On June 23, 2025, an important milestone was reached when the full Appropriations Committee approved the FY26 Agriculture, Rural Development, Food, and Drug Administration spending bill, which outlines federal funding priorities and sets the stage for potential regulatory updates affecting agriculture, including hemp. The bill could introduce major changes in the hemp industry, particularly influencing how hemp is cultivated, processed, and tested in laboratories nationwide.
Congress did not pass a new five-year Farm Bill in 2024, instead it extended the 2018 Farm Bill through the American Relief Act, 2025, signed on December 21, 2024. This extension maintains stability in hemp programs and regulatory oversight through September 30, 2025, setting a firm deadline for Congress to pass a new Farm Bill.
For hemp testing laboratories, the pending 2024 Farm Bill could fundamentally reshape THC testing standards, regulatory oversight, and compliance requirements across the industry.
Understanding the Farm Bill and Its Impact on Hemp
Farm Bills are comprehensive pieces of legislation passed every five years that govern federal agricultural policy, including funding for farming programs, nutrition assistance, rural development, and crop regulation. Appropriations within these bills provide the financial authority to implement these programs, ensuring stability and continuity across the agricultural sector.
The 2024 Farm Bill, currently represented by H.R. 8467, is the latest iteration under consideration. On June 23, 2025, the full Appropriations Committee approved the FY26 spending bill. Current Status: The bill must still pass the full House and Senate and be signed by the President before it can become law. If enacted, it could introduce major changes in the hemp industry, particularly influencing how hemp is tested and regulated.
How Did We Get Here?
The 2018 Farm Bill legalized hemp by defining it as cannabis containing under 0.3% delta-9 THC on a dry weight basis, the primary psychoactive compound. This legislation also created the U.S. Domestic Hemp Production Program to provide regulatory oversight for hemp cultivation across the country. However, the 0.3% delta-9 THC limit inadvertently created a loophole, allowing psychoactive cannabinoids such as delta-8 THC and delta 10-THC to flourish while technically complying with the federal definition.
This oversight led to rapid growth of the hemp-derived cannabinoid market, which achieved a value of close to $2.8 billion in 2023, with delta-8 THC alone accounting for $1.2 billion. The Mary Miller Amendment (H.R. 8467) aims to close this loophole by redefining the 0.3% THC limit, a move that could significantly reshape the industry.
Key Changes For Hemp Testing in the 2024 Farm Bill
The House Agriculture Committee passed the 2024 Farm Bill on May 23, 2024. This bill introduces new statutory definitions and updates existing language regarding hemp cultivation and hemp-derived products, while also modifying how the USDA regulates hemp. These changes, (Sections 10001–10006 of H.R. 8467), could have major implications for hemp testing laboratories and the broader industry.
Major Changes:
- Redefinition of “Hemp”
- Moves from the 2018 Farm Bill standard of delta-9 THC ≤ 0.3% on a dry weight basis to a “total THC” standard, which includes delta-9 THC plus other tetrahydrocannabinol equivalents (e.g., THCA, delta-8 THC derived from CBD).
- Proposals on Intoxicating Hemp Cannabinoids
- Amendments aim to restrict or ban hemp products containing intoxicating cannabinoids, driven by concerns about unregulated Δ⁸ markets and products marketed to minors.
- Laboratory Accreditation and DEA Registration
- Labs testing hemp are required to register with the DEA and meet USDA-accredited quality standards to ensure accurate and compliant THC testing.
- USDA Enforcement Delay for DEA-Registered Labs
- The USDA Agricultural Marketing Service has delayed enforcement of the DEA-registration requirement until December 31, 2025, giving laboratories and states additional time to comply while the regulatory and legislative picture evolves.
- Reporting & Certificates
- Labs will be required to submit certificates of analysis for hemp disposed of under industrial hemp programs.
- Relaxed Regulatory Requirements for Industrial Hemp Producers
- Producers designated as “industrial hemp only” may benefit from reduced testing requirements, relaxed background checks, and elimination of the 10-year ineligibility period following a felony conviction related to controlled substances.
Note:
- Final statutory language depends on negotiations in Congress and whether provisions survive a Senate conference.
- Reports from the Congressional Research Service and multiple law firms note potential litigation and state/federal clashes if hemp is redefined.
Implications for Hemp Testing Labs
The 2024 Farm Bill introduces several changes that could significantly impact hemp testing laboratories. The shift to a “total THC” testing standard requires labs to quantify delta-9 THC along with other tetrahydrocannabinol equivalents, including THCA and delta-8 THC derived from CBD. Labs must also consider the risk of decarboxylation during sample handling and analysis, which can artificially increase measured THC levels and affect compliance results.
Stricter reporting requirements will come into play, including the need to submit certificates of analysis for disposed hemp and to maintain detailed documentation of all test results. DEA registration will become mandatory for labs handling controlled cannabinoids, adding both compliance obligations and potential liability.
