Exposing The Lies! Part 2
A look into the last validated companies, followed by a spot of whistleblowing directly to The Foods Standards Agency (FSA).
An esteemed industry peer recently said to me, "It's not what you know, it's who you know"
He's obviously not the only one to say it, I'm just shy of 46 now, and I'd hazard a guess and say there's a good few hundred who have uttered those words to me, but one thing's for certain, a good eight out of ten of them never say it in a way that convinces me they believe it to be a good thing.
Bare this in mind as we go into Part 2 of 'Exposing the lies!', from The Hemp Hound Agency.
But first, a recap of Part 1
None of them had products on sale in the UK before 13/02/2020. One company was launched 15 days after that deadline, two were validated on the FSA Public List before having products on sale, and one of those is selling a product which in my opinion effectively compromises the authenticity of natural CBD products, which is a food crime, and something we'll touch on towards the end of this article.
But now it gets interesting, there's 5 other companies to look at and they all bring something 'different' to the table, so without further ado...
let's crack on with part 2!
Health and Happiness UK/Bod Healthcare might look like they have some legitimate products, but their capsules aren't, as they seem to have been launched on 10/04/2020.
This is based of their Facebook page as well as their Instagram page, as there are no lab reports for the capsules on their website.
Their CBII range was launched barely two months before the 13/02/2020 deadline for products on sale, but that doesn't necessarily mean that they didn't manage to make any sales in such a short time.
The capsules, if it's not "rules for thee but not for me", shouldn't be listed.
But aside from that, this might just be the first company I've looked into who actually has legitimately validated products!!!
IF... we weren't working off of the 1mg rule and functioning by 0.2% THC by volume.
This is a classic mistake which I've been aware of since 2016 - when you see 0.2%, that comes from farming guidelines and doesn't reflect the requirements for a finished, ingestible product. If we took a 10ml container, which is approximately 10,000mg dependent on carrier oil and final density, 0.2% THC means there's the potential for 20mg of THC per product. So this knocks out their 5% oil application, and leaves their 1% and 2% oils as possibly legitimate
That being said, that's not the only issue
Riddle me this - if Health and Happiness UK launched 2 months before the 13/02/2020 deadline for products on sale, what does it say when their supplier, Bod Healthcare, were incorporated in the UK in March of that year?
That's their UK arm anyway, Bod Healthcare have their roots in Australia, and are heavily involved in the likes of Project Twenty21. In fact, you can still see remnants of Bod Australia online from when their name was next to validated products.
Either way, all but 2 of the products submitted by Health and Happiness shouldn't be validated. There might be a reason why they are though, Bod Healthcare have access to the Medicines and Healthcare Regulatory Authority (MHRA) through their focus on medicinal products, which ties into a theory I outlined in Part 1 of this article.
"I've a question for you, what do you think all the validated companies have in common? Access to facilities that are MHRA approved!
This is very important to know, because I believe a destination point has been established, by The TIGRR report, and that's the reason why companies that have access to MHRA approved facilities and processes have been validated so far."
How many of the 99.31% of companies on the FSA's public list that are still 'awaiting evidence', have access to MHRA accredited facilities? I'll bet you 20p that the total number isn't very high!
Moving on, but first, I've a conflict to declare!
Controlled cannabinoids... I'm a big fan, but considering we're talking food supplemental levels, you know that my enthusiasm isn't on the basis of getting 'blazed'.
So back to that 1mg rule, it used to be a safe bet until Novel Foods came about, but then we started the process, and certain things became evident.
Controlled cannabinoids, which for the best part are owned by GW/Jazz Pharmaceuticals and includes THC Delta 9, in any products were likely to hamper applications as the requirements were based around 16 lab reports, from GW, for isolated CBD.
The FSA suggested as much, with Paul Tossall stating in an open webinar to Stephen Oliver and Matt Lawson of The Canna-Consultants that the Home Office (HO) were holding the FSA's hand in regards to controlled cannabinoid levels.
