Conflicts, Cover-Ups, and Cannabinoids: Exposing UK CBD Regulatory Capture and Why the FSA Must Reopen The Hemp Hound Agency's Complaint
- Apr 14
- 12 min read
Updated: Apr 17
What you're about to read is a recounting of a complaint process.
For those who know this story, I have a document that raises serious concerns about the involvement of Miss Emily Miles, the former CEO of the FSA, in that process. For those new to this, the FSA oversees food safety and novel food authorisations, including CBD products. But this is not a story of public protection, it’s a story of regulatory control, and a clear case of CBD regulatory capture in the UK.
Three years and two days ago, after listening to the concerns of various companies in the UK hemp and CBD industry, I submitted an email to the Head of Novel Foods, Paul Tossell, which expressed concerns about the FSA's management of CBD novel foods.
I covered that email in an article titled 'A letter of concern to the FSA'.
To cut a long story short:
The concerns, which came with evidence, were dismissed, twice, and when I was invited to submit a complaint, no direction was given.
But I did submit one in July 2022, and it wasn’t until I became vocal on social media that, by October, the FSA started to take it seriously. That complaint initially started in the form of two articles, 'Exposing the lies' Part 1 & Part 2, which were submitted to the FSA. After several emails between myself and the FSA Head of Complaints, Noel Sykes, the complaint was refined and delivered in one document.
I had a meeting at the end of October 2022 with Mr Sykes, who told me that "The Civil Service has a habit of ignoring inconvenient truths", whilst sitting next to a director who had been in the job for a matter of weeks.
That director, Dr James Cooper, claimed to be an observer, but he was very knowledgeable, certainly with synthetic CBD, and his purpose seemed to be more about rewording my complaint rather than addressing the issues that were raised.
Those issues were:
1. The creation of a cartel market to protect a monopoly - This is something we're still seeing, with companies being forced to 'accept' the 10mg ADI to progress towards authorisation of their products. (Also see point 4)
2. 13/02/20 - Certain companies were allowed to progress through the system despite not having physical products available to the consumer before this key date.
The FSA even confirmed this in FOI files which showed Cannaray could not prove product sales before this date, but their application was validated, despite the FSA ejecting others from the process for not being able to prove sales prior to 13/02/20.
3. 1mg rule - The FSA validated products that breached the Misuse of Drugs Regulations (MDR) 2001, but removed other products for that breach... rules for thee but not for me!
4. Conflicts of interest - Some might be aware that I've recently had conversations with a faculty member from Reading University about his employers connections to GW Pharmaceuticals, and questioning why they weren't declared when he discussed CBD, whilst representing his employer at the CoT, and reviewing 16 lab reports and literature for Epidiolex, which was presented by two GW Observers in January 2020.
This point also covered the use of pharmaceutical data to judge the safety of a food, and links to food crimes. (Also see point 6)
It also highlighted the FSA's relationship with the ACI - Links to GW, a vehicle for the intent of the Centre for Medicinal Cannabis, 'Join us or you won't be on the market past key deadline dates', fake lists of companies whose novel food applications had been rejected by the FSA, CBDListUK.com, and their links to the TIGRR report that was designed to benefit GW... say no more!
5. Actions of a named FSA worker - This complaint came as a result of Mr Tossell effectively saying twice that there was nothing to see, and I feel that he didn't adequately direct me to a complaints process. Due to the strength of the evidence provided to him, I questioned his actions in-line with the Civil Service Code.
6. Food Crimes by a regulator - diminishing the authenticity of whole-plant products, and diminishing foods by applying hoops to a process derived from pharmaceutical data. There was also a concern over the fact that the FSA had decided that synthetic CBD was the same as plant derived CBD Mr Sykes said that 'he' would investigate the complaint, which he officially confirmed in December 2022, but little did I know that he would hire an employment agency worker for that task.
But this was no ordinary worker. It turned out to be the FSA’s ex-Head of Resilience, with no food safety background, and, as confirmed through FSA FOI responses, his intent was to ensure no points were upheld.
It must be said that Mr Sykes did announce who would turn out to be a Mr Philip Randles, only he was described as 'extra resource', and when asked, he stated that it was internal to the FSA, and to help go through the evidence that had been submitted. I received a response dismissing all points, after three delay emails, with instructions on how to escalate the complaint if I wasn’t satisfied.
This is where Miss Emily Miles, who up until recently was the CEO of the FSA, enters the picture. I submitted my escalation request to her personal assistant (PA) in June 2023, however, after a week, I had received no confirmation of receipt email, and had to chase up. This involved liaising with Mr Sykes, and after the request was accepted, he stated that he would write a report on the investigation and the points raised in the escalation request.
He also stated that he would present that report to Miss Miles, who would provide updates to the progress of the investigation from there through her PA.
I waited, until November 2023, and due to having no update after five months, I submitted an FOI requesting all files in relation to the initial complaint investigation that was allegedly conducted by Mr Sykes.
He emailed in early December 2023, apologising for the delay, stating that he had shelved my complaint because of an existing workload.
There are two things I need you to consider here:
This complaint was made in the public interest with as much the industry in mind as the consumer. The FSA has a duty of care to both, and by shelving that complaint, it shows a level of disrespect to both. I'm deliberately removing myself from that equation. It would be easy for me to take the events of the last three years personally, but I entered this process with the industry in mind, and the consumers they served.
Miss Miles had assumed responsibility for the complaint at that time, so a big question needs to be asked as to why she hadn't chased up Mr Sykes for an update on his report that he said he was compiling five months earlier.
Mr Sykes further told me that he was aware of my FOI, which was publicly announced by The Hemp Hound Agency on social media. The concern there is 'that disrespect'. Why should it take an FOI request to the FSA for them to conduct a process that should have been dealt with within 20 to 40 days, as defined by government guidance when dealing with complaints that are in the public interest?
In March 2024, I attended an escalation investigation meeting with two FSA directors, neither of whom had any connections to CBD or novel foods. It was held in London, and I attended with some print-outs of evidence that was included in the initial complaint. We discussed the points that were raised, as well as the print-outs which I had brought, and it seemed like a positive conversation until is was said that:
"We could agree with all the points that you have raised, but the ultimate decision on the complaint resides with Miss Miles. She could agree with our findings, or, she could decided to uphold the initial findings"
This is where I started to think that the chances of an honest investigation was slim at best. What's more, a door was closed in that I was told that no new evidence could be submitted. Bear that in mind moving forward. Shortly after that meeting, the FOI request for all files for the original investigation was answered.
That response showed:
That an employment agency worker was hired to investigate the complaint - while Mr Randles' name was redacted, the email trail showed he was in the driving seat, and certainly was not, regardless of prior employment, ‘internal to the FSA’.
Miss Miles was briefed on the use of Mr Randles - This means that she would have been aware that he was hired to manage my complaint rather than investigate it in good faith, which furthered my concerns that there would be a dismissal of the escalation to Miss Miles.
Cannaray could not prove product sales prior to 13/02/2020 - But from there, it showed that the investigation wasn't completed. The point that highlighted that came in the part of the email chain that recognised the part of the complaint that focused on products the FSA had validated despite breaching MDR's 1mg rule, only for the complaint response for that section stating that those products were fine because they were on the market on 13/02/2020.
Another complaint equally as comprehensive as mine was dismissed because it was made anonymously - The reason why it was included in the FOI response is seemingly because it used similar language to that which I had used. What's more, even though it was made anonymously, the sender had provided an email address and an invitation to discuss that complaint further.
Despite being named in the complaint, Mr Tossell seemed to be part of the investigation, was told that no point would be upheld, and was allowed to check over the initial response to the complaint two weeks before I received it for 'factual inaccuracies' - This reinforces concerns over potential breaches of the Civil Service Code, and that there was no impartiality when conducting the investigation into someone who had dismissed actionable evidence.
Mr Sykes refutes saying that "The Civil Service has a habit of ignoring inconvenient truths" - But this is from a man who misrepresented an employment agency worker as internal resource, but as the FSA's ex-Head of Resilience, his experience was key to protecting the FSA's image, and not for investigating complaints of systemic mismanagement of an entire industry.
It's at this point that I realised a fair investigation was slimmer that what I had previously thought, so I submitted the FOI findings to the directors handling the escalation investigation. They responded saying that "we can't accept any further evidence", but I stated to them that as part of the focus is as to whether the initial investigation had been conducted appropriately, I was showing them that I had the files that they should be looking at. That unfortunately did little, as shortly after, I received Miss Miles' final ruling, and again all points were dismissed.
Some of you might be wondering what’s happened since then that’s led me to call for the complaint to be reopened...
Well, Miss Miles became a person of interest, more so when her work history was discovered:
She was a policy advisor for Tony Blair between 2002-2005 - Blair's government effectively signed an agreement with GW Pharmaceuticals in 1998, with Blair himself introducing the Skunk narrative in 2005.
2005 to 2011 - She worked mostly between Downing Street, the Cabinet Office and the Home Office, although according to Hansard, there is very little in the way of government documents, including in The National Archive for what she was doing at that time.
2012 to 2015 - She was the Director of Policing at the Home Office, which we'll discuss momentarily.
2014 to 2015 - She was appointed Director, Projects, Economic and Domestic Secretariat at the Cabinet Office, which is the overall red flag for why Miss Miles should not have investigated the escalation of my complaint, or at least, she should have declared conflicts relating to the topics outlined in the complaint.
2015 to 2019 - She was a Group Director of Strategy (November 2015 to April 2018), and Director of EU Exit Domestic and Constitutional Affairs Directorate (April 2018 to April 2019), both of which were at DEFRA.
