Industry thoughts and update
From The Hemp Hound Agency on the APPG of CBD report, the public disclosure complaint to the FSA, and a casual glance at who's doing what.
Well, it's been another long month of craziness and intrigue, and I'm not certain, but I think I've ruffled some feathers for calling out the questionable status of CBD products that have been validated by the FSA as part of the Novel Foods process.
Contrary to popular belief, my mission is not to make enemies, I'd rather be introducing people to their next avenue to adventure than pointing out what most people already know is wrong with Novel Foods. But today is update day, and there are some questions which need to be considered, so let's ponder them together.
Public Disclosure - Whistleblowing
Some of you might be aware that I've launched a public disclosure whistleblowing complaint about the Food Standards Agency (FSA), to the FSA. It focuses on the handling of Novel Foods for CBD products, how some companies seem to be validated against the rules that have been subjected upon the hemp and CBD industry as a whole, and that there is the potential for food crimes inside of the Novel Foods process.
The FSA should reply, if they choose to, by the 12th of August. However, the FSA have been notorious in their ability to deflect industry concerns, so I have backed up the complaint by submitting it to Food Standards Scotland (FSS), who should be replying around the 19th of August.
But there's something on the side lines that 'bugs' me...
And that involves what is happening in regards to Novel Foods for edible insects, which from a distance, seems to be about disrupting an industry, and there's one familiar name being flung about.
Now I've got to say this - I'm starting to think Paul Tossall loves upsetting people, and he seems to be doing a good job of it too!
I feel that I have to offer some advice though, Mystic Meg stylee - listening to the quiet voice inside might tell you why others outside are so vocal... or why the crickets sound angry.
Needless to say, there's something going on over there, and Horizon Edible Insects seem to be at the heart of asking questions. That being said, they're asking them to Paul Tossall, and we in the hemp and CBD world know that this tactic seldom bears any fruit, so I'll be keeping an eye on this situation to understand just how it unfolds.
You can too, and help as well. Click here to get a breakdown of what is happening in the world of edible insects and give Horizon a like for solidarities sake. If there is anything that crosses the divide, I will report back.
Whilst we wait for that and any reply to my industry whistleblowing...
I know that my articles are read by a fair few people, including by those who work for trade associations. So I have a simple question for them.
I've brought a lot of evidence to the table that shows the vast majority of validated products on the FSA's public list shouldn't be there, so where are you? The 'Big 3', why are you not using that information to highlight the flaws in Novel Foods? I don't care if you think I'm some sort of shouty activist, you cannot deny what has been put forward, so why am I, as are others, wondering if we need to poke you with a stick to get you to say something?
I can only imagine why they're silent
But their silence is concerning, see if I had created an application for Novel Foods and submitted it off the back of advice from a trade association to be mindful of the 1mg rule, or when my products were on sale by, I would expect them to ask questions if for some reason the vast majority of validated products happen to break the rules that they advised me to follow!
I'd be a stickler for that, and it just so happens that I have advised in that area, so I'm writing articles to challenge what everyone else can clearly see, but I don't run a trade association... interesting, don't you think?
Moving on to the APPG for CBD document that was release on the 26th of July
I had high hopes for this, but then I read it and my jaw dropped. It's certainly not what I was expecting, and there's quite a lot to it.
With every comprehensive document like this, you've got to look past the words, and towards the intent. It's like law, sometimes you've got to look at what it doesn't say you can't do, just as much as what it does say you can't do.
On the outside, it suggests a cannabis utopia in the UK. Over £4bn a year in domestic sales of recreational cannabis, with an extra £10+bn through cannabis tourism... which is nice and all, but what's that got to do with CBD, and how does this deal with Novel Foods?
I am going to say something now that I never thought I would hear myself say - adding a section for recreational cannabis in a document that was supposed to deal with CBD cheapens the intent. I say that as someone who will happily step up to anyone (with rizla) who thinks I can't make a decent spliff, so it's not a comment I make lightly.
It doesn't help with the medicinal cannabis section either, especially with where Novel Foods is now, and the recent TIGRR Report suggesting that there's a clear move to make the UK a global leader in medicinal CBD and cannabinoid based products.
This document actually has a hint of US politics as well!
I'm not saying that there's a US influence as such, even though if you look at those in the APPG itself there is a visible connection to a US company, but I am saying that it's a paper where other agendas have been added in. It's like presenting a Bill for improving something, whilst supplying an addendum with a blueprint to sabotage the Bill on the basis of vagueness.
but let's address 'that' elephant in the room!
