Lot & Batch Traceability

You're listening to HempDash Academy — practical compliance education for hemp retailers. Today's lesson: Lot & Batch Traceability. What a lot actually is under the Texas hemp rules, why the batch number on the label has to match the lot number on the COA, and how lot identity runs through records, inspections, and recalls. In this lesson, you will learn: Define 'lot' and 'batch' the way the Texas rules do — and know they're the same thing. Explain why the batch number on a label must match the lot number on its COA. Know which lot records the rules require, who keeps them, and for how long. Run intake and inventory so every unit on your shelf traces to a matching COA. The short answer: the lot number is the join key. A lot (Texas rules also say 'batch') is one specific production run of a product — a defined amount made together, tested together, and identified by one number. That number is required in two places: on the product label as the batch number (25 TAC §300.402(a)(1)) and on the Certificate of Analysis as the lot identification number of the tested sample (§300.301(d)(5)). The label also has to carry a URL that reaches the product's COA (§300.402(a)(6)). That's why the number on the package has to match the number on the COA: the COA only speaks for the lot that was actually sampled and tested. If the label says one lot and the COA says another, the document in your file describes a different production run — for the product in front of you, you effectively have no COA. Same recipe is not the test; same lot is. What Texas means by 'lot' and 'batch'. The governing rules are 25 TAC Chapter 300 — the DSHS Consumable Hemp Program rules covering manufacture, distribution, and retail sale, as amended effective March 31, 2026. Chapter 300 never defines 'lot' or 'batch' as standalone words. Instead it defines the two identifiers, and builds the lot vocabulary into them. The batch ID number identifies 'a specific amount of raw or processed hemp product that meets standards for identity, strength, purity, and composition,' and it must include the manufacturer's, processor's, or distributor's number plus a sequence 'for inventory, traceability, and identification' of the plant batches used (§300.101(7)). The rule adds: 'This is also called the lot number.' The batch date is 'the date a product batch was made, used for tracking and quality control' — 'also called the lot date' (§300.101(6)). So when the COA rule says 'lot identification number' and the label rule says 'batch number,' those are two names for the same identifier. Batch equals lot in this chapter; don't let a supplier tell you otherwise. What the rule requires — and what's operating discipline. The rule never says 'each lot must have its own COA' in one sentence. It doesn't have to — the structure does it: testing runs on a representative sample, the COA names that sample's lot, and the label names the lot and links to the COA. Put together, a COA for a different lot is a different product's paperwork. Here's the split between what the rule text commands and what we recommend as discipline: RULE: the label must show the batch number and batch date — §300.402(a)(1)–(2).. RULE: the COA must show the lot identification number of the sample — §300.301(d)(5).. RULE: the label must carry a conspicuously marked URL that reaches the product's COA in three or fewer steps — §300.402(a)(6).. RULE: a representative sample of the product must be tested before it's sold at retail — §300.301(b).. DISCIPLINE (ours, not the rule's): at intake, physically read the batch number on the package and match it to the lot number on the COA before anything is shelved. Record lot numbers at receiving. File COAs so you can pull any one by lot number. Verify by reading the printed number — not from memory, and never on a 'same recipe' assurance.. The paper trail behind every lot. Upstream of your store, lot identity is engineered, not decorative. Manufacturers and processors must keep master production records 'to ensure uniformity from batch to batch' (§300.204(a)) and batch production records for each batch (§300.205). They must maintain COAs of finished products by batch number, batch production records, and recalled product information — and every required record must include the identity of the product and the batch number (§300.203(d)(2), (4)–(5), (e)(4)). Even their raw ingredients must be identified by the 'batch or lot number from original package' (§300.206(b)(2)). Practical consequence for you: a per-lot COA always exists on their side. Asking for it is never an unreasonable request. On retention: records described in the chapter must be kept for no less than three years after they're created, maintained on site for immediate inspection, with access for DSHS or TABC on request (§300.203(a), (c)) — and manufacturers, processors, and retailers must retain test results for at least three years from the date results are received (§300.303(f)). How far the on-site duty reaches into a retail registrant's file cabinet is not spelled out; our conservative read is that the COAs and test results for what you sell should be retrievable on site, by lot number. Ask your attorney where your exact line is. One more thread: when a manufacturer investigates a product complaint, the record must include 'the batch number and batch date of product used' (§300.208(d)(3)). Lot identity runs through every record duty in the chapter — it's the chapter's unit of accountability. Lots are how recalls work. Recalls are lot events. §300.207(a) requires all facilities engaged in the manufacture, processing, distribution, or retail sale of consumable hemp products — that includes your store — to maintain written recall procedures, covering at minimum identification of recalled products and their immediate removal and segregation from sale and active inventory. The fuller recall-plan duty in §300.207(b) sits on manufacturers, distributors, and processors, not retailers. The rule doesn't say 'recalls operate by lot number' — but the batch number provides a primary traceability handle for identifying affected product — it's what the label and the COA carry. If you can't answer 'which units on my shelf are lot 2026-0483?' in minutes, you can't execute the removal-and-segregation step your written procedures must describe. What those written procedures should contain, and how a retail recall actually runs end to end, is its own topic — a later lesson covers it; for now, have procedures in writing and route the specifics through your attorney. Red flags. Stop a product before the shelf if you see any of these: Label batch number doesn't match the COA's lot identification number — 'same recipe' is not an answer. No batch number or batch date on the label at all. One shipment, multiple lots of the same SKU, but only one COA. Label URL or QR resolves to a COA for a different lot, or to a marketing page. Supplier offers a 'master COA' or 'product-line COA' covering all lots. Lot numbers that change format between the label, the invoice, and the COA — verify before shelving, don't assume. Here is a real-world example. A retailer receives 12 cases of the same gummy SKU in one delivery. At receiving, the batch numbers on the packages show two lots: eight cases of LOT-2026-0512 and four of LOT-2026-0483. The paperwork includes one COA — for 0512. The distributor's email says 'same product, same formula, COA attached.' Under the per-lot scheme, that shipment is two products. The 0512 cases have matching documentation and can be shelved. The 0483 cases have no COA — a COA for a different lot is a different product's paperwork — so they wait in the back, segregated and marked, until the 0483 COA arrives and matches. The store didn't reject the whole delivery and didn't shelve all of it; it split the decision exactly where the lot numbers split. Key takeaways. In Texas rules, batch = lot: the batch ID number 'is also called the lot number' (§300.101(7)), and it must trace to the manufacturer and production sequence. The lot number is the join key — label batch number (§300.402(a)(1)) must match the COA's lot identification number (§300.301(d)(5)), because the COA only speaks for the lot that was tested. Lot records run three years deep: on-site, inspectable records (§300.203) and test-result retention for manufacturers, processors, and retailers (§300.303(f)). Recalls operate on lot identity — and written recall procedures are required at retail too (§300.207(a)). If you can't find a lot on your shelf fast, you can't run the procedure. And finally, the checklist: Lot traceability checklist. Every product on the shelf shows a batch number and batch date on its label. At intake, the label's batch number is matched — by reading it — against the COA's lot identification number. Mixed-lot shipments are split at receiving: each lot shelved only with its own matching COA. Lot numbers are recorded at receiving, so 'which units are lot X?' is answerable in minutes. COAs and test results are filed retrievable by lot number, kept at least three years, and available on site. Written recall procedures exist and name who identifies, pulls, and segregates a recalled lot. Label URL/QR spot-checked: it reaches the COA for this lot, not another. 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.