October 2019 to September 2024 - She was appointed as the CEO of the FSA just as they were formulating Novel Food Regulations for CBD products. She announced that she was leaving that position within weeks of providing the escalation response and going back to DEFRA.
The question is: what projects was she tasked with looking after?
And this is where I must present my evidence and explain why Miss Miles was conflicted when assuming responsibility for the escalated complaint:
GW are known to have received batches of seized cannabis from the Home Office in 2004, 2008, 2014, and 2018.
These were provided directly from police forces, so you would assume that as the Director of Policing, she would have had to sign that off, or at least, directed the police on what to send and where.
Plus, you would assume that she was part of policy discussions surrounding cannabis regulation regardless of context.
According to Prof. Geoffrey Guy's 2021 book, 'A Worthwhile Medicine', GW not only provided answers to parliamentary questions regarding cannabis for the Home Office, they also maintained narratives.
That means that in Miss Miles' capacity as the Director of Policing, she could well have been privy, or influenced by that management.
But this is where we have confirmation of involvement in CBD regulation, and conversations regarding its novel status between 2014-15
That FOI response addresses questions regarding Miss Miles time as Director for Policing.
1. All internal emails, memos, and meeting minutes referencing ‘cannabis’ or ‘cannabinoids’ where Emily Miles is named or included as a participant.
2. Records of any correspondence between Emily Miles and the Drugs & Firearms Licensing Unit (DLFU) regarding cannabis regulation, licensing, or enforcement policy.
3. Any documentation linking Emily Miles to discussions about the novel food status of CBD or regulatory coordination between the Home Office and the FSA.
4. All records from 2012 to 2015 where Emily Miles provided input on controlled substances policy, including cannabis scheduling and regulatory enforcement.
The response confirmed the existence of files within the scope of questions 1 and 3, confirming her involvement.
This should naturally lead to one question: Was she the CEO of the FSA to manage something she became part of between 2014-15?
That question considers the fact that the FSA has confirmed that the Home Office approached them in 2015, when Miss Miles was still in their employ, asking for the novel status of CBD. If she was, and it's extremely likely that is the case, it would not be in her interest to investigate in good faith a complaint that could have a negative impact on something that at the point of her providing the escalation response, she had been working on for 10 years. This leads to a wider concern regarding Mr Tossell and his placement as the Head of Novel Foods days before the EU announced CBD as novel in January 2019 after not having anyone in that position from September 2018, one month before the FSA sent an Article 4 submission calling for CBD to be classed as novel. That submission itself was made one month before the legalisation of medicinal cannabis in the UK, which came about due to a politically managed public campaign that focused on Epidiolex. And of course, Mr Randles. If she greenlighted his hiring, she would have also defined his brief. And if that's the case, its most likely that in 2014 when she became Director of Projects, Economic and Domestic Secretariat at the Cabinet Office, she became the Civil service manager of the agreement that exists between GW and the government.
Subsequently, she is conflicted. To what extent is anyone's guess, but when considering that which has been detailed above, there is enough to call for the reopening of my complaint against the FSA's handling of novel foods, and for any investigation to be conducted in good faith.
The letter below calls for that, and was sent to the FSA on 11/04/2025.
Before you read it though, let's talk
First off, this is bigger than novel foods. This is about regulatory manipulation and undeclared conflicts of a senior Civil Servant when investigating a complaint that was made in the public interest.
Equally, this has never been about 'me'. With my past in the hemp and CBD industry, this is about a duty of care to the industry, and when others were too scared to rock the boat, someone had to.
CBD novel foods has never been about consumer safety, it's about corporate interests that are managed by the government.
Politicians come and go, but Civil Servants, the only place they go is where they can best support the governments intent, and it seems that Miss Miles is a journey-woman.
For this investigation to be reopened, I need support from you the industry. And to any consumers who're reading this, we need your help too. The FSA has shut me down twice, but here's hoping that the third time is the charm, and that they will investigate my complaint completely and transparently. If you want to help, here's what to do. Email either paul.tossell@food.gov.uk, noel.sykes@food.gov.uk, or cbdpubliclist@food.gov.uk, and simply state that, as a business, industry participant, or consumer, you have concerns and would like to see the complaint submitted by The Hemp Hound Agency in June 2022 investigated appropriately, and in line with the Civil Service Code.
This is no longer an inconvenient truth that can be ignored
In summary, this article highlights:
Clear conflicts of interest within the FSA’s handling of CBD novel foods
Evidence of executive interference and procedural mismanagement
The need for an impartial, transparent investigation to restore public trust.
This is why I’m calling for the reopening of my complaint, and why your support matters
For further information regarding this article or the services on offer through The Hemp Hound Agency, call 07456528813 or email: cefyn.jones@hemphound.co.uk
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