What is a Certificate of Analysis (COA)?

A COA is a regulatory compliance document issued by a third-party testing laboratory certifying a product's cannabinoid content, contaminants, and compliance with state law.

What kinds of COA irregularities were documented?

Documented irregularities include outdated COAs applied to current lots, duplicate lot numbers across different products, COA results altered to show 'passing' values, and missing COAs for products actively on retail shelves.

Are COAs public records?

COAs from licensed testing laboratories are public records under state hemp testing regulations. The Original Documents Library indexes all references.

Certificate of Analysis Irregularities

Fact: Certificates of Analysis were outdated, misapplied to different product lots, or adjusted to create the appearance of regulatory compliance.

What Was Found

Examination of the COAs provided by Nutrition Excellence LLC revealed the following issues:

Outdated certificates: Some COAs on file predated the product lots they were associated with, or had expired under state testing requirements.
Misapplied COAs: Certificates referencing one formulation or product lot were used to represent different products.
Apparent adjustments: Inconsistencies between COA data and actual product contents as represented on labels, particularly regarding CBD content in North Dakota-labeled products.

Original laboratory reports have been requested from the Minnesota Office of Cannabis Management and the North Dakota Department of Agriculture as part of the pending regulatory proceedings.

Applicable Standard

North Dakota law requires hemp-derived products to be tested in accordance with NDCC 4.1-18.1-04.4, including accurate representation of cannabinoid content on certificates of analysis.

Regulatory Action

COA-related allegations have been included in complaints addressed to: