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Battleplans for 2023

An outline for the coming year, from The Hemp Hound Agency

2022... it's a year I feel most of us won't forget in a hurry, and for a multitude of reasons.

We've had it all: question marks placed over the heads of every major trade association, companies grassing companies up for non-compliance of Novel Foods requirements whilst breaking the very same rules, the public interest disclosure complaint in regards to the Food Standards Agency's (FSA) handling of Novel Foods, and in amongst that, we've got the likes of Cannaray and Brains Bioceuticals singing and dancing about how well they're doing when by all accounts, their wares shouldn't even be on the FSA's public list for CBD products, or for that matter, on sale due to them not qualifying for the CBD Novel Foods amnesty that was announced on 13/02/20... fun times!

But you know what they say, out with the old and in with the new, so welcome to 2023. Do feel free to leave '2022' a 1 star review on Trip Advisor, and lets make this a 5 star year for the UK hemp and CBD industry.

As for The Hemp Hound Agency though, we've got plans to discuss which maybe of interest. So top up that brew, and when you've got a handful of Hobnobs ready, lets talk about...

What to expect from The Hemp Hound Agency in 2023

Novel Foods

Since March 2022, I have been one of the few that's been championing fairness in Novel Foods for CBD products, which ultimately led to me submitting a public interest disclosure complaint against the FSA's handling of the process, as well as one or two other related matters of course.

You can find this complaint here, and see how the FSA responded to that complaint here.

They have informed me that there will be a reply in early February after a full investigation has been concluded, which I will then relay to you as soon as I receive it.

Does it stop there though?

I hope so, especially in regards to direct engagements with the FSA to the level they have been. Since March of 2022, I have now written 180 minutes read time worth of articles that all focus on Novel Foods (not including this one), and the time and effort needed to publish that is more than I'd like to admit.

I'm hoping that's in the past, the articles and finger pointing, and certainly the last couple of engagements with the FSA have been positive and proactive, but there's other aspects of Novel Foods that concern me, especially as there's an independent review of the Novel Foods process that should of started by now, or is due to very soon.

This review is not aimed specifically at CBD products as far as I know, but you can bet that there will be some sort of effect on a process that currently has over 12,000 products tied to it.

Don't think for a second that I'm suggesting a negative influence though, not for CBD products anyway as the FSA after all are trying to unpick themselves from EU directives, and any review could conclude that the Novel Foods process should be simplified, or not, it's just too early to tell.

My other concern though is with 'not novel' cold press hemp products and Article 4 Submissions, the review into Novel Foods will look at the requirements for a food to be deemed as not novel, and when an Article 4 Submission would be required.

What does this mean?

I'd like to think I'm also a champion for cold press hemp oil products, as well as the right to display cannabinoid content on the basis of being nutritional data and improtant for consumer safety and knowledge. I've written articles on the matter, one of which included me going direct to the FSA with questions on the topic, which you can find here.

Those articles are in fact a reply to several companies and trade associations who believe that cold press hemp oil circumvents Novel Foods Regulations, even though the FSA have confirmed the 'not novel' status of products that fit within the processing dynamics that qualify as cold pressed.

So what's the issue?

There's a few as it goes, especially when trade associations grumble nonsensically about little topics, when there were far more serious industry concerns that needed addressing at the time!

Forgive me, but I have umbrage with trade associations who ignore industry wide issues, which they themselves have to accept then raises those question marks over their heads that I alluded to at the beginning of this article.

That umbrage also carries through to companies who like to focus on the potential of the little guy not playing ball, when they're either bending the rules themselves, and/or are ignoring the big companies that are doing the same thing.

Why focus on products on the suspicion that they might not be as they say they are, or whether they may or may not be circumventing Novel Foods Regulations, when there are in fact a lot of CBD products on the public list that provably aren't what they say they are, and 'have' breached Novel Foods requirements for CBD products?

