The test expired
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How it happens
A lot is tested, packed and partly sold, and the remainder sits. Five calendar months from the end of the test month go by, and what is left cannot be transported or delivered for transportation in interstate commerce until it is retested.
The seed is usually fine
Which is what makes this frustrating and also what makes it easy to ignore. The rule is about the currency of the evidence, not about the condition of the seed, and a retest often confirms the original figure.
The label is the problem, twice
The printed date is now outside the window, so even a fresh test means relabeling or overlabeling. That is a real cost, and it is the cost the twenty-four month window exists to avoid.
Over-packing is the root cause
Packing a year of stock against a five-month window guarantees this. Matching batch size to the window, or sealing to earn the longer one, are the two honest answers.
Sealing changes the arithmetic, not the rule
Twenty-four months from a test completed prior to packaging covers two seasons. That makes larger batches rational, and it is why the package decision and the production plan are the same decision.
Intrastate sales are a separate question
The federal window attaches to interstate commerce. State seed laws run alongside it with their own requirements, so a local sale is not automatically unaffected and is not automatically covered either.
Track it per lot, in a calendar
Lot, crop, test month, window end, and whether it is sealed. Four columns, and it is the only control that works, because nothing in the warehouse signals the date.
The cheapest fix is a smaller batch
Packing to the window rather than to the pallet costs a little more per unit and removes this failure entirely. It is the answer for anyone without an induction sealer, and it needs no capital.