The December 11 US hemp rule change counts total THC, including THCA, and caps...

https://zandersexcellentdigests.yousher.com/what-does-thc-free-actually-mean-for-cbd-isolate-suppliers

The December 11 US hemp rule change counts total THC, including THCA, and caps total THC at 0.4 mg per container. That puts many intoxicating hemp products outside the new limit and is likely to shift demand toward compliant, non-intoxicating products