And the thing is, I'm not the only one who has noticed this!

But that aside, I believe that there will be an attempt to alter the definition of, and requirements for not novel products, outside of the existing chorus of mutterings, and I believe that this review that was tendered out by the FSA in October 2022 signifies that intention!

Needless to say, there will be the utmost scrutiny from me of whoever wins that contract, which will include background checks, to ensure that they have no connections to cannabis in anyway.

Cold press oils with an advertised cannabinoid content are a threat, not just to the companies and associations who have been vocal so far, but also to whoever pushed for all cannabinoids to be defined as Novel Foods.

We could debate who that is exactly, but my money is on those who supplied 16 lab reports to those who determined the requirements for Novel Foods, as they also have 148 patents for cannabinoid based medicines.

And that leads up to the problem that arises!

There is a blatant move to make the UK a powerhouse for medicinal CBD and cannabinoid based products, and rather unwittingly, the CBD industry is priming their market share to be taken away from them by allowing their products to be advertised as having medicinal impact.

There was a warning about this from the MHRA themselves back in 2018, when the then head of Borderline Medicines stated that they were just waiting for the consumer to view CBD products as medicinal before they step in and pick up from 2016 when they tried to define CBD as a purely medicinal compound. Fast forward to 2023, and most CBD companies are advertising their products as being anti-inflammatory, or able to help with chronic pain, and in a lot of cases, so much more.

So how does this effect cold press hemp oil producers?

Well it all comes down to that 'threat' I mentioned before, and if CBD products get redefined, which there could be a move for now that the MHRA are granting licenses for companies to grow unlicensed cannabis for medicinal purposes, there will then be a targeting of cold press hemp oils that advertise the cannabinoid content.

At the end of the day, CBD as well as cold press hemp oils are being sold with claims that match what this unlicensed cannabis will most likely be prescribed for, and those who grow it will pay licensing fees to do so, which means their interests need to be protected.

Equally there are companies who are playing ball, and aren't making claims that would raise any eyebrow in the MHRA's Borderline Medicines department, and they need protecting too!

Novel Food regulations allow for the sale of cold press hemp oil, labelling guidance and good practice means that products of this nature should advertise the nutritional content for consumer knowledge, as well as safety. That means that there's a potential issue for these products, which I personally want to deal with.

So what's the solution?

An Article 4 submission would validate cold press hemp oil as a food, and constructing it to argue with first class evidence that cannabinoids are nutritional, naturally occurring, and that they should be advertised, should do the trick.

As there's grounds for that, which can be shown through the awarding of 2 Article 4's for mushroom products that advertise their natural vitamin and mineral content, I plan to use that precedence within any application, as well as other cases where certain foods are allowed to advertise constituent parts within the food itself. Think Omega oils and fishfingers!

It won't be easy, I expect resistance, and it will require a lot of studying from me. I am looking to start a food law training course beforehand to ensure that the resulting Article 4 is submitted appropriately, and with the necessary accompanying evidence.

From there I will look into the feasibility of a legal conversion course, as long as there is the potential to focus on food law in that process.

At the end of the day...

In 2017 the FSA defined CBD isolates as Novel, but in 2019 the European Food Standards Agency (EFSA) defined all cannabinoids as Novel Foods, and the FSA followed suit. In 2 years, whole-plant full and broad spectrum products went from old food, to new. Those types of bombshells really shouldn't be allowed to happen too often, and yet here we are, in the hemp and CBD industry, still scrambling for some kind of solid ground.

On that, I feel obliged to pursue an Article 4 validation of the fact that cold press hemp oils with an advertised naturally occurring cannabinoid content are not novel, and thus safe from people or entities that are trying to put the kybosh on that industry.

And it is a different industry, related yes, but that distinction resides in part on the basis of selective vs non-selective extraction methods.