Then Kit Malthouse, as Policing Minister, called into question the levels of controlled cannabinoids in CBD supplemental products, which led to the HO and ACMD putting out a call for evidence in regards to all cannabinoids.
The ACMD came back to the HO with their suggestions on controlled cannabinoid levels, which was more than halved in an 'opinion' submitted by The ACI (GW in sheep's clothing).
Neither gave much leg room if accepted by the HO, and suggested full and broad spectrum applications could struggle.
Enter Charlottes Web/Savage Cabbage (CW), and with one or two products that are, shall we say, 'as full-fat as you like!'
This is where I'm conflicted, because I like a bit of fat in my CBD products, so when I see some of CW's products, I don't really want to make a noise about it, but I have to.
I've no choice for two reasons, 1) I've worked with 100's of companies who helped build the UK CBD markets to where it is now, and 2) everyone of those companies I've worked with was led to believe that submitting an application for a product like this would be a silly move.
So when I see this lab report, I feel that someone has made a mockery of the Novel Foods process, and at the expense of every company who wanted to be able to submit and application for a true full spectrum product.
We all know CW have been about for a bit, so on that basis I wasn't going question whether they had products on sale in the UK before 13/02/2020, but I have a pretty good understanding of the law, and that's where we have a bit of a hiccup.
When is a drug a food? Well due to the existence of the Endo-Cannabinoid System (ECS), cannabis is a food before anything, but we're working by law and not ideals here.
The two governing bits of legislation when it comes to cannabis 'the drug' vs cannabis the 'food' are the Misuse of Drugs Act 1971 (MoDA, Sect 37), and the Misuse of Drugs Regulation 2001 (MoDR, Sect 2) respectively.
The HO recently told a UK trade association that MoDR (1mg rule) doesn't apply to CBD products as they don't quite fit all three limbs of Sect 2, which is an interesting thing to say half way through the Novel Foods process, and after the 1mg rule had served their purposes through the lifespan of the hemp and CBD industry. The HO went on to say that MoDA needs to be amended to accommodate an ever growing CBD industry. If that's the case, we're working by MoDA as is, which means Sect 37. This basically translates from legalese as 'regardless of THC level, cannabis is illegal'.
That being said, that is their opinion, and stays that way unless tested in court, or accepted and reflected with amendments to MoDA.
Despite their opinion, UK based financial service providers observe MoDR, but regardless of which laws we're looking at, this and other CW and Savage Cabbage products shouldn't be validated.
This concerns me, one of the reasons why I started looking into CBD was because I became aware of CW and what they do. I was so hoping that they would be one of those companies who I could say "at least Novel Foods is working in 'some' way", but actually, these validated products almost reinforce the craziness that surrounds Novel Foods as much as Pureis and their synthetic CBD.
So how are these products even validated if the HO is supposedly ensuring that the FSA are aware of controlled cannabinoid levels? Turns out that CW brought Abacus Healthcare not so long ago, and that came with access to MHRA approved facilities!
Let's just take a breather for a second!
I need to explain something, it may make some of you breath easy, others, not so much.
Another esteemed industry colleague recently suggested to me that there are 1,100 Novel Foods applications for products that didn't exist before 13/02/2020. That's OK, I've seen a few, and I'm aware that there's some big players who have products in that number as well.
The reason why that's OK is because those companies haven't had their applications validated yet, which means that the FSA haven't assessed the validity of any submitted evidence.
which then leads to the question of why I'm doing what I'm doing.
The system is rigged, there's no doubt about that, so my intention is to expose just how much it's rigged. I don't have to look at any other companies than the 11 that are validated to show this, so anyone who's submitted questionable evidence with their Novel Foods application and is still holed up with the chasing pack can breathe easy, because I don't think you're going anywhere for a bit.
