Which Texas Hemp Rules Are Unsettled, and Which Are Not

Somebody asked a version of this question in every channel we watch this week: everything is in court, so does any of it still apply to me?

The question is reasonable. The premise inside it is not, and the premise is doing all the damage.

Texas hemp is not one rule with one status. It is a set of separate records, each with its own effective date, its own verification history, and its own open questions. They are being reported as a single weather system — "the Texas THC ban," singular — and they do not move together. A filing aimed at one of them does nothing to another.

So here is the map, record by record, in the state our review actually holds it.

The COA content requirements — verified, effective, no stay identified

25 TAC §300.301(d) names twelve fields as a condition of sale. Laboratory identification and contact information. Sample and lot identification. Analytical methods and instrumentation with limits of detection and quantitation. An expiration date. Measurement-of-uncertainty analysis parameters. A QR code verifying the authenticity of testing at an accredited laboratory. And results reporting three values — delta-9 THC, total delta-9 THC, and total THC per container.

That field list was verified on August 16, 2026 against two independent official publications, and its completeness was ratified by our compliance team on August 17. It took effect March 31, 2026, and our record identifies no stay or injunction against it.

That is the whole of what we say about it. We are not telling you it is being enforced this week, and we are not telling you it is not. Those are different sentences from the one above, and we do not have the second one.

The field set itself is walked through in [The Twelve Fields a Texas COA Must Carry](https://gethempdash.com/learn/texas-coa-requirements-twelve-fields).

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

Registration and fees — verified, and not the thing in dispute this week

25 TAC §300.502(g) sets registration at $5,000 per retail location, for the registration and again for the renewal. §300.202(c) sets $10,000 per facility license, likewise for both. A $1,000 delinquency fee applies; a minor amendment is $125; the fees are not prorated.

Triple-source verified on August 16, 2026, with no interpretation questions open. Effective March 31, 2026.

We flag this one separately because a widely-ranking registration explainer still tells operators the figure is $155 per location, and has done so for two weeks running. That is a number people are budgeting against. It is worked through at [What a Texas Retail Hemp Registration Costs](https://gethempdash.com/learn/texas-hemp-registration-fees-per-location).

Source: 25 TAC §300.502(g) and §300.202(c), adopted rules (TRD-202601066). In effect March 31, 2026.

The total delta-9 THC threshold — text verified, posture open

The threshold binds total delta-9 THC, at 0.3% or less on a dry weight basis, inclusive, with an allowance where the accredited laboratory's measurement of uncertainty produces a range including that figure. Total delta-9 THC is computed as delta-9 THC plus 0.877 times THCA.

The rule text is verified — dual-sourced, string-identical across the DSHS adopted-rule PDF and the Texas Register adoption notice. The enforcement posture is a separate field on the same record, and it is under review. We assert it in neither direction, and we did so before any of this month's filings.

This is the distinction the whole page turns on. A rule's text and a rule's enforcement posture are two different questions with two different answers, and they can sit in different states on the same record at the same time. Merging them is how people get surprised in both directions — reformulating against something that is not settled, or ignoring something that is.

The arithmetic is at [Total Delta-9 THC Is a Computed Value](https://gethempdash.com/learn/total-delta-9-thc-how-it-is-computed).

The July 31 scheduling action — pending, and scope undecided

The controlled-substance scheduling of manufactured and synthesized cannabinoids, published at 51 TexReg 4597 on July 10, 2026 with an effective date of July 31, 2026, is on our record as pending review. Its primary-source deep link is outstanding, and the record declines to decide which products and processes fall inside "manufactured" or "synthesized."

Retailer-facing pages continue to state without qualification that raw THCA flower is a scheduled substance in Texas as of July 31. We are not repeating that, for a reason we set out in full yesterday: the specific thing we have not confirmed is the exact hinge the claim turns on. That is at [THCA Reaches Texas Rules Two Different Ways](https://gethempdash.com/learn/thca-two-texas-rules).

The federal provisions — scheduled, not present tense

P.L. 119-37 is scheduled to take effect on November 12, 2026. It is a future requirement, it appears as one everywhere we write about it, and it changes nothing today. We keep saying this because we keep reading it in the present tense.

What a lawsuit does to a record

Less than people think, and slower.

A filing is a request. It asks a court to do something to a rule. Until a court does that thing, the rule sits where it sat — which is why "this is being challenged" and "this does not apply to me" are not the same sentence, and why the distance between them is measured in months rather than news cycles.

What we know this week is that a petition was filed August 20 in the 459th Judicial District Court of Travis County, that a complaint was filed August 19 in the U.S. District Court for the Western District of Texas, and that a third action in the Southern District has been reported. Temporary restraining orders and temporary injunctions are sought in these matters. No ruling has been reported to us.

Every one of those sentences is press reporting. We have not pulled a docket, we are not characterising the merits, and we are not forecasting an outcome.

One more thing about the coverage, since it is being repeated everywhere without the qualifier: the economic figures circulating this week — jobs, revenue, percentage declines — come out of a complaint. A number in a pleading is an allegation. It may well turn out to be right. It has not yet been established, and reprinting it as a measurement is how a claim launders itself into a fact. We do not publish figures we have not verified, and that includes figures that would be convenient for us.

What is worth doing this morning

Work out which record your actual question sits on.

"Can I still stock this?" is a scope question, and scope is the part nobody has settled. "Does this certificate report what the rule requires?" is a field-set question, and that record is verified, effective since March 31, and carries no stay we have identified.

The second question is answerable today, entirely inside your own shop, and its answer does not change based on how the first one resolves. That is not a consolation prize. In a week with three filings and no rulings, it is the only category of work that cannot be undone by something a court does next month.

The full record set, with each status shown rather than summarised, is at [the Texas Rule Center](https://gethempdash.com/texas-rules).