Cold press hemp oils have been about for some time, otherwise they would have been obliged to be part of the Novel Foods process. That was determined by the FSA in 2020 when they provided guidance on Novel Foods where they stated that "Cold press hemp, and derivatives, are not novel".

Not 'hemp seed oil', but 'cold pressed hemp'.

Here's the twist though, despite there being a recognised CBD food supplement industry in the UK, there is still that intention to hand all medicinal CBD and cannabinoid based products to the MHRA, which to me casts doubt on the small producers who helped build both the CBD and cold pressed hemp industries and are caught up in making claims that the likes of Cannaray and Brains Bioceuticals will be able to get away with.

Download PDF • 5.40MB
The TIGRR Report - please refer to P.81 Proposal 11.15: Regulation of medical cannabinoids and medicinal CBD from the Home Office to DHSC / MHRA to create a regulatory pathway for assessment and approval based on patient benefit

Subsequently, any accepted Article 4 Submission would not only protect cold press hemp oil providers, but potentially those who offer wholeplant CBD products as well.

It's all about recognising cannabis as a food, officially, and without any backdoor clauses that allow that status to be changed at the drop of a hat, which is exactly what happened in 2019!

I can't stop Novel foods, equally I can't stop companies from making unfounded claims on their cannabinoid based products, so where's the middle ground?

Keep reading and you'll find out!

At the end of the day, there needs to be an official recognition of cannabis as a food as much as a medicine. Everything's top heavy right now, which I understand and respect, but it's been suggested that regulations around medicinal cannabis needs to be sorted out before we talk about recreational use (??? Keep this in mind through the article), whilst dismissing cannabis as a source of nutrition, and the absolute craziness that is Novel Foods.

That's the issue, cannabis as a food is being overlooked by the 'recreational vs medicinal' debate that's been ongoing for a couple of years now, and I know why that is. The CBD industry, whilst projected to be a billion Pound (£) industry in the UK very soon, will never make as much money as a legal market for recreational cannabis would bring, and it probably won't even come closed to the revenue that medicinal CBD and cannabinoid based products would generate if certain hurdles were overcome.

The debate should be 'food vs medicines', but no Pharmaceutical company will win that argument, which then raises the question of 'who engineered that recreational vs medicinal debate?', and the answer to that is 'those who want medicinal cannabis sorted out before we talk about recreational cannabis... and ix nay on cannabis as a food!'

So in essence...

I will help any interested company to apply for an Article 4 for cold press hemp oil, and associated derivatives, on the basis that the natural cannabinoid content can be advertised as nutritional data, and that it should be advertised for consumer knowledge and safety.

I will use what I learn from the food law training course to reinforce my existing knowledge base, and construct the applications from there. From the point of submission, I will continue to 'man the post' to provide any further evidence that is requested, to ensure a smooth process.

What does that entail?

An Article 4 submission is practically a watered down Novel Foods application, in that it shouldn't require toxicology reports. Publicly available information is permitted as well, so the costs associated to the process should be a lot less than it is to create a Novel Foods application for CBD products.

What will be needed is proof that the food and the process have been used from before 1997, as well as evidence that shows acknowledgement of the Endo-Cannabinoid System (ECS), and that phyto-cannabinoids (plant derived) feed that system.

I've mentioned that I expect resistance from this process, which is why I plan to submit as much information with references as is appropriate.

It has been suggested by some that...

Article 4's are for companies who are 'uncertain' about the status of their products, but the FSA have stated that submitting Article 4's for cold press hemp oil isn't necessary as they deem said oils as not novel.

There is more than enough uncertainty around Novel Foods, let alone with the industry voices calling into question the validity of cold press hemp oils, or the flip-flopping between Novel Foods 1.0 (2017) and 2.0 (2019), so I believe that an Article 4 is an absolute must, to protect and ensure the status of cannabis as a food.

Side note

I want to make sure that some people don't confuse this direction as an agenda, in any other time and situation I would happily throw my hat in for the fight for better access to medicinal cannabis, and when the time comes, I will champion the right to smoke a blunt.