And to those validated companies who're reading this and consider me as public enemy No.1, I'm sorry to say this but the feeling isn't mutual. The FSA are my focus, because if they ever admit to accepting dodgy (case by case) applications, the submitted evidence will either need to be thrown out, or re-evaluated appropriately. If the latter turns out to be the case and Novel Foods is rebooted fairly, then I think I need to warn those 1,100 or so fake applications that Paul Tossall has stated it's a serious offence to lie to the FSA when it comes to food products...
In all honesty, you should all be aware of that full stop, regardless of whether Novel Foods is shown to be corrupt or not!
Anyway, we currently have 9 questionable applications that the FSA have let through the door, of course all in varying degrees, so let's look at the 2 we've got left.
And for a second, I thought I had found 'the chosen one', a company who had all of it's products just right...
Only to realise that it wasn't the case, and that this company had validated products with just a tad too much CBN in, which is a controlled cannabinoid, and subject to the 1mg rule.
We're not talking too much over, certainly nowhere near the levels of controlled cannabinoids present in CW's products.
cbdMD from my investigations are the closest to having a clean bill of health, some of their products are in fact bang on point, but their higher strength products are defined in UK law as drugs.
There's not quite a direct link to the MHRA, but cbdMD have medical trials going on which is pretty much the like of having your foot in the door.
That being said, you can imagine how disappointed I was when I found this lab report for their 1500mg Natural Tincture.
30ml, with 0.107mg per-millilitre comes in at 3.21mg per bottle. This isn't as much as they have in their higher strength gummies though, they come in at over 9mg per container (132.42g container at 0.070mg of CBN per gram equals 9.27mg). Again, nowhere near CW's controlled cannabinoid levels, but that's 10 out of 11 companies so far who have products that shouldn't be validated.
There weren't products on sale before 13/02/2020, or they're technically more a drug than a food. That folks, is the FSA's validated list so far... purdy, innit!
And finally comes the enigma!
If you were doing an investigation into companies who've been validated by the FSA, here's one to scratch your chin to.
No lab reports that I can find, and all their product related post on LinkedIn have been edited. This ordinarily wouldn't be too much of an issue, until you get to the fact that they were founded less than one month before the 13/02/2020 'products on sale' deadline from the FSA.
I've said many times before, anyone in this industry that formed 5 seconds before a major deadline is worthy of scrutiny, because it suggests that, in this industry certainly, they knew something.
Now I might be wrong here, and 4MP might be 100% legitimate, so I would like to invite them as well as all other companies to get in contact if there's anything I've gotten incorrect, but if you do, please ensure you're able to provide the evidence you submitted to the FSA to verify your products.
And especially for CBDex if you are 4MP, the earliest product posts for that is only one year old so I'm obviously curious. There's two posts from a year ago, both marked as edited and they both offer the option to pre-order, which is then followed with a post stating CBDex been validated but was still offering the product on pre-order...
It's not actually until 3 months ago that 4MP posted that CBDex was now in stock, suggesting that this is another company like Pureis and Brains Botanicals in having products validated before they were actually on sale.
As for a connection to the MHRA, look at their main product range. There's no way they aren't made with a medicinal focus in mind.
So that's all of the validated companies
And I'm going to say first and foremost that it's been tough, I've never written so much on one topic in my life as I have since March of this year.
I'm looking at the industry journalist when I say that, I feel like I should bill them for doing their work. I mean seriously, I've had to take time out of my own business concerns because the bigger concerns of Novel Foods was overriding my ability to focus on anything else.
It really must take a special type of person who can sit back, as a reporter, whilst watching the seriously questionable events and activities that surround CBD Novel Foods take place and not lift a pen... my dyslexia and I would like to thank you for your inaction!
So let's now explore the connection between the validated companies and the MHRA!
Here's a response from an FOI request to the MHRA, in which they state 222 companies have been enforced against between 2017-2021.
