Okay, so hear me out.

I've gone off quite a bit in the past about how brands are banking on you not checking COAs. This one's a bit different though, because while that's all technically legal albeit shady and untruthful towards the customer - this situation could actually result in real consequences for the dispensaries that are blatantly advertising in a non-compliant way.

You get an email. Subject line says something like "BOGO Everything" or "40% OFF ALL CONCENTRATES." Big bold text. Looks exciting. You get in the car.

Then you get to the store and half the stuff you wanted is excluded. There's a fine print disclaimer buried under the giant graphic that lists out five to eight brands that don't qualify. Not obscure brands either -we're talking major in-state names, national brands, and sometimes entire product categories like pre-rolls and accessories as a whole. On "ALL PRODUCTS" sales.

I've been collecting these emails for a while now and I want to show you what this actually looks like at scale, because I think a lot of us have just accepted it as part of the dispensary experience. We shouldn't.

Here's the pattern, just from one chain, documented across multiple months:

• "40% OFF ALL VAPES"
• "BOGO ALL FLOWER"
• "40% OFF ALL CONCENTRATES"
• "BOGO ENTIRE STORE"
• "ALL PRODUCTS 40% OFF"
• "Buy 2 Get 2 FREE ALL PRODUCTS"
• "2 for 1 BOGO ALL PRODUCTS"
• "ENTIRE STORE BOGO on 1000+ of your favorite products"
• "ALL PRODUCTS 45% OFF"

Every single one of those had an exclusion list attached. This is not an occasional oversight. This is a playbook. And there are three Arizona statutes that say it's a problem.

Why this matters legally

A.R.S. § 44-1522 -- Consumer Fraud Act

The actual text:

> "The act, use or employment by any person of any deception, deceptive or unfair act or practice, fraud, false pretense, false promise, misrepresentation, or concealment, suppression or omission of any material fact with intent that others rely on such concealment, suppression or omission, in connection with the sale or advertisement of any merchandise whether or not any person has in fact been misled, deceived or damaged thereby, is declared to be an unlawful practice."

Notice that last clause: "whether or not any person has in fact been misled, deceived or damaged." Nobody has to prove they were hurt. The practice itself is the violation. This is a big difference from a lot of states where damages must be proven in order to take action regarding false or misleading marketing.

A.R.S. § 13-2203 -- False Advertising

The actual text:

> "A person commits false advertising if, in connection with the promotion of the sale of property or services, such person recklessly causes to be made or makes a false or misleading statement in any advertisement."

> "False advertising is a class 1 misdemeanor."

This one is criminal, not civil. And notice the word "recklessly" - not "intentionally." Sending the same misleading email format dozens of times removes any argument that it was accidental.

A.R.S. § 36-2859 -- Cannabis Advertising Restrictions

The actual text:

> "A marijuana establishment or nonprofit medical marijuana dispensary that violates advertising laws is subject to disciplinary action by the Arizona Department of Health Services."

> "In addition to any other penalty imposed by law, an individual or entity other than a marijuana establishment or nonprofit medical marijuana dispensary that advertises marijuana or marijuana products in violation of this section or otherwise violates this section shall pay a civil penalty of $20,000 per violation."

This is the one with teeth. A dispensary that violates advertising law answers to the agency that holds their license - $20,000 per violation, and DHS can take disciplinary action on top of that. Each individual email could arguably be a separate violation.

"But there's a disclaimer at the bottom" - Yeah, about that

This is the argument every dispensary's legal team would run if this ever got escalated, and it doesn't actually hold up if you reference our state statutes.

A.R.S. § 44-1522(C) explicitly tells Arizona courts to use Federal Trade Commission interpretations as a guide when construing the Consumer Fraud Act. That matters enormously, because the FTC has been clear on this for decades.

From the FTC's own Deception Policy Statement:

> "Written disclosures or fine print may be insufficient to correct a misleading representation, and pro forma statements or disclaimers may not cure otherwise deceptive messages or practices."

The FTC goes further in its guidance documents:

> "Advertisers cannot use fine print to contradict other statements in an ad or to clear up misimpressions the ad would otherwise leave. Accurate information in a footnote or text will likely not remedy a false headline because reasonable consumers may glance only at the headline."

And directly on point:

> "If a disclosure provides information that contradicts a material claim, the disclosure will not be sufficient to prevent the ad from being deceptive -- in that situation, the claim itself must be modified."

Because Arizona statute explicitly instructs courts to follow FTC doctrine, this isn't fringe legal theory - it's baked directly into how § 44-1522 is supposed to be applied.