Cannabis is being labelled though, and those who are doing that labelling intend to close the door on all other facets which cannabis also has.

I can't have that, the plant belongs to the people, and that's not just on the basis of the Endo-Cannabinoid System!

Big business wants to legalise recreational cannabis in the UK, but then that will have a direct impact on the pharmaceutical sector, who themselves either want continued prohibition, or a decriminalised model that favours access to medicinal cannabis. Both want to pigeonhole the plant to a point that suits their agenda, which I hope I've demonstrated so far is at the expense of cannabis as a food. The problem there is that it was a food before it was a medicine, and was a food before the invention of 'getting blazed'.

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I am all about cannabis as a food, but even foods have medicinal properties

And that's been another big frustration in this hemp and CBD industry, at one point people could get away with rudimentary claims that focused on the ECS's ability to help regulate core bodily functions, but then the MHRA put an end to that in 2019, to a point where you're not even supposed to suggest that your CBD products can interact with the ECS.

On a personal note, I think that there are some companies who have really taken things too far now, but then I've still have further research to go that might indicate a lot of these conditions are in fact symptoms of Endo-Cannabinoid Deficiency Syndrome (ECDS), and if that's the case, the reason why a lot of people are sick is in fact because they have been starved of a food that is unjustly prohibited.

But that's getting ahead of myself! Cannabis is a food, but it's also a herb, and most if not all herbs have recognised medicinal abilities, but has this been accepted at all by the powers that be, or those who pay their wages?

Traditional Herbal Registration

When is an old herb a new medicine? That would be when you patent combinations of its constituent parts, and redefine what is 'effective'.

Cannabis vs cannabinoids anyone?

Separating herbs from their constituent parts is not a new thing as it goes, neither is separating herbalists from the claims that they can make on their wares. In 1941 the UK passed the Pharmacy and Medicines Act, which started the movement that ultimately allowed pharmacists to patent active compounds from plants, whilst dismissing the effectiveness of the source of said compounds, and dismissing those who used to sell them in a raw state. We are talking about a political move a few decades after a major pharmacological discovery that allowed for the isolation of active compounds within plants such as morphine and strychnine, and less than 100 years after the rise of the first pharmaceutical company, Merck (Founded in 1668 as a chemist, they made their move beyond that status in 1827).

80 year later from the Pharmacy and Medicines Act and the game is still the same, only we're dealing with cannabis, and the available literature that confirms its status as a medicinal herb is not something you can actually ignore, or erase.

And you've got to realise that cannabis when still listed in the British Pharmacopeia was labelled as being beneficial for an insane amount of medical conditions, and that was before the recent conditions that have emerged that may or may not be symptoms of ECDS.

So the problem here is that those who look to restrict basic claims on cannabis based food products are also those who recognise that cannabis was a traditional herbal medicine, and in part also those who keep the lights on at MHRA HQ.

We're not just talking about GW/Jazz Pharmaceuticals (GW) either, which will become evident later in this article, although allow me to plant an egg in you head. What pharmaceutical companies were about in the later 1800's that might have thought "We can isolate active compounds now quite effectively, and cannabis helps with lots of conditions... maybe we should lobby for it to become illegal, until we know what compounds it contains, how they work, and bosh, drop a new medicine or three!"?

Bear them in mind as you read further, you might come across them as we continue in this article.


That leads to an interesting situation - Big Pharma recognises the history of the good plant, and I can prove that in multiple studies from various companies tied to Big Pharma, which explains why there has been an aggressive move, certainly since 2016 in the UK, to separate cannabis from cannabinoids!

The TIGRR report is the intended roadmap for cannabis in the UK, which suggests that we should move towards becoming a powerhouse for medicinal CBD and cannabinoid based products, but in the same breath it states there is no suggestion that it calls for the legalisation of cannabis in anyway.

That leads to an interesting window of opportunity!

Essentially, and as mentioned above, we are talking cannabis, and as we all use strains that are on the EU approved list, Sativa L.

This distinction needs to be highlighted, especially as there is none in law that recognises indica or ruderalis, or if you want to be totally inclusive of all genus, Australian Bastard Cannabis (ABS) as well.

Sativa is specified though, so the question is, what has cannabis sativa L over time been recognised as helpful with, or acts as a preventative against?

Well let's just clear up something first

And that is the thought that any cannabis that is high in THC was historically used for medicines (amongst other things), where as low THC cannabis was only used for industrial purposes, or as a food.

Is that actually the case?

Who knew of THC in 2,900 BCE, when Emperor Fu Hsi noted that Cannabis ('Ma' in Ancient Chinese) was a popular medicine that possessed both Yin and Yang?

Was CBD known about in 2,700 BCE, when the book 'The Great Herbal' (Pen T'sao, still in use today) listed cannabis as useful against rheumatism, menstrual problems, gout, malaria, and absent-mindedness?

What about all of the other cannabinoids, the CBC's, CBG's, CBL's, and everything else under the cannabis leaf shaped sun, did anyone know of them? Last I heard, CBN was the first cannabinoid to be isolated, and that was in 1898, which is roughly about the time that people in the U.S started demonising cannabis by using it to attack ethnic communities at the time.

What about the distinction between sativa and indica, with both believed to have originated in Asia. Sativa L was classified in 1753 by Swedish botanist Carl Linnaeus, and Indica was classified in 1785 by the French Biologist Jean-Baptiste Lamarck.

Did the Chinese distinguish between the two? There is a distinction between what was used for food and industrial uses vs what was used for medicines, but both sativa and indica can express THC, you can have low THC variables of both, and both can be used for industrial uses. In Vietnam to this day for example, there is a region that grows cannabis for industrial purposes above other uses, but they grow a short plant, which suggests they use indica rather than sativa for their needs.

And what about the ancient Egyptians, who not only used cannabis internally (to cool the womb) but also externally for pain and swelling? Does the latter sound like a CBD balm to you?

Zoroastrians do their bit as well, the proto-religion lists cannabis first, and as the most important of over 10,000 medicinal herbs within its ancient texts, but is there a distinction between indica vs sativa, or any indication of the knowledge of cannabinoids?

And whilst we're touching on religions, Jesus Christ and his Apostles are alleged to have used cannabis oil to perform some of their miracles!

That's 'over there' though, what really means something is whether or not cannabis was used within the confines of the EU, and before there was the introduction of indica to the British shores.

Well, archaeologists discovered a grave in the Netherlands dated from 2,400 BCE, which contained cannabis pollen that was believed to have been used as a painkiller for the grave's inhabitant. One wonders whether that pollen was from an indica plant, or otherwise.

The earliest evidence of cannabis farming in Britain came as seeds that were discovered in York, which were dated to the 10th century. It suggested that the Vikings brought them over, who themselves seem to have a access to cannabis throughout their time of prominence (793-1066 BCE). Whilst it's uncertain whether they were using cannabis in any other context outside of a fibre crop, it is known that cannabis pollen has been found at most of their settlements outside of Scandinavia.

Whilst that is within the Viking era, it is believed that hemp oil was imported into the British isles beforehand by the Romans, who themselves share a history with the ancient Greeks that uses cannabis as a medicinal herb.

Then comes one of my favourite canna-celebrities, Pope Martin the 5th, who's actually Martin the 3rd, and had cold press hemp seed and flower added to his lunchtime soup everyday during his rein back in the 1400's. One wonders whether that was purely for flavouring, or as a tonic for some unspecified condition.

In the middle ages cannabis was used to treat jaundice, coughs and pain, but trade routes with Asia and the middle east brought knowledge to the UK of the other herbal benefits of cannabis, and led to Nicolas Culpeper (1616-1654) describing it as beneficial for depression, arthritis, gout and inflammation.