All of those companies were chastised for making medicinal claims on supplemental products, but you will find that most companies who have been validated have some sort of medicinal trial going on, and all are making claims that any other company wouldn't be allowed to make.
Here's a few to show you what I mean:
Bod Healthcare: Long Covid
Brains Bioceuticals: Opioid Addiction
Pureis: Synthetic cannabinoids (pharmaceutical product!)
Cannaray: Moving into medical cannabis sector
cbdMD: Research partnership with the University of Mississippi
Charlotte's Web: Medical trials with Harvard University
Further to this, some of these companies have a focus on pet products, and some are endorsing charities that have a medicinal focus. How many of the 99.31% of companies would get away with things like that?
All of a sudden, 'awaiting evidence' is only one problem that a lot of companies have to consider. What's worse is that I've warned so many people that the MHRA would be back, but few if any listened. That being said, I didn't know how right I would be, and I never envisaged them being as involved as they seem to be now.
And that leads right up to: what 'is' Novel Foods?
Basically, it's someone finishing what the MHRA couldn't in 2016, it's about redefining CBD as a pure medicinal compound by allowing the FSA to compromise the validity of whole plant products whilst they deny that they're doing so. Not just in anyway though, this is a cold and calculated move, designed to squeeze everyone out by insisting on a marketplace that is driven with pharma-grade products that the consumer doesn't really want, isolated and/or synthetic in construct.
Want a randomly thrown in fact to help you see this move? You know how white labelled products still needed to be tied into a Novel Foods application because they are classed as brand new products simply by having a different label? That my friends, comes from the pharmaceutical world, and NOT the food world!
Further to this...
Who does the transfer of power over cannabis from the HO to the MHRA suit the most, I mean, it's all about following the money trail, right?
You've guessed it, it's those pesky rogues who own the plant in all but name, GW/Jazz Pharmaceuticals.
Why GW? purely and simply because they make the rules, and it's not just in the food supplemental world either. In fact, if GW didn't grow Skunk #1 as well as genetic variables of the strain, politicians wouldn't be telling us all that a strain that was from the 90's which barely topped 20% THC is worse than the modern strains that can exceed 30% THC.
That's the same with Novel Foods, the FSA can't be 'controlled' to the point of effectively policing GW's interests with controlled cannabinoids, but the MHRA can, which is why they 'need' to have control of cannabis in line with the vision of The TIGRR report, so that the UK can become a global leader when it comes to medicinal CBD and cannabinoid products.
Medicinal... it doesn't sound like there's an inclusion for a supplemental industry, which in the UK could become a billion pound industry within the next two years, if there wasn't the uncertainty around Novel Foods that is. And don't let the validated companies fool you, because they are all playing by GW's and the MHRA's rules!
So, I'm scared you lot are getting bored of me bringing them up, but I feel I've given you a different dynamic to consider here, and I have proof beyond their 16 lab reports to show they are trying to influence the hemp and CBD supplemental industry!
Remember the Centre for Toxicity (COT) giving guidance to the FSA that was based around those 16 GW lab reports? So what if I told you GW were overseeing those meetings that decided their lab reports for pharmaceutical grade CBD were appropriate to be used to govern the requirements for Novel Foods, which ultimately restricted an entire industry to protect their interests?
Let's up the ante a bit, what would it mean to you if I told you GW became more active in protecting their interest in December of 2016, just after the MHRA admitted defeat from trying to redefine CBD as a purely medicinal compound?
Ok, what I'm about to show you is GW diminishing, or compromising the validity of food, by being part of meetings that are deliberately designed to redefine CBD from a food, to a medicine.
First, you need to see the timeline between GW and Reading University, which you can find here.
Advisory Council on the Misuse of Drugs Report on Phytocannabinoids addressed to Sarah Newton MP. Professor Ben Whalley (Director for research for GW) was the Chair of the Phytocannabinoids Working Group and Professor of Neuropharmacology, University of Reading. In the same document, a special thanks was given to Professor Gary Stephens and Professor Claire Williams (both Reading University, and both have connections to GW).
