Product Labels

You're listening to HempDash Academy — practical compliance education for hemp retailers. Today's lesson: Product Labels. Direct answer: a Texas consumable hemp label needs eight specific pieces of information, five verbatim warnings, and packaging that is tamper-evident and child-resistant — required by 25 TAC §§300.402–407 (effective March 31, 2026) and HSC §443.205. This lesson gives you the exact lists and a two-minute review to check any label against them. In this lesson, you will learn: Name the label elements Texas requires (rule and statute), with cites. Recite the five required warnings and where the label must appear. Know the three packaging requirements — not just child-resistant. Connect the label to the COA — the two must work together. Run a two-minute label review that catches the common failures. The short answer. In Texas, product labels and packaging for consumable hemp are governed by 25 TAC Chapter 300, Subchapter D (§§300.402–300.407), as amended effective March 31, 2026, which implements Health and Safety Code §§443.204–443.205. Jurisdiction: Texas — if you sell in Texas, this applies to what's on your shelf, including products made out of state (§300.403). What the rules require, in one breath: eight label elements (including a working link to the product's COA), five specific warnings, the label on the outer packaging of every unit sold at retail, and packaging that is tamper-evident, child-resistant, and — for multi-serving products — resealable. Everything below is the detail, with the rule-requires items separated from our operational advice. What the rule requires on the label. 25 TAC §300.402(a) and HSC §443.205(a) together require every consumable hemp product marketed as containing cannabinoids to be labeled with: Batch number (also called the lot number) — §300.402(a)(1). Batch date — §300.402(a)(2). Product name — §300.402(a)(3). Name of the product's manufacturer or processor — §300.402(a)(4). Telephone number and email address of the manufacturer or processor — §300.402(a)(5). A URL that provides or links to the product's COA (or a COA for each hemp-derived ingredient) — §300.402(a)(6). The URL must be conspicuously marked and must reach the COA in three or fewer steps. Recommended serving size in milligrams, and servings per container — §300.402(a)(7). A certification that the delta-9 THC concentration of the product (or each hemp-derived ingredient) is not more than 0.3 percent — HSC §443.205(a)(6). The QR code question. Rule-requires: a URL. A QR code is welcome — the statute expressly contemplates scannable codes — but DSHS's current guidance is blunt: you can use a QR code, but the URL itself must still appear on the label. Treat a QR-only label as a gap until counsel tells you otherwise. And the link has to work. 'Reaches the COA in three or fewer steps' is the rule's own standard — a QR or URL that lands on a homepage, a marketing page, or a dead link fails it. Scan every code at intake; where it lands is the whole point. The five required warnings. §300.402(b) requires these specific warnings on the label — treat the wording as fixed, not as themes to paraphrase: Keep out of reach of children. Product may contain tetrahydrocannabinol (THC) and can cause a user to fail a drug test. All THCs have psychoactive properties. Pregnant or nursing women should consult a healthcare provider before use. This product has not been evaluated by the FDA. Where the label goes, and what the package must be. Placement (rule-requires): the label must appear on the outer packaging of each product intended for individual retail sale — §300.402(c). The statute is looser (inner or outer), but the 2026 rule says outer; follow the rule. Packaging (rule-requires, §300.405): before sale, the product must be prepackaged — or placed, at the time of sale, in packaging — that is (1) tamper-evident, (2) child-resistant, and (3) resealable if it holds multiple servings or multiple products, with the child-resistant mechanism staying intact. Note that 'at the time of sale' puts this duty squarely at the register: child-resistant is the requirement everyone knows, but tamper-evident and resealable are just as binding. Misleading packaging (rule-requires, §300.407): you must not sell a product in packaging that would likely mislead someone to believe it contains no hemp-derived cannabinoid, or that it's intended for medical use. Copycat packaging — what the rules actually say. Operational guidance, stated carefully: Texas's adopted rules do not contain a named 'appeals to children' or 'candy-like packaging' ban — that idea circulated in failed 2025 legislation and appears in Executive Order GA-56's recitals, but it was not adopted into Chapter 300. What does exist is sharper than a vibe: packaging that imitates a familiar candy or snack brand risks 'misleading a person to believe the package does not contain a hemp-derived cannabinoid' — a direct §300.407 problem — and copycat hemp-THC packaging has drawn joint FDA/FTC warning letters at the federal level since 2022. So the shelf rule we recommend is unchanged even though the legal basis is different than most people assume: don't stock look-alike packaging. If it could be mistaken for ordinary candy or snacks, it exposes you under §300.407 and puts you adjacent to an active federal enforcement lane. When in doubt on a specific product, ask counsel — don't guess. Label ↔ COA: one thread through the whole course. The label's lot number and its COA link tie every lesson together: the label points to the COA, the COA belongs to a lot, and the lot number connects package, document, and your records. Operationally, the label and the COA must agree — same lot, and potency consistent with what the linked lab report says. The linked COA must show the amount of cannabinoid per serving or unit, total THC, and total delta-9 THC. One conservative note: whether potency amounts must also be printed on the label itself (beyond serving size, which is required) is not crisply settled in the rule text. Our advice: make sure the amounts are reachable through the link — that's clearly required — and treat printing them on the label as best practice. Have counsel confirm your specific template. Also worth knowing exists: §300.406 requires written procedures and records for receiving, examining, approving, and destroying label stock. That duty sits chiefly with manufacturers and processors — but it's why 'the printer made a mistake' is never an accepted excuse upstream, and why you can insist your suppliers fix label errors fast. The failures a two-minute review catches. These are the mundane gaps a label review at intake catches — each one maps to a requirement above: QR code or URL that lands on a homepage or dead link instead of reaching the COA within three steps. Label lot number that doesn't match the COA (or no lot number at all). Missing or paraphrased warnings — all five, verbatim, legible. No serving size in milligrams, or no servings-per-container count. Packaging that isn't tamper-evident or child-resistant, or multi-serving packages that can't reseal. Look-alike candy/snack trade dress (§300.407 risk + federal enforcement target). Old stock with pre-March 31, 2026 labels — we could locate no grandfathering provision in the adopted rules, so treat old label stock as non-compliant until confirmed otherwise. Looking ahead: the federal cliff (not current law). Future-effective, flagged so you can plan: on November 12, 2026, a federal provision (Section 781 of the FY2026 appropriations act, signed November 2025) redefines federal hemp from 0.3% delta-9 THC to 0.3% total THC and caps finished products at 0.4 mg total THC per container. Nothing about your Texas label obligations changes today — but products and potency panels that are lawful in Texas right now may become federally unlawful on that date. If your catalog hasn't been audited against the total-THC standard yet, start before fall inventory buys. Here is a real-world example. A store received a restock of a product they'd carried for a year. Same product, new lot — but the manufacturer had reprinted labels, and the QR code now pointed to their homepage instead of the lab document. Under the amended rules that's not a cosmetic miss: the COA must be reachable in three or fewer steps from a conspicuously marked URL. One scan at intake caught it; the manufacturer shipped corrected labels within a week. Two minutes of label review at intake is dramatically cheaper than the same discovery during an inspection. Key takeaways. Eight label elements, five verbatim warnings, outer-packaging placement — 25 TAC §300.402 plus HSC §443.205. Packaging is three requirements, not one: tamper-evident, child-resistant, and resealable for multi-serving products (§300.405). A QR code doesn't replace the printed URL, and the link must reach the COA in three or fewer steps. Texas has no named 'appeals to children' packaging rule — but copycat candy packaging risks §300.407 and is a federal enforcement target. Don't stock it. The lot number is the thread: package ↔ label ↔ COA ↔ your records. And finally, the checklist: Two-minute label review. Batch/lot number and batch date present; lot matches the COA. Product name and manufacturer/processor name, phone, and email present. URL conspicuously marked; QR (if any) supplements it — and it reaches the COA in ≤3 steps. 0.3% delta-9 THC certification statement present. Serving size in mg and servings per container present. All five required warnings present, verbatim and legible. Label is on the outer packaging of each retail unit. Packaging is tamper-evident and child-resistant; multi-serving packages reseal with the child-resistant mechanism intact. Nothing about the trade dress imitates candy/snacks or suggests medical use. Label potency is consistent with the linked COA. 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.