September 28, 2026
Governor Gavin Newsom signed AB 1965 on September 27, according to his office's legislative update. The bill lets the Department of Cannabis Control buy product off a dispensary shelf and send it to a lab. It also requires every retailer to hand over a product's certificate of analysis when a customer asks for one. The bill, by Assemblymember LaShae Sharp-Collins of San Diego, passed both chambers without a single no vote.
California's new cannabis testing law takes effect January 1, 2027. The retailer requirements are short. The bigger changes are for the brands, distributors, and labs whose test results the state can now check against the product actually on sale.
The retail provisions are two new subsections of Business and Professions Code §26070, per the enrolled text:
Retailers already have the COAs. The DCC said so in its statement of reasons for a related rulemaking: "Retail licensees have access to COAs in the CCTT system but are not required by law to provide COAs to retail customers, and while some retailers already voluntarily make COAs available to their customers, many do not." The new law makes producing a COA part of every sale for any customer who asks.
AB 1965 states that all cannabis and cannabis products are subject to testing or retesting and directs the DCC to set criteria for which batches get retested. It also changes what labs can do on their own:
Blind proficiency testing means the state sends a lab a sample with a known potency and checks whether the lab reports the right number. Round-robin testing sends the same sample to several labs and compares their results. Both give the state a direct way to spot labs whose numbers run high.
The DCC has a name for it. In the same rulemaking record, the department describes distributors sending one batch to several labs, after which "the distributor will select their preferred test results and have that laboratory accept the manifest and upload the results in the CCTT system." That practice is "lab shopping," and the department says it undermines confidence in lab results.
AB 1965 gives the state a way to catch it after the fact. A distributor can still choose which lab tests a batch. It can no longer count on the product going unchecked once it reaches a shelf.
AB 1965 was not the only testing change this week. The DCC's revised pesticide action levels take effect October 1, changing the thresholds that decide whether a batch passes or fails.
Newsom also signed AB 2250 by Assemblymember Cecilia Aguiar-Curry on the same day. It widens track-and-trace to cover cultivation through delivery, bars anyone in the business of selling cigarettes or tobacco from any sale of cannabis, and extends seizure authority to cannabis held at unlicensed premises. The Marijuana Herald reports it also removes high-purity CBN isolate from the definition of cannabis concentrate starting in 2028.
Still pending is the DCC's track-and-trace rulemaking, whose comment period closed July 20. It would put the COA-on-request requirement into regulation as §15404.1 and require retailers to enter nine tax fields on each sale in the state system. The DCC cites California Department of Tax and Fee Administration findings that retailers' reported gross receipts sometimes differ by as much as 30 percent from the sales recorded in track-and-trace.
POS, menu, and e-commerce vendors. "Retailers need point-of-sale or back-office systems capable of producing a COA on demand without delay," Harris Sliwoski wrote of the bill. A budtender who has to log into a separate system to find a PDF slows down the checkout line. Linking a COA to each SKU at the register is an easy feature to sell before January.
Brands and distributors. Off-the-shelf testing exposes any gap between the tested batch and the product on the shelf. Harris Sliwoski singles out edible makers, where formulation changes after initial testing have "historically created gaps." A failed shelf test comes back to the brand and the distributor, even though the dispensary is where the sample was bought.
Labs. Proficiency and round-robin programs make a lab's accuracy measurable, and a lab that reports consistently high numbers will have a harder time explaining them.
This is a summary of the enrolled bill, not legal advice. Licensees should check the final chaptered text and any DCC implementing rules with counsel.
When does AB 1965 take effect? January 1, 2027. It was signed September 27, 2026, and is not an urgency bill.
Do California dispensaries have to show you a certificate of analysis? Starting in 2027, yes, on request. The requirement covers any licensee authorized to sell cannabis at retail, including delivery services.
What is off-the-shelf cannabis testing? The state obtains product that is already on sale at a retailer and sends it to a lab. The result can be compared with the batch's original compliance test.
What is lab shopping? The DCC's term for a distributor testing one batch at several labs and keeping the most favorable result, usually the highest potency.
California's retailers will have new compliance steps in January, and their vendors will be making sales calls about them this fall. See verified, owner-level contacts for licensed California dispensaries, refreshed weekly. Free preview at holdenleads.com.
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