One COA. Three Different Stories.
- Rhiannon Yard, MBA
- 2 days ago
- 4 min read
Why the same Certificate of Analysis can mean three different things depending on who's reading it.
Why a COA Can Be Misunderstood
A Certificate of Analysis (COA) should be one of the simplest documents in the hemp industry.
Instead, it has become one of the most misunderstood.
That's because a COA isn't written for just one audience.
It's written for consumers.
It's written for laboratories.
It's written for regulators.
And each of those audiences is looking for something completely different.
The problem isn't that those three perspectives exist.
The problem is that they're often presented together without explaining how they relate to one another.
Story #1: The Consumer
Imagine you buy a hemp beverage.
You aren't asking yourself:
"Is this product below 0.3% Total THC?"
You're asking:
How many milligrams of THC are in this bottle?
How many servings are there?
How much THC will I consume if I drink the whole thing?
That's why product labels and COAs prominently display:
Milligrams (mg)
Serving size
Servings per package
Those numbers tell you what you're actually consuming.
They're practical.
They're easy to understand.
They're meaningful.
Story #2: The Laboratory
Now step into the laboratory.
The chemist isn't thinking about serving size.
The laboratory's work extends far beyond cannabinoids. Depending on the product and jurisdiction, a COA may also include heavy metals, pesticides, residual solvents, microbial contaminants, mycotoxins, water activity, moisture content, and other quality and safety analyses.
Each of those tests answers a specific scientific question. Heavy metals ask whether the product is safe from toxic elements. Microbial testing asks whether harmful organisms are present. Residual solvent testing evaluates manufacturing purity.
Cannabinoid reporting occupies a unique role. It doesn't simply describe chemistry; it also becomes part of the legal determination of whether a product qualifies as hemp.
A typical COA may report:
Delta-9 THC
THCA
CBD
CBDA
Other cannabinoids
Measurement uncertainty
Pass/Fail results
The laboratory is answering a scientific question:
What cannabinoids are present, and in what quantities?
That's analytical chemistry.
Story #3: The Regulator
Now imagine you're a regulator.
You're asking something different.
Does this product meet the legal definition of hemp?
To answer that question, laboratories may be required to report Total THC in accordance with applicable regulations, including accounting for the potential contribution of THCA through the regulatory Total THC calculation.
That serves a legal purpose.
It is not the same as describing the amount of Delta-9 THC present in the product today, and it is not the same as describing the amount a consumer expects to see on a label in milligrams per serving.
Three Languages. One Report.
This is where the conversation becomes interesting.
A COA may simultaneously communicate:
Milligrams
How much cannabinoid is in a serving or package.
Analytical Results
The cannabinoids measured in the laboratory.
Regulatory Classification
Whether the product meets the legal definition of hemp under the applicable rules.
Those aren't competing ideas.
They're different ways of describing the same product for different purposes.
The Question That Keeps Coming Back
Here's where I continue to have questions.
When a finished beverage, gummy, or tincture is reported as containing a certain number of milligrams of Total THC per serving and is also reported as being below 0.3% Total THC, how are those two descriptions connected?
More specifically, what analytical methodology connects the laboratory measurements reported on the COA to the regulatory percentage used to classify the finished product?
For harvested plant material, moisture can vary significantly, making dry weight a practical way to standardize comparisons.
Finished products are different.
A beverage contains water.
A gummy contains sugars, gelatin or pectin, flavorings, and other ingredients.
A tincture contains oils.
These products are formulated to be consumed exactly as they are sold, not in a dried state.
Somewhere between the laboratory measurements and the final regulatory determination, analytical data becomes a legal classification.
Understanding that transition is where my questions begin.
So what analytical process bridges the gap between:
the milligrams reported to consumers,
the laboratory's cannabinoid measurements,
the Total THC calculation that includes THCA conversion,
and the percentage used for regulatory classification?
Each analytical result on a COA is generated using an analytical method. That naturally raises the question of how the regulatory percentage reported for a finished product relates to those underlying measurements and calculations.
Is there a standardized methodology applied across finished product types?
If there is, understanding that methodology would help manufacturers, laboratories, retailers, attorneys, regulators, and consumers speak the same language.
Better Questions Lead to Better Standards
None of this calls into question the ability of laboratories to accurately measure cannabinoids.
Nor does it question the importance of having objective standards.
It simply recognizes that a modern Certificate of Analysis is doing several jobs at once.
If we want a transparent and consistent hemp market, we should be able to clearly explain how those jobs fit together.
A Certificate of Analysis shouldn't require three different interpretations.
Consumers should understand what they're consuming.
Laboratories should clearly communicate what they've measured.
Regulators should be able to explain how those measurements relate to the legal standard.
When those three perspectives align, confidence in the system grows.
When they don't, questions about consistency, transparency, and methodology are inevitable.
A consumer buys milligrams.
A laboratory measures chemistry.
A regulator classifies a product.
A Certificate of Analysis has to connect all three.
Good science isn't just about measuring accurately. It's about making sure everyone understands what those measurements mean.
If we can't clearly explain how one Certificate of Analysis connects milligrams, laboratory measurements, and legal classification, perhaps the next step isn't more debate—it's better explanation.