"ALL VAPES 40% OFF ^((excludes these five major brands))" is not a disclosure. Under the framework Arizona law is required to follow, that contradiction doesn't get the advertiser off the hook - it is the violation.

What you can actually do about it

There are two places to report, and I'd encourage doing both:

Arizona Attorney General's Office -- File a consumer fraud complaint at azag.gov/complaints/consumer. This is where A.R.S. § 44-1522 and § 13-2203 complaints live. A pattern of complaints about a specific practice from a specific company is exactly what triggers investigations. (A.R.S. § 44-1531 notes that willful violations carry civil penalties of not less than $10,000 per violation.)

ADHS Marijuana Program -- File a complaint directly with the agency that licenses these dispensaries at azdhs.gov. This is your § 36-2859 hook. They have the authority to take disciplinary action specifically against dispensaries that violate advertising law, separate from and in addition to anything the AG does.

Screenshot your emails and document the headline claim and the exclusion list side by side. That contrast is your entire complaint in one image.

Here's a draft for both complaint destinations as well if you would like to use just be sure to fill in all of the placeholder spots:

For the Arizona Attorney General:

>I am filing a complaint against [DISPENSARY NAME] for a pattern of deceptive advertising in violation of A.R.S. § 44-1522 (Consumer Fraud Act) and A.R.S. § 13-2203 (False Advertising).

>This dispensary has repeatedly sent promotional emails advertising storewide sales using absolute language such as "ALL PRODUCTS," "ENTIRE STORE," and "BOGO ALL [CATEGORY]" while burying significant brand and category exclusions in fine print below the primary advertisement. The headline claims are materially inconsistent with the actual terms of the offer.

>Under A.R.S. § 44-1522, this conduct is an unlawful practice "whether or not any person has in fact been misled, deceived or damaged thereby." Under A.R.S. § 13-2203, recklessly making a false or misleading statement in an advertisement constitutes false advertising, a class 1 misdemeanor. A.R.S. § 44-1522(C) further instructs that courts use FTC interpretations as a guide, and FTC doctrine is explicit that fine print cannot cure a deceptive headline.

>I have attached screenshots documenting this pattern. I am requesting that your office investigate this practice and take appropriate enforcement action.

For ADHS:

>I am filing a complaint against [DISPENSARY NAME], license number [LICENSE NUMBER IF KNOWN], for advertising practices I believe violate A.R.S. § 36-2859 (Cannabis Advertising Restrictions).

>This dispensary has repeatedly sent promotional emails using absolute terms such as "ALL PRODUCTS," "ENTIRE STORE," and "BOGO ALL [CATEGORY]" to describe sales that in practice exclude significant brands and entire product categories. This pattern of advertising creates a materially false impression of the scope of the offer.

>Under A.R.S. § 36-2859, a marijuana establishment that violates advertising laws is subject to disciplinary action by the Arizona Department of Health Services. I am requesting that your office review the attached documentation and take appropriate action against this licensee.

This isn't just one chain

I'm using their emails because I have them and they're a clean paper trail, but this is an industry-wide habit. If you've gotten similar emails from other dispensaries, the process is exactly the same. The playbook of screaming "ALL" in a headline and whispering the exclusions is not unique to any one brand.

Statutes referenced: A.R.S. § 44-1522 (Consumer Fraud Act)

A.R.S. § 13-2203 (False Advertising)

A.R.S. § 36-2859 (Cannabis Advertising Restrictions)

A.R.S. § 44-1531 (Civil Penalties)

FTC Deception Policy Statement, 103 F.T.C. 174 (1984)

I'm heading to the Glendale CA area just north of downtown. Any flower over there that I should not miss out on? Appreciate solid suggestions!

Someone recommended Simply Mary in one of my recent threads and basically made the case that THCa is just unheated THC, so the site is legit. The chemistry is correct. But whether decarboxylation is real has nothing to do with whether a vendor is honest with you. So, I did what I usually do and went through their entire public COA library. The thing they control, the thing they choose to put in front of customers, and this is what I found.

FLOWER

More than a dozen flower products have either broken links that redirect to their homepage or no COA link at all. Banana Zkittlez, Sour Apple, Mochi, Strawnana, Do-Si-Do, Curelato, Pink Slushie, Z-Pie, Super Runtz, Rainbow Guava, and Lemon Cherry Gas are all sitting on the storefront with nothing behind them documentation-wise.

