Thats a flawed question.
Most hybrids now are f1s so you get a range of phenos. Every plant from a pack is not going to test the same.
For Bodhi seeds Black Triangle def has ohenos that test at 30%. But not sure how common that is.
Thats one of the reasons for clone onlies.
Heres some GMO which consistently tests 32-36%thc
(Clone only)