Culpeper himself was English, and if the knowledge he gained was through modern trade routes of the time, the use and knowledge of Cannabis in Wales beforehand came from the migration of the Celts into the area. The file below is called Medieval Welsh Medical Texts which was originally printed in 1861, but it's actually comprised of 4 documents called Meddygon Myddfai (‘The Physicians of Myddfai’) which were originally written around Culpeper's time and includes preparations for fevers and sores which include hemp tops. Some of the preparations are alleged to have been passed down from Hippocrates (460-370BCE) and Galen (129-216AD).

Medieval Welsh Medical Texts Meddygon Myddfai
Download PDF • 25.07MB

You would assume that this was before indica reached the UK, and due to many references to hemp during that time you would assume that we are looking at potential health benefits from low THC sativa.

At least 'I'm' assuming that, and that's on the basis of W.B O'Shaughnessy reintroducing cannabis to British medicine in 1842 after conducting experiments with 'Indian hemp' in 1839 whilst stationed at Calcutta.

And then we have the Scottish, who have a little more history with cannabis than most may know about. Seeds sourced from bazaars in Bombay were sown at the Edinburgh Botanic Garden in 1849, which ultimately resulted in plants standing 3 metres high. This funnily enough is the height that most sativa strains can grow to, and it is rumoured that the reason we only have sativa strains on the EU approved list is because the height allows for a better fibre content.

But allow me to just remind you of what I said earlier. Sativa and Indica have the same geographical origin, so would that Indian hemp be indica, or sativa?

The funny thing about this is that those who grew this Indian hemp in Scotland concluded that indica and sativa were one species despite the classifications from Linnaeus and Lamarck nearly 100 years beforehand, so is it possible that what was thought be Indian Hemp, and ultimately used for medicinal purposes and listed in the British Pharmacopeia as cannabis indica, was in fact sativa?

And that argument I believe, justifies the right for a cannabis oil, derived from sativa strains, has a fair shout for the right to a Traditional Herbal Registration.

And most importantly, THC content isn't an issue as the hemp strains that were used in the UK before any introduction of Indian hemp whether indica or otherwise was in fact low in THC, with some suggesting between 3-7%, and was still recognised as a herbal medicine for a wide range of issues, and was a sativa, just like the strains on the EU approved list.

OK, maybe not quite like the strains on the EU approved list as those strains have less than 0.2% THC in them, but even with the 3-7% cannabis that was indigenous to the British isles pre-1800's, there seems to be no history of cannabis use in the UK before that time that suggests people were using it to get high.

And that's a point that needs to be made, and with our current knowledge of cannabis as a plant, and by looking at GW's patent list, we can clearly see that THC is not the only medicinally beneficial cannabinoid to be found in the cannabis plant.

The pitfalls of this thinking

There's a few bodily systems that benefit from herbal sources, but few herbs to my knowledge directly interact with the ECS as much as cannabis does. Yes there are other sources of phyto-cannabinoids, but the sources themselves tend to have a handful of active ingredients at best, where as there is an ever growing list of cannabis strains, all of which have different terpene profiles as well as cannabinoid content. We are in effect talking over 500 known compounds, most with recognised benefits and abilities, and that's growing (seemingly) daily.

That being said, there are a list of conditions that seems to be quoted from areas within Europe and the UK where it can be argued that low THC (hemp) sativa was used as a herbal remedy, subsequently that should mean that sativa oils derived from EU approved hemp strains should be able to qualify for a Traditional Herbal Registration, so how do we get one?

The answer to that is 'by getting a cold pressed sativa oil validated as a food first!'

And then it depends on the MHRA, who are earmarked to regulate the UK's push to become a powerhouse for medicinal CBD and cannabinoid focused products.

