the Unique Identifier (UID) number need to on the package?
Yes. The UID is found on the CoA and must be on individual packages.The UID will accompany the product throughout its life cycle.
What is an Research and Development (R&D) report and how is that different from a CoA?
An R&D report is a report generated during the development of a product or a pre-harvested flower. It is not a State approved CoA as it may come from a lab that is not state approved or be a report that does not include all state required tests.
What can we do with product that has not been tested, but we’d like to sell?
This product needs to be put in the hands of a distributor to be tested at a state certified lab and then sold. Also you must ensure that testing lab employees takes the sample of cannabis from the distributor’s premises. It will be tested for the panel in the Phase testing requirements are in.
E.g. – My product is was manufactured in January, but I never tested it and now want to sell it. I must send it to a distributor and they will arrange for testing. It will be tested adhering to Phase II regulations and be able to sell if it passes.
Stay tuned for more compliance updates as the year progresses and more regulations unfold. As always, feel free to send your questions to email@example.com.