Cannabis Testing by State-New Hampshire
COA Requirement:
Required.
Alternative Treatment Centers (ATCs) are required to test cannabis and cannabis-infused products (CIP) before dispensing. While the term "Certificate of Analysis (COA)" is not explicitly used, the rules mandate documented lab testing for contaminants and potency, with recordkeeping and reporting to the Department of Health and Human Services (DHHS).
Cannabinoid Testing Requirements:
The required cannabinoid profile includes testing for:
- THC
- THCA
- THCV
- CBD
- CBDA
- CBDV
- CBC
- CBG
- CBN
These results must be expressed in percent by weight or volume.
Terpene Testing Requirements:
Not required.
Terpene analysis is not mentioned in the ATC testing rules or labeling requirements.
Contaminants Tested For:
Testing is outlined in He-C 402.16–402.18.
a. Microbiological Testing: Required for all batches, including:
- Total yeast and mold
- Salmonella spp.
- Escherichia coli (E. coli)
Products that fail microbial testing may not be dispensed.
b. Mycotoxins: Required. Must test for:
- Aflatoxins (B1, B2, G1, G2)
- Ochratoxin A
These must be absent or below action thresholds to pass testing.
c. Pesticides: Required.
- Cannabis must be tested for chemical residues, including pesticides and solvents.
- However, specific compound lists (e.g., daminozide, paclobutrazol) are not published in He-C 402.
- Only general standards are referenced (e.g., validated method, detection limit, absence/presence).
d. Heavy Metals: Required. Testing for arsenic, lead, cadmium, mercury is mandated for all finished products.
e. Filth / Foreign Materials: Required. Must screen for:
- Dirt, hair, insects, mold, feces, etc.
- Visual inspections are performed as part of batch review.
Contaminants Not Required (But of Concern):
- No terpene testing
- No chromium, nickel, selenium, or barium metal testing
- No required testing for Listeria monocytogenes, Shigella spp., or Clostridium botulinum
- Specific banned pesticide list is not published, leaving a regulatory gray area
Risk Level:
Medium Concern:
While core testing is solid (pesticides, microbes, mycotoxins, heavy metals), the lack of explicit banned chemical lists and terpene/expanded metal screening is a gap.
Moisture and Water Activity:
Moisture content testing is implied via microbial and mold testing protocols.
Water activity (aw) thresholds (e.g., ≤0.65) are not explicitly defined, unlike other states.
State Cannabis Regulatory Agency:
New Hampshire Department of Health and Human Services: Therapeutic Cannabis Program
Website: https://www.dhhs.nh.gov
Phone: (603) 271-9333
Address: 29 Hazen Drive, Concord, NH 03301
Email: tcp@dhhs.nh.gov
References:
New Hampshire Department of Health and Human Services. (2023). He-C 402: Therapeutic Cannabis Program Regulations