USDA hemp registration, what must merchants maintain, and what sample test cadence?

Under the 2018 Farm Bill, hemp (cannabis sativa L. with ≤0.3% delta-9 THC by dry weight) is federally legal. Each hemp grower needs a USDA-approved license (either directly from USDA or via an approved state hemp program, most states run their own). As a merchant selling finished products, you don’t need a grower license, but you need to maintain documentation that:

• Your hemp source has a current USDA-approved license (request a copy annually).
• Each lot tests ≤0.3% delta-9 THC by dry weight at an ISO-17025-accredited lab (this is the COA workflow above).
• You retain COAs for at least 3 years (some states want 5).

Sample test cadence: every batch. A “batch” is a single homogeneous production run, usually 1,000-10,000 units depending on product. Smaller brands often test once per quarter and pretend it covers everything; that’s the bet that loses if an AG audits. Real brands like Charlotte’s Web and Lazarus Naturals test every batch and publish the COA publicly.

Magento side: we capture USDA license number + state hemp program in store config, surface it in the footer, the privacy/terms page, and on every COA page. If a state inspector visits the site, the documentation trail is one click away.