Arizona DHS Suspends Dispensary for Selling Products with Expired COAs and Undisclosed Lab Switching (May 2025)

Arizona Testing Certificate Requirements

Under A.R.S. § 36-2854 and DHS Rule R9-17-319, all cannabis products sold in Arizona must be accompanied by a valid Certificate of Analysis (COA) from a licensed testing laboratory. COAs expire 365 days from the date of sample collection. Products with expired COAs must be removed from sale and retested before they may be sold.

Inspection Findings

DHS compliance officers conducting a surprise inspection on May 7, 2025 identified:

1. 22 product lots with COA issuance dates between April 2024 and May 2024 — all expired at the time of sale
2. Evidence that 8 of these lots had been originally tested at Laboratory X but were shipped from Laboratory Y without new COAs — constituting unreported lab switching prohibited under R9-17-319(B)
3. Point-of-sale records indicating these products had been sold to 340 registered patients over a 90-day period

Suspension Order

DHS issued a 14-day suspension effective May 9, 2025. During the suspension period, the dispensary is prohibited from:

• Selling or transferring any cannabis product
• Accepting deliveries from licensed producers or manufacturers

The dispensary may apply for reinstatement after demonstrating that all affected products have been quarantined, retested, and — if they fail current standards — destroyed.

Patient Safety Notification

DHS directed the dispensary to notify all 340 affected patients via its electronic communication system within 72 hours of the suspension order.

Compliance Guidance

Arizona dispensaries should implement a COA expiration tracking system as part of their inventory management protocol. COA refresh orders should be placed no later than 330 days from initial test date to allow for re-testing turnaround time.