Alabama's Hemp Label Law: The COA Link Runs Both Directions

Alabama's consumable hemp chapter contains a requirement we have not seen anywhere else: the scannable code is required on the label and on the certificate of analysis, pointing at each other. Most brands find the second half out after the labels are printed, because labs do not add it by default.

Direction one: label to certificate

§ 28-12-25, Code of Alabama 1975: "Each container of a consumable hemp product must be labeled to include, at a minimum:"

Direction two: certificate back to label

§ 28-12-22(b) sets out what the certificate of analysis itself must contain — batch or lot number, date issued, method of analysis, product name, cannabinoid profile, and, at (b)(5):

"A scannable barcode or quick response code linked to the label on the consumable hemp product container"

So the certificate points at the label, and the label points at the certificate. That is a genuinely unusual construction, and it is the half brands miss, because it is a requirement that lands on the lab's document rather than on the packaging designer's artwork.

Worth asking your lab about directly. A certificate issued in a standard template will not carry a code pointing back at your label unless someone asks for it. If your certificates are re-issued or corrected during the year, each new document has to carry that code too, and has to sit at the address the already-printed label points to.

When it applies

§ 28-12-20(a): "On and after January 1, 2026, no consumable hemp product may be distributed into or within the state, nor offered for sale or sold at retail within the state unless the product: (1) Has a corresponding certificate of analysis described in Section 28-12-22 issued by an independent testing laboratory that tests the batch from which the product was produced; (2) Is in the original sealed container as packaged by the producer and meets the packaging restrictions in Section 28-12-24; (3) Meets the serving size and product content requirements … and (4) Meets the labeling requirements described in Section 28-12-25."

All of this arrived with HB445 of the 2025 Regular Session (Rep. Whitt), which added Chapter 12 to Title 28 and put the Alcoholic Beverage Control Board in charge. Section 3 of the act made it effective July 1, 2025; the distribution, retail-sale and retailer-licensing gates apply on and after January 1, 2026. Both dates have passed.

Source: HB445, enrolled text, Alabama Legislature 2025 Regular Session (PDF) · program page: Alabama ABC Board — Consumable Hemp Products.

What we are not claiming

Alabama's chapter contains no "three steps or fewer" standard — that is Texas and Florida, and it would be wrong to import it here. We also have not verified how the ABC Board is enforcing the § 28-12-22(b)(5) reverse link in practice, or whether it is being read as a duty on the laboratory, the processor, or both. The statutory text is quoted above so you can take it to the Board or to counsel as written.

The practical failure mode

The label side is a one-time job. The certificate side is not. Every re-issued report, retest and lab change produces a new document that has to carry a code pointing at the right label and has to live where the already-printed label's code points. If certificates are loose PDFs in a Drive folder or a media library, that pairing drifts the first time anything is corrected — and the labels are already in the field, so there is no cheap fix.

The structural answer is a permanent page per batch that owns the pairing: the batch number, the current certificate, and one address that does not change when the document behind it does.

One permanent page that owns the batch-to-certificate pairing

BatchLink gives each batch a permanent URL plus a printable QR code, with the batch number displayed beside the report. Replace a corrected certificate in place, and every code already printed keeps working. Free for your first two batches, no card.

Create a free batch page

Related reading

Sources reviewed August 2026, against the primary sources linked above rather than a secondary summary. Rules in this space change — confirm the current text with the agency before a print run. This is general information, not legal advice.