COA Expiration & Retesting

You're listening to HempDash Academy — practical compliance education for hemp retailers. Today's lesson: COA Expiration & Retesting. Do hemp COAs expire in Texas? Yes — and the rule says exactly what that means. What §300.301(f) requires when a COA expires, what retesting involves, and how to run expiry dates as a calendar discipline instead of an inspection surprise. In this lesson, you will learn: Answer 'do COAs expire?' with the exact Texas rule, not folklore. Know what §300.301(f) requires when a COA expires — and what it leaves open. Tell COA expiration apart from batch dates and ingredient use-by dates. Run COA expiry as a calendar discipline across your whole inventory. The short answer: yes, COAs expire. In Texas, every Certificate of Analysis must carry an expiration date — it is item (9) of the 12 items required on a COA under 25 TAC §300.301(d). (The full list, and how to check a COA at intake, is covered in Understanding COAs — this lesson assumes that ground and goes deeper on the expiry piece.) The rule is unusually blunt about what that date means. §300.301(f), in full: 'Expired COAs are not valid. Consumable hemp products with expired COAs must be retested and are subject to detention or embargo under Texas Health and Safety Code §431.048.' An expired COA doesn't fade — it stops working. A product on your shelf whose only COA has expired is, in the rule's own terms, a product without a valid COA. These are the DSHS Consumable Hemp Program rules as amended effective March 31, 2026. Everything in this lesson is Texas law; other states run their own regimes. What the rule requires — and what it leaves open. It helps to be precise about which parts of this are rule text and which parts are operating judgment. The rule side: Where the rule is silent, treat the gap as a question for your supplier agreements and your attorney — not as permission. The conservative operating posture is simple: a COA that is expired, or about to expire, is a supply-chain problem you raise with your supplier before the date hits, and a product you don't leave on the shelf on the strength of an invalid document. Rule requires: an expiration date on every COA — §300.301(d)(9).. Rule requires: expired COAs are not valid — §300.301(f).. Rule requires: products with expired COAs must be retested — §300.301(f).. Rule exposes: those products to detention or embargo under HSC §431.048 — §300.301(f).. Rule also covers fraud: forged, falsified, or altered lab results are a violation, and those products must likewise be retested and are subject to detention or embargo — §300.301(e).. Rule does NOT say: how long a COA is valid. Chapter 300 does not prescribe a fixed validity period; use the expiration date stated on the COA.. Rule does NOT say: who must arrange the retest. Subsection (f) is written in the passive — 'must be retested' — without assigning the duty to the manufacturer, distributor, or retailer.. Rule does NOT say: whether a passing retest fully restores a product already detained, or exactly what a retest panel must cover.. Three different dates — don't mix them up. COA expiration is one of three date concepts in the rules, and confusing them causes real mistakes. First: the COA expiration date (§300.301(d)(9)) — when the lab document stops being valid. Second: the batch date on the product label — the date the batch was made, which the rules also call the lot date (§300.101(6)); the retail label list in §300.402(a) requires batch number and batch date, and notably does not include a product expiration date. Third: on the manufacturing side, every raw material and ingredient must be identified with an 'expiration, re-test, or use-by date' (§300.206(b)(5)) — a traceability requirement inside the facility, not something you'll police at retail. The practical takeaway for a store: the date that governs whether you can rely on the paperwork is the one on the COA. A fresh-looking product with an expired COA is still a compliance problem; an older batch date with a current, matching COA is not — at least not on this axis. Retesting, in practice. A retest is a new laboratory analysis of the same lot, by an accredited (ISO/IEC 17025) laboratory, producing a new COA for that lot. The rules around it that do exist are worth knowing: everyone in the chain must ensure products are tested against the department's most current analyte list (§300.303(h)) — so a retest is run against today's panel, not the one that applied when the lot was first tested. Testing costs are paid by the manufacturer, processor, or retailer at the rate the chosen lab prescribes (§300.303(d)). And results must be retained for at least three years from receipt (§300.303(f)) — keep the old COA and the new