From Dec. 11, the U.S. hemp rule counts total THC, including THCA, and caps...

https://scarlettsimpressiveword.lumenforgex.com/posts/why-would-hemp-flower-pass-before-but-fail-now

From Dec. 11, the U.S. hemp rule counts total THC, including THCA, and caps each container at 0.4 mg. That may shift demand away from intoxicating hemp products. THC-free inputs with batch lab reports are the clearest compliance path.