But there is the issue of who funds them, and as it turns out, they were created in 1988 by Margret Thatcher as a department that runs on licensing fees from pharmaceutical companies. The list below comes from a recent Freedom of Information request (FOI, which I did not submit) for the MHRA's income over 2019 to 2020, and it has some very interesting names that you'll find easily with a quick word search (Control + F, do try to remember those pharmaceutical companies who were about in the late 1800's as well as those who are 'running the show' today, shall we say).

2019 20 Income transaction raised
Download XLSX • 183KB

There's also what happened in 2016, the year when the MHRA tried to redefine CBD as a purely medicinal compound. They would have been asked to do that to protect someone's interests, and considering the Home Office (HO) approached the FSA in 2017 to ask that all cannabinoids be defined as Novel Foods, guided the VMD in 2018 on outlawing CBD supplemental pet products, provided 16 lab reports that are ultimately being used to govern the requirements for a competitor industry via GW who themselves admitted to a 20+ year long working relationship with the HO in open documents, it's a sure bet that any Traditional Herbal Registration submitted by me to the MHRA will also be met with a similar level of resistance that I expect from submitting an Article 4.

The ultimate issue though, from what I can see, is that there are several conditions listed through the world that medical cannabis can help with, but history suggests that the plant as a whole is better than the sum of its parts, and it's never been just about one cannabinoid, not in a traditional herbal sense, anyway!

And if I successfully highlight that, that's when the resistance will come!

But it will benefit many, because accepted food related health claims for cold press cannabis (hemp) sativa L oil (and derivatives, and with an advertised cannabinoid content) should open the door for similar regulated claims on CBD oils and related products.

The process is similar to that with an Article 4 Submission, in that publicly available information is acceptable, and it must show evidence that the herb being applied for has been known to help with condition X for over 30 years

You might ask, why so heavy on distinguishing between sativa and indica

Well we've got to go back to W.B. Shaughnessy, who we'll call William from now on, and is reputed to be responsible for providing Queen Victoria cannabis for menstrual cramps, or as the ancient Egyptians called it, to cool the womb!

It seems to me that William has shown something that others are yet to see, that THC is not the be all, and end all, of medicinal cannabis. He did that inadvertently of course, because a lot of the conditions that indica was used to treat after he reintroduced western medicine back to the potentials of cannabis were already being treated with indigenous sativa that had nowhere near the THC value of indica, or Indian hemp, especially when it came in the form of hashish, or far more potent oils that were extracted from it.

The confusion with indica and sativa is a long running saga, which is further added to by the fact that even the strains listed as sativa's on the EU approved strain list aren't entirely 100% sativa. A lot of plants as a whole are hybrids, and have been bred to incorporate genetics from both indica and sativa, and if you're looking for an auto-flowering seed, ruderalis genes as well.

I know, no-one's added ABS to that list yet, but that might just make things more complicated...

You can make a sativa plant have indica qualities - the canna-community are fast catching up on 'when' to harvest a plant, and ignoring the specified grow times that come with certain strains. In that world, indica is known to (mostly) express more CBN, which is decarboxylated THC Delta 9, and more associated with the side effects to cannabis use that Delta 9 is often demonised with. So to make a sativa express more CBN, you simply add a week or two to the suggested flowering time for the strain you're growing, and keep an eye on the trichomes for when they turn an amber colour.

You can do a similar reversal with an indica, in that if you shorten the flowering cycle, you will capture the THC Delta 9 before it converts to CBN, by ensuring that you harvest when the trichomes are milky which is before they turn amber with the presence of CBN.

And Big Pharma is not immune from such confusions either!

Sativex, created by GW... Is it made with a sativa?

Well it's believed that GW brought the genetics for a strain called Skunk #1 somewhere in the late 90's to early 00's, and are growing that as well as genetic variants in Portland Down for their products, but is it a true sativa?

Well according to many sites, Skunk #1 is a hybrid which is 65% indica... say no more!