Non-compliance carries serious implications, including regulatory penalties, reputational damage, and potential legal liability if non-compliant hemp enters the market. Combined with the risk of “lab shopping,” where producers may seek labs with less stringent procedures, these changes underscore the importance of robust SOPs, accurate record-keeping, and adherence to federal standards to maintain credibility and regulatory compliance.
Key Steps for Laboratories to Achieve Quality and Compliance in Hemp Testing
New requirements for hemp testing laboratories will introduce significant regulatory changes under the U.S. Domestic Hemp Production Program. Starting December 31, 2025, when the bill becomes a law, any laboratory performing THC testing on hemp will be required to obtain DEA registration that allows the lab to legally handle controlled substances; however DEA may further extend this deadline due to a dearth of DEA registered laboratories. For information on registering a hemp testing laboratory with the DEA, please visit the DEA Diversion Control Division website.
Laboratories will submit all hemp test results through the USDA’s Hemp eManagement Platform (HeMP). To use HeMP, laboratories must have a HeMP account. If you have not yet created an account, please follow the USDA instructions to create or access a HeMP account.
To ensure the reliability, accuracy, and regulatory compliance of hemp testing, laboratories should follow these key steps:
- Initiate DEA Registration Process
- Access the DEA Diversion Control Division’s website to begin the registration process.
- Complete the necessary forms and submit all required documentation as outlined by the DEA.
- Obtain ISO/IEC 17025 Accreditation (Optional but Recommended)
- While not mandatory, ISO/IEC 17025 accreditation demonstrates laboratory competence and reliability in testing.
- Accreditation can improve confidence in THC testing results and support consistency and credibility in the hemp industry.
- Laboratory Quality Assurance Protocols
Laboratories must implement robust quality assurance protocols to ensure valid and reliable test results. These include:
- Standard Operating Procedures (SOPs): Develop and maintain SOPs specifically to ensure accurate testing of total THC, covering sample preparation, analysis, and reporting. SOPs should comply with AOAC International Standard Method Performance Requirements (SMPR) for cannabinoid quantification.
- Training and Competency: Ensure all personnel are adequately trained and demonstrate competency in their roles.
- Equipment Calibration and Maintenance: Regularly calibrate and maintain equipment to ensure accurate measurements.
- Internal Audits: Conduct internal audits to assess compliance with protocols and identify areas for improvement.
- Measurement of Uncertainty (MU)
- Calculate MU: Determine the measurement of uncertainty for each test result to characterize the dispersion of values that could reasonably be attributed to the quantity measured.
- Document MU: Maintain records of MU calculations and include them in test reports.
- Develop and Implement Chain of Custody Protocols
- Establish and document chain of custody procedures to maintain the integrity of samples from collection through testing and reporting.
- Ensures traceability and prevents tampering or contamination.
- Utilize the Hemp eManagement Platform (HeMP)
- Register for and use the USDA Hemp eManagement Platform (HeMP) to submit THC test results.
- Ensure that all required information—such as producer details, sample identification, lot number, and test results—is accurately submitted.
- Report Test Results to USDA
- Submit all THC test results through HeMP.
- Only formal test results should be reported; interim or informal results are not accepted.
- Maintain records of all submitted results in accordance with USDA requirements.
- Disposal of Non-Compliant Samples
- Follow all federal, state, and local regulations regarding the disposal of controlled substances.
- Document the disposal process, including dates, methods, and personnel involved.
- Compliance with USDA Guidelines
- Stay informed of USDA regulations and hemp testing guidelines.
- Implement changes promptly to ensure ongoing compliance with updated regulations.
Leveraging a Modern Hemp LIMS for Quality and Compliance
The 2024 Farm Bill introduces new quality and regulatory requirements that hemp testing laboratories need to comply with. Implementing a Laboratory Information Management System (LIMS) tailored for hemp testing can help laboratories prepare in advance for the proposed changes.
What Should You Look for in a Modern Hemp LIMS?:
- Automated Workflows: Ensures laboratories follow SOPs consistently, reducing errors and maintaining compliance with updated THC testing protocols.
- Chain of Custody Management: Tracks each sample from receipt to disposal, supporting the secure handling of controlled substances as required under DEA regulations.
- Regulatory Compliance Support: Facilitates accurate reporting of THC results to the USDA via HeMP, and helps meet ISO/IEC 17025:2017 and other auditing standards for quality assurance.
- Real-Time Data Access: Provides immediate visibility into testing results and laboratory operations, allowing labs to respond quickly to regulatory changes and maintain timely reporting.
By leveraging a modern hemp LIMS, hemp testing laboratories can streamline operations, ensure accurate reporting, and stay fully compliant with the new requirements established by the 2024 Farm Bill.
Conclusion
The 2024 Farm Bill represents a pivotal moment for the hemp industry, introducing regulatory changes that will impact how laboratories test, report, and manage hemp products. By understanding these updates, implementing robust quality assurance protocols, leveraging tools like a modern hemp LIMS, and ensuring DEA registration and proper reporting through HeMP, laboratories can maintain compliance and uphold the integrity of hemp testing. Staying proactive will be key for labs to navigate these changes and continue supporting a safe, reliable, and transparent hemp market.