Deciphering Certificates of Analysis

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When shopping for cannabis products, customers are advised to look for a certificate of analysis (COA), a document produced by a third-party lab that’s independent of the manufacturer. A COA establishes that a product was analytically tested and meets specifications of safety and quality.

However, the Food & Drug Administration (FDA) still has yet to issue rules and regulations for hemp products, cannabinoids and edibles. Thus, a COA might not always show a complete picture of what’s in the cannabis product you’re about to purchase.

How does one navigate this wild west of information, or lack thereof? Erik Fuchs, compliance director at Ethereal Gold Dispensary (237 Harrison Ave., Waukesha), along with his father, Bill Fuchs, give presentations on reading COAs. Bill is the founder of Logical Green Solutions, a consulting firm that helps cannabis farmers and indoor growers with grow systems and LED grow lights, and a member of the Midwest Hemp Council.

Many COAs list only the potency of a product because it’s more economical for a manufacturer to just test potency, Bill explains. Some states only require a bare minimum of potency testing. But a full panel COA lists the presence of residual solvents, heavy metals, microbial contaminants and mycotoxins, contact information for the laboratory, a product description and other vital information.

“Customers are generally very surprised when they learn that third party lab tested does not mean a full panel lab test. The general reaction from customers when we explain that every product at Ethereal Gold Dispensary is full panel lab is that they share a story of how they picked up a product at a gas station or convenience store and it didn’t work, it made them incredibly sick, or they experienced hallucinations or extreme queasiness,” Erik shares.

Reading a Certificate of Analysis

The format of COAs can vary from lab to lab, Bill explains, but look for the following on all full panel COAs:

The product manufacturer: A COA should list who manufactured the product. “We’ve found that manufacturers, particularly those from overseas, just put ‘unknown’ because they don’t want it to stand out. Or they leave it blank,” Bill says.

Laboratory information: The testing lab should be listed, along with an address and phone number.

Product description: There should be a clear description of the product. Some full panel COAs include a photo. “If the product you’re looking at is a gummy, and you have a test report for a tincture, it’s probably not right,” Bill affirms.

The COA should list a batch number; the date it was tested, which should be recent; and the sampling methods, such as if a whole pack of gummies or just a section of a gummy was tested.

Potency: A COA should list the potency of all of the cannabinoids in the product.

Cannabinoids: Lists the percentage of cannabinoids present, including cannabidiol (CBD) and tetrahydrocannabinol (THC) content.

Pass/Fail: The pass/fail section tell users the overall cleanliness of the product.  A notation of “none detected” for residual solvents like butane or acetone will earn a passing mark.

Terpenes: This section lists the flavor and aroma profile of the cannabis strain.

Signature: A full panel COA should be signed off by the scientist or toxicologist at the laboratory.

Quick response (QR) code: There should be a QR code on the product you’re buying, which links to the full panel COA report. “It should not just link to the lab’s or manufacturer’s website,” Bill notes. Investigate further if there’s a broken link. Sometimes cyberspace glitches happen, but it could also mean that a COA isn’t available.

Spotting Altered Certificates of Analysis

Words like “unknown” or missing information: If it’s unknown, then it is unknown. If there’s no information listed for heavy metals or pesticides, the product likely wasn’t tested for those contaminants.

Confirm results are recent, and a batch number: Bill and Erik have seen some manufacturers provide test reports from 2020 for 2021. “We want to see a test for every batch they run,” Bill explains. “Just like for food, if a bad batch comes up, you know the batch and can warn people not to use it.”

Watch for Inconsistent Font: A sign a COA has been altered will have information listed in varying fonts, or blank spots where information should be listed. Bill and Erik have seen reports where manufacturers have scrubbed information from a COA. When they checked with the listed lab, they discovered the product didn’t pass.

Question Any “THC-free” Claim: Some products are labeled “THC-free,” but the COA testing shows less than .3 THC, the federal legal limit. That’s deceiving for those looking for a true THC-free product, Bill notes. A THC-free product should list “trace” or “none.”

What Part of the Plant Was Tested? When purchasing flower, the COA should list which part of the plant was tested. Some products might be “hot”—containing more than the federally legal limit of .3% THC—because the whole plant was tested instead of just the flower. Adding stems and leaves into the testing process can lower THC content. The legality of this practice varies from state to state.

Phrases Like “Sample,” “Informational Only” or “Analysis Report”: These are not COAs, per se. “The reason manufacturers don’t do complete panel COA reports is because they either have bad products, they can’t meet standards or they want to save money,” Bill says. A complete panel COA can run approximately $500 per test per batch. Some states charge a tax for COAs, but not for an “analysis report.”

Hidden Information on Packages: Bill pointed to a photo of a cannabis product that had stickers strategically placed on the box. When the Ethereal Gold Dispensary team investigated further, they found discrepancies with the listed dosages.

Celebrity Brands Might Not Be What They Seem: It’s “in” for celebrities to throw their names behind wine, spirits and cannabis. While there are some good quality celebrity brands, Bill showed an example of a celebrity-endorsed cannabis product in which the company simply bought product and repackaged it under the celebrity’s brand. In addition, the product included a minimal COA created on a Word document.

If customers are unsure about a COA, Bill advises to call the lab. “Most will gladly take calls,” he says. In addition, Ethereal Gold Dispensary will take competitors COAs and analyze them for free.