The December 11 US hemp rule change counts total THC, including THCA, and caps...
https://evelynsnewblogs.scriblorax.com/posts/is-there-any-safe-way-to-keep-exporting-hemp-flower-to-the-us
The December 11 US hemp rule change counts total THC, including THCA, and caps hemp-derived THC at 0.4 mg per container. That narrows the market for intoxicating products and shifts demand toward compliant, non-intoxicating ingredients