I firmly believe there needs to be a rethink of this whole indica/sativa debate, after all, a rose is just a rose, regardless of the colours of it's petals.

And on that thought, you've got to wonder if indica isn't mentioned or distinguished in law for a reason, and that's because it's believed that all cannabis preparations before cannabis was removed from the British Pharmacopoeia in 1938 (I believe) were labelled as being derived from cannabis indica, and not cannabis sativa. But sativa was in the UK at the very least 860 years before indica, and it was recognised as being able to help with conditions that its so called THC rich indica cousin can help with, despite it lacking in the THC department over that near 1000 years.

But, you've got to play the game regardless of the cards that are dealt. So on that basis...

The Article 4 will lead to a Traditional Herbal Registration application for cold press cannabis sativa oil, that is allowed to advertise a cannabinoid content on the basis of nutritional data, consumer knowledge, and of course consumer safety.

And if I can secure that, then I will be looking at the feasibility of applying for a low THC indica oil on the same basis. I know that there is certainly one respected company that does openly process low THC indica for their products, and that the FSA are fully aware of that dynamic, so it's pretty much accepted as a food even if indica (and ruderalis) itself could be viewed as more prohibited due to there being no specified indica strains on the EU approved strain list, and that's half the battle fought!

I'd be foolish to think I will be able to do all of this in a year though, in fact I'd be lucky if I got it done in two, but I'm in this for the long haul, and I invite all companies either currently selling, or are looking to sell cold press sativa oils to give me a shout.

I'd also be foolish if I thought for a second I could apply for registrations for each and every potential condition that cannabis could be a natural remedy for - some of the conditions from days past that cannabis was used to treat don't quite have the evidence to suggest that they were effective, but there are other conditions listed that do have ancient and recent information to show that cannabis was the herb that got the job done. You'll understand when I say my cards are close to my chest on this one!

I have to point out that I have no business to tie into my actions, neither will I create one, or a product range that benefits from them. That wouldn't be right, certainly not in my head anyway, but I feel the same opinion would come from others as well!

That's OK though, I had my shot in 2016, and learnt quite quickly that my forte was helping companies rather than running one, other than The Hemp Hound Agency of course.

I have no doubt in my mind that I have to take this journey, there's just too many things that are pushing me towards this action which I can't ignore, so I won't, and I'll crack on from here whilst going about my day to day tasks with The Hemp Hound Agency, promoting The Directory, and developing Hemp Hound TV... It's going to be a busy year!

That all starts on the 10th of January, which is The Hemp Hound Agency's 2nd Birthday. If you want to know more about what's going on, or want to be part of the journey, email and ask for more details.

Before I go, I've got something a little unusual for you

Poetry, but we're not talking any old ramblings from Wordsworth, Keates, or Slim Shady, and the topic matter is of absolute relevance to this article, and the direction that The Hemp Hound Agency is taking from here.

Before the 1941 Pharmacy and Medicines Act came into play, Viscount Plumer stated in the reading of the bill in the House of Lords that "herbalists are being very badly treated". The Viscount himself declared his interests as the Chairman of the Society of Herbalists at that time, whilst calling into question the intention of the Act, why such a bill was being pushed through and taking up valuable Government and Parliamentary time whilst in the grips of the Second World War, the impact it would have on herbalists, and of course the unfairness in effectively giving pharmaceutical companies the chance to patent nature.

He obviously wasn't successful in his endeavours, but what I find interesting is that those who challenged him and herbalists in general used the same sentences now that still shackle the plant to this day, just as GW used recently when saying that the CBD industry needed more political direction, that controlled cannabinoids are dangerous, and that cannabis by extension should continue to be prohibited... whilst holding 148 patents behind their back, and giving a thumbs up to their shareholders.

1 Comment

Unknown member
Jan 10, 2023

Hear! Hear! The very best of luck on your voyage. Millions are behind you and your strategy, knowledge and tenacity is the boon. Godspeed!

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