one. Two more reasons not to let this drift. DSHS conducts random testing of consumable hemp products at retail (§300.302(c)) and can demand samples at the licensee's or registrant's expense (§300.302(d)) — your paperwork can be checked against a fresh state-run analysis at any time. And the retest COA must be verified like any COA: same lot number as the product on your shelf, QR code resolving to the lab, full results. A retest COA for a different lot is not a retest of your inventory — it's a different product's paperwork. One open question to resolve with your supplier and counsel rather than by guessing: the retail label must carry a URL that reaches the product's COA within three steps (§300.402(a)(6)). When a lot is retested, confirm where that link now leads and that a customer or inspector following it reaches a valid, current COA. If DSHS gets there first. The enforcement chain behind §300.301(f) is concrete. The department tags or marks an article it finds — or has probable cause to believe — is adulterated or misbranded (§300.603, mirroring HSC §431.048); a tagged article can't be used, moved, or sold without authorization. From there the paths are: court-ordered destruction at the claimant's cost (§300.604), or court-ordered correction by proper labeling or processing under department supervision, where the defect is correctable (§300.605). Administrative penalties are also on the table (§300.606) — though the department must notify a retailer of a potential violation and give the registrant an opportunity to resolve unintentional or negligent violations (§300.606(b)). That notice-and-cure provision is real, but it is not a strategy. The whole reason to run COA expiry off a calendar is so that the first person to notice an expired COA is you, with weeks of runway — not an inspector, with a roll of tags. Red flags. Any of these should stop a product, or stop a shipment at the door: A COA with no expiration date at all — a required field is missing (§300.301(d)(9)). An expired COA anywhere in your active-inventory files. A supplier who responds to an expiring COA with a COA for a different lot. A 'retest' COA from a lab you can't verify as accredited, or with no QR code resolving to the lab. A retest reporting fewer analytes than the original — current analyte list applies (§300.303(h)). Any sign a COA's dates or results have been altered — that's the §300.301(e) problem, and it's severe. The label's COA link or QR resolving to an expired document. Here is a real-world example. A retailer's monthly file review flags a gummy line whose COA expires in ten days. She emails the distributor asking for a retest COA for LOT-4188 — the lot on her shelf. The distributor replies same day with a brand-new COA… for LOT-5023, the batch currently shipping. Tempting, and useless: a COA belongs to its lot. LOT-5023's paperwork says nothing about LOT-4188. Two clean endings exist: the distributor gets LOT-4188 retested and sends the new COA before the old one lapses, or the retailer swaps her remaining LOT-4188 stock for LOT-5023 units — product and paperwork moving together. She picks the swap, files both COAs, and her shelf never spends a day backed by an invalid document. Key takeaways. Every Texas COA must carry an expiration date, and expired COAs are not valid — 25 TAC §300.301(d)(9) and (f). An expired COA means the product must be retested, and it is exposed to detention or embargo under HSC §431.048 in the meantime. The rule sets no validity period and doesn't say who arranges the retest — settle those in supplier agreements and with counsel, and run expiry dates on a calendar. COA expiration, label batch date, and ingredient use-by dates are three different things — and a retest COA must match the lot you actually hold. And finally, the checklist: COA expiry watch checklist. Every COA on file has an expiration date recorded — a missing date is itself a red flag. COA expiration dates live in a calendar or tracker, not just inside the PDFs. A recurring review catches COAs expiring within the next 30 days. Expiring soon: request a retest COA for the same lot from your supplier before the date. Expired with product still on shelf: pull the product until a valid COA for that lot exists. Verify the retest COA like any COA — lot match, QR to the lab, current full analyte panel. Retain the old and new COAs; keep results at least three years (§300.303(f)). Confirm the label's COA URL/QR reaches a current, valid COA after any retest. You've completed this HempDash Academy lesson. Test what you learned below, or see how HempDash can help put it into practice. This recording is educational information, not legal advice — rules change, so verify current requirements with DSHS and your attorney.