Missouri's mandatory testing rules (19 CSR 100-1.110) create two main types of mandatory testing for marijuana products: harvest lot testing and process lot testing.

In many cases, marijuana products may be sampled in bulk, which allows samples to be collected before the product is packaged¹.

Harvest lot testing

Marijuana product that is mandatory tested as a harvest lot² includes bud/flower, shake/trim and ground material. This is product that has not been made into another marijuana product. For these products, the bulk sampling is only allowed after all processing, such as sorting and grinding, of the harvest lot is complete.

Once the product passes mandatory testing, the marijuana product may be packaged into any retail size (for example, 3.5-gram, 7-gram, 14-gram, etc.).

Process lot testing

Marijuana product that is mandatory tested as a process lot³ includes marijuana concentrate, extract, distillates, isolates, vape cartridges, prerolls, infused prerolls and infused products. Products sold in a method of administration, such as vape cartridges, are not allowed to be bulk tested. These types of products must be in their method of administration prior to mandatory testing.

Infused products that are allowed to be sampled in bulk must be divided into units for sale after all processing is complete, before mandatory testing. The number of units for sale must be recorded on the chain of custody so the testing licensee can determine the correct sample size and accurate dose. Failure to identify the number of units for sale before testing can result in:

• The Certificate of Analysis (COA) does not match the final product.
• Incorrect chain of custody information.
• Unintentional manipulation of testing results.

Once the number of units for sale is established, the product can be mandatory tested. After mandatory testing is complete, the product may be packaged appropriately based on the predetermined unit counts.

Additional considerations and important reminders

• Recalls are based on test tag number. Using one set of mandatory testing results across multiple products can increase the number of items that must be recalled if something goes wrong.
• Both testing licensees and licensees producing final marijuana product should regularly review and update their standard operating procedures to ensure compliance with mandatory testing requirements.

For questions, contact your compliance officer or email:  CannabisCompliance@health.mo.gov

1. 19 CSR 100-1.110(5)(B)4
2. 19 CSR 100-1.010(36)
3. 19 CSR 100-1.010(81)