Starting December 11, the US hemp rule counts total THC, including THCA, when...
https://dallassinterestingwords.cloudhinter.com/posts/if-i-sell-cbd-tinctures-how-do-i-stay-under-the-0.4-mg-thc-cap
Starting December 11, the US hemp rule counts total THC, including THCA, when determining whether a product qualifies as hemp. It also sets a cap of 0.4 mg of THC per container