Certificate of Analysis and its Pitfalls
As the cannabis industry continues to evolve in medical, supplemental and infused food & drink products, certificate of analysis (COA) plays a major role in labeling hence protection of public health and safety. Manufacturers, consumers, retail outlets, and regulators must depend on the COA for the safety and efficacy of these products. A certificate of analysis (COA) provides a comprehensive report on the content of products (type of cannabinoids) as well as the test results of potential contaminants such as pesticides, heavy metals, residual solvents, foreign matter that may be present in the product. Mislabeled products are in plenty in the market due to an overall lack of specific industry standards. A study conducted in 2017 found that almost 70% of online CBD products are mislabeled, either having substantially more or less CBD than advertised. This has caused an issue for many consumers who purchase products on false pretense, later to find out they have received lesser quality CBD than advertised or other safety concerns of the product. All COA’s are not created the same! Unfortunately, there is a fundamental lack of consistency and mandatory information that all COA’s must require in order to fully assure the safety and efficacy concerns. This needs to be streamlined and minimum requirements developed by the regulatory agencies and FDA. The list of topics is long and must be discussed as part of the standardization of COA’s What are the minimum testing requirements for each type of product? Side effects? General informative narratives? QR codes for consumer access in real-time Certificate of conformance vs Certificate of Analysis Additionally, industry and regulatory agencies must examine the legality and liability of COA of analysis from the third party laboratory to manufacturer and retailer. Who is the responsible party?