COA Process | 2019

COA Process | 2019


AFG Distribution is committed to providing and ensuring that all CBD products we sell and distribute are of quality and follow and meet all federal and state laws. In 2018, The Trump Administration passed the Farm Bill, which took hemp off the Schedule 1 listing of controlled substances. Hemp is defined as having less than 0.3% tetrahydrocannabinol (THC). The passing of the farm bill has allowed for the legal growing, processing, and selling of Industrial Hemp using interstate commerce.  


Certificate Of Analysis (COA’s)

A certificate of analysis (COA) is a lab report on the chemical make-up (e.g., contents) of a product. In the context of Industrial Hemp derived products, the COA shows the contents of the cannabinoids & other tested compounds such as heavy metals, etc.  COA’s are used to verify that the contents of the product are matched to the advertised or marketed product. These reports are important for verifying that hemp extracts have less than .3% THC, as determined by the definition of legal Industrial Hemp in the law. 


AFG Distributions SOP for COA’s

AFG understood that Industrial Hemp products were new to the market and there was a lot of confusion with what was legal and wasn’t. Early on we decided to start collecting COA’s from our vendors.  We then imaged the hard copy to upload into our enterprise resource planning system, Netsuite.  Later we recognized that a majority of companies were sourcing Industrial Hemp from several different growers, all of which had different COA’s. We decided in May of 2019 that we would not be keeping hard copies or electronic copies of COA’s on file, due to the large number of items we warehouse containing CBD and the labor hours needed to monitor and keep current with respect to COA’s. We decided to place a link on the product page of our AFG Distribution website. This link provides a direct source for the customer to connect with the vendors' homepage for COA’s and was a way for us to keep track of who provided COA’s. Later, we began to see that companies were placing QR codes on their products, we placed this info into our website as well. When scanned the QR code will link you to the COA for that harvest. 



SOP for ensuring lab testing and compliance from vendors.

When considering bringing in a new vendor for CBD products, our product team ensures that the COA is received and vetted before the product is purchased and delivered to our facility. We also contact the testing laboratory to confirm that the lab test has not been altered and that the testing was actually done. Confirming that lab testing is legitimate will prevent a vendor from supplying us with a counterfeit COA.    

AFG will continue to monitor industrial hemp. When a hemp product is received, it will be inspected to ensure vendors are remaining compliant. We have added a note to our inventory control system (smart scanners), to ensure the QR code is located on all items containing hemp. Items that do not bear the QR code will be returned to the vendor at their expense.






Distribution Program/Guidelines: 

We have retained Kight Law Office PC (KLO) to represent us. KLO represents businesses in the hemp/CBD industry across the United States. Under the Agricultural Improvement Act of 2018 "hemp", which includes its extracts, cannabinoids, and derivatives, is removed from the Controlled Substances Act. The federal government has the sole authority to regulate hemp; however, a state may regulate hemp if it proposes a plan to do so that is approved by the USDA. As of this time, no state plans have been approved. Despite this, some state regulatory authorities do regulate hemp. We frequently consult with our attorneys to stay abreast of state regulatory changes and the ways in which state and federal regulations coordinate with each other. 



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