July 2019: COT Member Dr Gunther Kuhnle was present for this meeting and did not declare to the committee any interests with Reading University, despite sect 5 in the minutes for the meeting discussing an "Scoping paper for the potential adverse effects of CBD products" Dr Stella Cochrane and Dr Natalie Thatcher declared that their employers,
Unilever and Mondelez International, respectively, have an interest in using
cannabidiol (CBD) in their food products. This was considered to be a non-personal
specific interest and they were able to contribute to the discussion.
Jan 2020 Two representatives from GW Pharmaceuticals were present as observers. Dr Gunther Kuhnle was present for this meeting and did not declare any interests despite item 5 of their meeting being about "Update on CBD-additional data".
Dr Stella Cochrane and Dr Natalie Thatcher declared indirect personal
interests as their employers were interested in CBD as a potential food ingredient.
May 2020 Dr Gunther Kuhnle was present and didn't declare to the committee any interests despite the topic matters including "Potential risks from use of topically applied CBD-containing cosmetic products"
December 2020 No interests were declared by Dr Gunther Kuhnle, despite item 9 " Potential adverse effects associated with exposure to cannabidiol (CBD) by inhalation." Dr Stella Cochrane and Dr Natalie Thatcher declared non-personal, specific
interests as their employers were interested in potentially developing CBD containing
Dr Gunther Kuhnle was present and did not declare interests. Item 6 of the meeting was "Update to the COT Position paper on the potential risk of CBD in CBD food products: additional text summarising committee discussions relating to dermal and inhalation exposure"
Further to this
GW Pharmaceuticals founder Geoffrey Guy given honorary degree from the
University of Reading on 7th July 2016.
GW Pharmaceuticals & Otsuka Pharmaceutical Co funded University of Reading research through £1 million pound grant, expanding on a previous research collaboration worth £500,000 pounds.
That sounds like conflicts that should have been declared by Dr Kuhnle, yet despite others declaring their interests, he chose to remain silent.
So what does all of this mean?
It means that there's been the potential for GW to have had a man on the inside for some time now. And take a look at the topics that are listed, doesn't it look like an evaluation of a drug or pharmaceutical product?
So there you have it
GW are everywhere - best mates with the HO, and they've managed to stamp their authority on the food sector with what could be viewed as undeclared operatives in high level meetings. What they are doing is trying to diminish your view of cannabis as a food, in favour of it being a medicine, which is where their pockets get fatter.
And if you want further proof of that, look below at the side effects from the pharmaceutical product that Hemp and CBD food supplemental products are being judged by!
This is one of the reasons why I keep telling people that this 'recreational vs medicinal' discussion is engineered - think about it, recreational is a form of ingestion, that hits the pockets of GW more that food supplements which has lower levels of controlled cannabinoids in them, and means there the potential for someone to feed their ECS more effectively and avoid associated conditions that result in a depleted ECS, some of which GW are patenting medicines for.
So in essence, GW's meddling in cannabis outside of the medicinal realm is designed to starve your ECS to the point of medicinal need.
Through 16 lab reports and undeclared interests with the FSA and HO, they are compromising the validity of hemp and CBD as a food, and as I've mention previously, compromising the validity of food is a food crime, and something the FSA claim to be quite focused on. It's even mentioned in their 5 year strategy plan (Page 8), which was released just days ago.
And there's several counts, certainly when it comes directly to the FSA, that I believe need to considered
Insisting that synthetic cannabinoids don't need to be labelled as such (Misrepresentation, Substitution)
Name one instance when a copy of a food stuff is better than the original? This diminishes the authenticity of natural CBD in the eye's of the industry as well as the consumer. It also shows the FSA endorsing Substitution in the eyes of the industry as a whole.