The document linked as the 818-OG COA is actually a Glitter Bomb COA from SC Labs. There is also a separate Glitter Bomb COA from Badger Labs elsewhere in the flower section. Two labs, two COAs, both for Glitter Bomb, and one was filed under a completely different product name.

Six flower strains including Blue Dream, Wedding Cake, Lemon Truffles, Glitter Bomb, Biscotti, and Green Apple Gas all share the identical Badger Labs project number and batch ID. What's being presented as a diverse selection of small-batch genetics is in several cases the same grow submission with different labels attached.

Outside of a small handful of exceptions, not one flower COA in their library includes a safety panel. No pesticides. No heavy metals. No microbiology. Potency only.

EDIBLES

Their entire edible section is backed exclusively by R&D documents. Every single edible COA from Encore Labs contains an explicit disclaimer on the face of the document stating it is not a California regulatory compliance certificate and is for R&D and quality assurance purposes only. These are research documents being presented as consumer product verification.

Their Pineapple gummy and Shirley Temple gummy link to the exact same file. Not similar documents. The identical URL. One document is being presented as proof for two separate products. Their generic named "Rosin Gummy" COA link redirects to the homepage just like the broken Flower links.

CONCENTRATES

The majority of concentrate COAs from Green Leaf Lab, Pinnacle Analytics, and FESA Labs carry the same kind of explicit R&D disclaimer as the edibles. These are not compliance certificates. They are informational documents that the labs themselves say should not be used as product verification.

Bums Breath appears twice in the concentrate catalog under different listings pointing to the same document and link.

Multiple concentrate products share batch IDs in ways that indicate single submissions being split across multiple SKUs. Tropaya and Papaya Juice don't just share a batch ID, they share the exact same extraction timestamp down to the minute. Neon Wreck and Island Panther share a batch. Whitethorn Rose and Ridgeline Rose share a batch. The boutique variety catalog is, in several cases, one batch with different names on the jar.

Then there's the Delta-8 problem. Delta-8-THC does not naturally occur in cannabis at meaningful levels. When it shows up in double digits it indicates either synthetic production or chemical conversion from CBD. Multiple products sold as premium THCa rosin show exactly that with zero disclosure: Moonbow, Trop Cherry, Watermelon Z, Modified Grape, GG X SD, Darryl Strawberry, and Grape Pie all show between 9% and 14% Delta-8. Several carry significant CBD content alongside it, which is consistent with a conversion process rather than natural extraction. None of it is labeled. None of it is disclosed. It sits in the rosin section next to everything else with no distinction.

By the numbers

Across their full catalog of flower, edibles, and concentrates, here's what the documentation actually looks like:

- 11+ products with broken COA links that redirect to the homepage

- 7+ products with no COA link whatsoever

- 100% of edible COAs are explicitly R&D-only non-compliance documents

- Majority of concentrate COAs carry the same R&D disclaimer

- 1 COA being used as documentation for 2 separate edible products

- 1 COA filed under the wrong product name entirely

- 6 flower strains sharing a single Badger Labs batch ID

- 4+ confirmed cases of one concentrate COA covering multiple SKUs, including two products sharing the exact same extraction timestamp down to the minute

- 7 concentrate products showing 9-14% Delta-8-THC with zero disclosure to consumers

- 0 cultivator information anywhere in the catalog

- 0 flower COAs with a complete safety panel outside of a small handful of exceptions

This is their public-facing documentation. The thing they maintain. The thing they point to when someone asks if they're legitimate.

So here's the actual question

This is everything that made it to paper. These are the documents they chose to publish, maintained at their own discretion, on their own storefront. Within that controlled, publicly visible record there are missing documents, duplicate documents, mislabeled documents, R&D paperwork passed off as compliance verification, shared batch IDs across multiple SKUs, and undisclosed cannabinoid profiles indicating synthetic or converted material being sold as natural THCa concentrate.

If this is what they let you see, what does the part you can't see look like?

Look. I'm not here to tell you what to buy. You're an adult and that's your call. But if you've agreed with anything I've written in the past about brand accountability, whether that's been about COA transparency, mislabeled products, or companies that hide what's actually in what you're smoking, then I genuinely hope you can see this for what it is. The loophole being legal doesn't make the dishonesty acceptable. The standard I hold licensed Arizona brands to doesn't disappear because a vendor is operating outside of a regulated market. If anything it should be higher, because there's nobody else checking.

THCa converting to THC when heated is a chemistry fact. It says nothing about whether the person selling it to you is being straight with you. This documentation says quite a bit about that, and none of it is reassuring.

I’m guessing they just give a preroll out? Lmk if anyone went today or in the past