New Mexico Cannabis Testing Overview
COA Requirement:
Required.
Each batch of usable cannabis or cannabis-derived product must be tested by a DOH-approved laboratory before it can be released for sale, transfer, or further processing. Although the term “Certificate of Analysis” (COA) is not used verbatim, the rule requires testing records be retained and used to verify regulatory compliance.
Cannabinoid Testing Requirements:
Required. All batches must be tested for the following:
- THC
- THCA
- CBD
- CBDA
- Calculated Total THC and CBD (via standard decarboxylation formulas)
Optional analytes include:
- CBN
- CBG
- CBGA
- CBC
- THCV
- CBDV (Recommended for strain characterization)
Terpene Testing Requirements:
Not required.
New Mexico regulations do not mandate terpene testing or reporting.
Contaminants Tested For:
a. Microbiological Contaminants: Testing required for:
- Total Aerobic Microbial Count
- Total Yeast and Mold Count
- Total Coliforms
- Bile-tolerant Gram-negative Bacteria
- Salmonella spp. and E. coli (must be absent in 10 g)
b. Mycotoxins: Required:
- Aflatoxins B1, B2, G1, G2
- Ochratoxin A
Total combined concentration must be <20 µg/kg (20 ppb)
c. Heavy Metals: Required. Must test for:
- Arsenic (≤2.0 ppm)
- Cadmium (≤0.8 ppm)
- Lead (≤1.2 ppm)
- Mercury (≤0.4 ppm)
d. Pesticides: Required. Required analytes include:
- Abamectin
- Azoxystrobin
- Bifenazate
- Myclobutanil
- Permethrins
- Spinosad
- Tebuconazole
Each with strict action limits (e.g., 100–500 µg/kg or ppb)
e. Foreign Materials / Filth: Required. Visual inspections and video-documented destruction procedures are mandatory for failed batches
Contaminants Not Required (But of Concern):
New Mexico has a robust panel, but does not explicitly require:
- Listeria monocytogenes
- Shigella spp.
- Chromium or Nickel (not listed among heavy metals)
- Terpenes
- Moisture activity (aw) testing, although moisture content is tested and must be <15% for flower
Risk Level:
Moderate Concern: Comprehensive coverage of core hazards, but lacks testing for water activity, terpenes, and certain pathogens common in other states.
Moisture and Water Activity:
Moisture content testing required (≤15%).
Water activity (aw) not explicitly required
State Cannabis Regulatory Agency:
New Mexico Department of Health: Medical Cannabis Program
Website: https://www.nmhealth.org/about/mcp
Email: medical.cannabis@state.nm.us
Phone: (505) 827-2321
Address: 5301 Central Ave NE, Suite 204, Albuquerque, NM 87108
References:
New Mexico Department of Health, Medical Cannabis Program. (June 23, 2020). Title 7, Chapter 34, Part 4 New Mexico Licensing Requirements for Producers, Couriers, Manufacturers and Laboratories.*
New Mexico Regulation and Licensing Department, Cannabis Control Division. (March 9, 2022). Title 16, Chapter 8, Part 2. Emergency amendment to 16.8.2 NMAC amending Section 26, effective 3/09/2022.
New Mexico Department of Health. (2024). 7.34.4 NMAC: Licensing and Testing Rules for Cannabis. .