Not insisting on appropriate safety assessments on synthetic cannabinoid despite there being a need for them for natural cannabinoid products (Misrepresentation, Substitution)
Considering that there have been reported deaths from synthetic cannabinoid ingestion, not conducting these tests whilst also not insisting on separating synthetic and natural CBD through appropriate labelling concerns me. Allowing the sale of these products I believe is misrepresenting synthetic cannabinoid products by endorsing Substitution, which compromises the authenticity of natural hemp and CBD products.
Using 16 lab reports for isolated CBD to govern the requirements for wholeplant, and synthetic products (Misrepresentation, Substitution)
I feel I don't have to explain this point, other than the sentence itself points directly to a food crime being committed.
Document fraud and theft
There's a number of companies who don't seem to have jumped through the hoops that the FSA has given everyone else, and there's only one of two reasons for it. Either companies have lied in application, or the FSA have removed those hoops for the validated companies with the simple explanation of applications working on a case by case basis, which to be honest, sounds corrupt!
If it is the former, it's document fraud. If it's the latter, it's defrauding the industry, all of the companies who're 'awaiting evidence', and all of the companies who either closed or stopped product lines because of Novel Foods, though conflicting documents. Either way, both lead to the theft of market share through validated companies being allowed to sell products that according to FSA deadlines and rules, shouldn't be on shelves until they have been authorised BY the FSA.
I believe that criminal activity is being used to gently push CBD into a medicinal context, this brings The TIGRR report one step closer to reality and gives cannabis to the MHRA. But by doing that, the FSA are allowing one more food crime to occur, and that is by them further diminishing the validity of hemp based products as a food in favour of them being a medicine.
On that basis, I am now placing myself as an industry whistleblower!
And that's on top of launching a complaint to the FSA's own police force (NFCU) on the grounds of what I'm whistleblowing for, and that's that the FSA are breaking their own rules by allowing what is effectively a two tier system which gives those with access to MHRA accredited facilities the upper hand. That's not fair, especially when those validated companies in no way reflect the ones that built this industry, which is being loomed over by GW.
Allow me to formally go through the process
My name is Cefyn Jones, founder of The Hemp Hound Agency, and I am making a Public Interest Disclosure of wrongdoing by the FSA
The above information is within the public interest, because it shows the potential for corruption at government level which is being orchestrated by a company who has interests in monopolising their influence over cannabis outside of their focused industry.
I believe the intention is to starve people of cannabinoids as a whole, until their need is medicinal. Naturally, this has health implications for the over 6 million UK residents who already take CBD and other cannabinoids everyday.
I believe the above information to be true, I have been investigating this matter for some time now.
On top of the listed food crimes above, there is a cartel market that is developing with the FSA directly involved, which is instilling an anti-competitive atmosphere in the UK Hemp and CBD industry as a whole.
Further to this, there has been a breach of legal obligation by the FSA to the industry and the consumer, all of which is outlined above.
The danger to health and safety of any individual is apparent, not just in the attempt to starve peoples ECS to the point of medicinal access but also through the misrepresentation and substitution of synthetic cannabinoids, which are being passed through the Novel Foods process on the back of requirement designed for naturally sourced cannabinoids.
I firmly believe that Paul Tossall, the FSA board and Novel Foods section, as well as the ACNFP, COT, HO and GW/Jazz Pharmaceuticals, are complicit in these actions, and I firmly believe that Paul Tossall and the Novel Foods team are concealing data that shows wrongdoing by either his department, or the companies who currently have had products listed by the FSA.
These actions to my knowledge started in 2019, and are ongoing. There is further evidence supplied in the recommended article list which includes Pt. 1 of this article, as well as an article that contains correspondence between Paul Tossall and myself. I've also included an industry poll, conducted by The Hemp Hound Agency and shows there is serious concerns from the industry as a whole.
Now it's your turn, please share this article and help get the information out as much as you can. Let's make this a whistleblowing event that the FSA will never forget while I send it directly to the FSA, Paul Tossall and the NFCU.