Here's a detailed breakdown. The parts explaining DSHS and SB2024 Compliance are at the bottom of the page.
***READ THE SECOND PAGE OF COA***
This product is a mechanically dispensed inhaler (pMDI) formulated to deliver less than 0.03% Delta-9 THC per actuation.
- Total Δ9-THC Content: ~80.22 mg at a rate of 5.73 mg/ gram
- Total CBD Content: ~147 mg at a rate of 10.5 mg/ gram
- CBD : THC Ratio: ~2:1
- Total Sprays per Unit: 150
- Product Size: 14 grams
- Serving Size: 0.093 grams (i.e., 93mg per 1 spray)
Total Servings:
• 14g ÷ 0.093g/spray = 150 sprays
THC Per Spray:
• 5.73 mg THC per gram x 0.093 g = ~0.533mg THC per spray
CBD Per Spray:
• 10.5 mg/g x 0.093 g = ~0.976 mg CBD per spray
Dry Weight % Per Spray:
This is the weight-based percentage of THC in each dose:
- 0.533 mg THC ÷ 93 mg = ~0.573% THC in infused portion
- But considering the total canister includes propellant air (50% weight), actual dry weight % per spray
- =0.2865% THC ✅
You’re seeing that 0.573% number, and that looks like a high percentage when you compare it to the spray’s weight — which might make it seem like it’s over the legal limit of 0.3% THC by dry weight.
The Reality:
Each spray gives you 0.533mg of THC. That’s the actual dose you’re getting — and it doesn’t change. ✅
But when labs and the law talk about THC % by weight, they’re not just looking at the active formula. They include the whole contents of the can — including the air (propellant) that helps spray it out.
In our case, the formula is mixed 50/50 with propellant. So if a spray weighs 93 mg total, only half of that is actual liquid — the rest is just pressurized propellant.
So How Does That Affect Testing?
- Without the air: 0.533 mg ÷ 93 mg = ~0.573% THC
❌ That’s technically over the 0.3% limit. - But with the air factored in, it’s 0.533 mg ÷ 186 mg = ~0.2865% THC
✅ That’s under the legal limit.
Bottom Line:
- You’re getting 0.533 mg THC per spray.
- The product is legally compliant, because the air weight dilutes the THC % on paper.
- This is how inhalers are meant to be tested under federal hemp guidelines.
Each spray is designed to contain a metered amount of active hemp-derived cannabinoids, including CBD and trace Delta-9 THC.
The formulation and dosage are compliant with the 2018 Agricultural Improvement
Act (Farm Bill), which requires Delta-9 Tetrahydrocannabinol (D9-THC)
concentrations to remain below 0.3% on a dry weight basis.
Verified by third-party laboratory testing (Kaycha Labs, COA dated 04/22/2025), this product contains a total D9-THC concentration of 0.573% by infused weight, with formulation controls limiting each spray's delivery to under 0.03% D9-THC by dry weight.
Lab: Kaycha Labs
Sample ID: DE50418009-001
Test Date: April 22, 2025
Product: Inhaler
Matrix: Infused
Serving Size: 0.093 grams (i.e., 93mg per spray)
Total Product Mass: 14g
Total THC (Δ9-THC):
- Percentage (as tested): 0.5730%
- THC Mass (mg/g): 5.730 mg THC per gram of infused formula
Total Cannabinoids Percentage: 1.8650%
Looking for a smoke-free, vapor-free way to support your wellness?
Our mist inhaler offers discreet, precision dosing of federally compliant hemp-derived CBD and Delta-9 THC, all without batteries, coils, or heat.
Unlike vaporizers or e-cigarettes, our device uses a pressurized pump system to deliver a fine mist — no clouds, no combustion, no nonsense.
This product is not intended to diagnose, treat, cure, or prevent any disease.
This product has not been evaluated by the Food and Drug Administration.
This device is not an electronic cigarette and is not intended for use as a smoking cessation tool.
⚠️ This product is not an e-cigarette or vaporizer.
No heat. No electronics. No battery. Not a smoking alternative.
Metered mist delivery system – similar to medical-grade inhalers.
Regarding SB2024: Going over SB2024, it says ""E-cigarette" means:
(i) an electronic cigarette or any other
device that simulates smoking by using a mechanical heating element, battery, or electronic circuit to deliver nicotine or other substances to the individual inhaling from the device; or
(ii) a consumable liquid solution or other
material aerosolized or vaporized during the use of an electronic cigarette or other device described by this subdivision..."
That part towards the end where it says "..During the use of an electronic cigarette or other device described..." is an important distinction made by our lawmakers. It's the specific type of devices they listed that are banned, not the act of inhaling Delta-9 itself. And when you go down through the list of the devices they included, none of them apply to these inhalers.
This product does NOT contain THC-A.
✅DSHS Rule Compliance
This inhaler contains ZERO THC-A. So the new total THC formula — THCA + Delta-9 — doesn't change its calculation at all. The inhaler was never THCA-based to begin with.
§300.101(38) — Official DSHS Definition of "Smoking": "Burning or igniting a substance and inhaling the resultant smoke or heating a substance and inhaling the resulting vapor or aerosol."
DSHS has deliberately written the broadest possible definition of "smoking." The word "or" is doing enormous work there. It doesn't just mean combustion — it explicitly includes heating a substance and inhaling the resulting vapor or aerosol. This was clearly written to capture vapes and e-cigarettes that don't technically "burn" anything.
HOWEVER -
The inhaler uses no heat whatsoever. The propellant is pressurized gas — HFA 134a. Nothing is heated. Nothing is burned. The mist is produced entirely by mechanical pressure, not thermal energy. The formula temperature doesn't change at any point during actuation.
So under the plain language of this definition, the inhaler falls into neither category:
❌ Not burning or igniting anything
❌ Not heating anything
The aerosol is produced without heat — which is precisely why pharmaceutical pMDIs exist as a category distinct from vaporizers in medical literature.
The definition says "heating a substance and inhaling the resulting vapor or aerosol." The word "resulting" ties the aerosol to the heating. If there's no heating, there's no "resulting" aerosol under this definition — the aerosol just exists because of pressure. This product doesn't meet the statutory definition of smoking because no heat is involved at any stage.
