Does a Texas COA Need an Expiration Date?

Short answer: yes. An expiration date is one of the twelve fields that 25 TAC §300.301(d) requires on a certificate of analysis for consumable hemp products, as a condition of sale in Texas.

Source: 25 TAC §300.301(d), adopted rules filed with the Secretary of State March 2, 2026 (TRD-202601066). In effect March 31, 2026.

Why this question comes up so often

Because a certificate with no expiration date looks complete. It has a laboratory name, a set of results, a date of testing. Nothing about it advertises a missing field, and the omission is invisible unless you are checking against the required contents specifically.

The operational problem is silence

Most compliance failures announce themselves in some way. This one does not.

A certificate does not break. It expires. When the date passes:

• nothing changes on the shelf
• no system raises an alarm
• no vendor sends a notification
• the product is physically identical to how it was the day before

And the evidence supporting it has lapsed.

This makes expiration a time problem rather than a document problem, which is why filing systems tend not to catch it. A folder is organised by where things are, not by when they stop being current.

What to do about it

• Record the expiration date as data, not as something inside a PDF. A date you cannot query is a date you will not act on.
• Check it at receiving. A certificate that arrives already close to expiry is a known future gap, and the cheapest moment to raise it is before the case is on the shelf.
• Review by date, not by vendor. The question "what expires in the next 30 days" cannot be answered by a vendor-organised folder.

Related questions

Is a certificate with no expiration date automatically invalid? This page does not make that claim. What the rule establishes is that an expiration date is among the required contents. A certificate lacking a required field is non-passing on that field, which is a narrower and more precise statement than a verdict on the document as a whole.

Does an expired certificate mean the product is non-compliant? Also not a claim this page makes. It means the evidence you are relying on is no longer current, which is a problem in its own right regardless of the underlying product.

What are the other eleven fields? They are covered field-by-field in the Twelve Fields guide, which also flags the ones most commonly absent.