Looking beyond the point that recreational cannabis is being included as a topic in a paper that was supposed to be focusing on CBD markets, is it right for this paper to assume what legal status should be awarded to cannabis for that recreational market to become a reality?
This is my problem - food supplemental products should observe appropriate food laws and guidelines, as should medicinal products with the respective legislation that governs their markets, but recreational... at the moment, any action with the plant is prohibited, so considering millions (Yes, millions) of people over the years have been arrested for consuming or cultivating cannabis, I personally feel that it's them as well as the wider consumer base who should be asked that question.
And I say that for 3 reasons
The members of the APPG claim to represent around 700 entities within the cannabis sector - I've smoked spliffs with more than 700 people, or consumers if you will, and most are torn between decriminalisation or descheduling.
That isn't meant to read as childish as it does, but I feel it highlights a valid point. I wouldn't like to guess how many people I've smoked weed with, but very few have directly mentioned legalisation as the way to go. Most say decriminalisation, and there's a growing call for descheduling as well, which is why I believe this question needs to be sorted out by referendum. Cannabis touches so many lives, and in this sense, they should all have their say.
Legalisation as such is not preferred because it doesn't deal with why the laws exist in the first place, it opens up the UK to big business rather than domestic talent, and most importantly, doesn't come with the right to grow at home.
Which is an absolute shame because there's some very talented growers in the UK who should be able to find a route into any fledgling recreational market without requiring the financial backing that comes from the existing Big-Canna companies. They should also have the right to grow at home, because at the end of the day, we're all feeding our own Endo-Cannabinoid Systems, and we shouldn't be held to ransom by market access.
Does a legalised market allow for people to question past convictions for crimes that involved cannabis is some way? I'd say no, because the law would have changed through lobbying rather than there being a question mark over the validity of the law itself, which would then raise a further question mark over previous convictions.
How many lives do you think have been disrupted because of being arrested for smoking a spliff? How many of you feel that lives shouldn't be affected for a choice that harms no-one other than the consumer themselves?
This is something I feel quite strongly about, and the laws of averages means I won't be the only one.
It's been projected that over 6 million people in the UK consume cannabis in some way, whether through CBD products, medicinal, or recreational cannabis. That's in the here and now, although I do believe that's a low ball number, but how many people in the UK do you think have consumed cannabis in the last 30 years? I would hazard a guess and say somewhere between 15 and 25 million, and possibly even more.
So how many lives do you think have been tarnished with a criminal record, just for smoking cannabis?
Since 2006, there's been 2,192,173 cannabis seizures in England and Wales alone, how many of them do you think were for less than an eighth (3.5 grams or £25 worth)?
That averages at 156,583.8 seizures per year, if that was the case all the way back to 1971 for the signing of the Misuse of Drugs Act, there would be the potential for over 7.8 million seizures in total
As for those who have been raided, how many do you think had less than 20 plants, weren't stealing electricity, weren't part of a county lines gang and at worse was guilty of supplying their own needs?
The illegal cannabis industry is very similar to how businesses in the UK contribute to the countries Gross Domestic Product (GDP), 90% or so comes from small hobby growers, where as the other 10% comes from the likes of organised crime. On that basis, I would hazard a guess and say about 7 million of those seizures would have had a detrimental effect on many people's lives, which held them back from a fulfilling career as a result of a blight on their criminal record... all because they chose to smoke a herb.
And that is an issue that must be addressed
As for the alleged 6 million users in the UK today - in itself, it represents just less than 10% of the UK population. but then we have polls which show an over 50% approval rating for a change in cannabis laws since 2019, some for legalisation and others for decriminalisation, but most importantly, that's a big enough figure to warrant a discussion on the merits of descheduling cannabis, decriminalising 'actions' with the plant, or legalising the use of the plant.
If you are fully aware of the history of cannabis prohibition, you'll understand why the latter will annoy a lot of people. However, the definitions of legalisation and decriminalisation seems to in the screenshot above seem to be skewed. Decriminalisation of cannabis means that you are no longer subjected to laws for an act involving the cultivation or consumption of cannabis, where as legalisation means the little man is priced out of jumping into new markets.
That's my concerns with the intent for a legalised recreational market
But even that doesn't detract from the fact that this document was supposed to be about CBD products and Novel Foods, and I wonder if this is a wasted opportunity.
I honestly feel that CBD and Novel Foods is the most pressing issue right now, and that the issue in question is hidden in between more glamorous topics. Of course there are the vultures circling around every aspect of cannabis, waiting for change to favour their interests, but the ones in the CBD world are ripping at the carcass as we speak. Medicinal cannabis in the UK can be sorted out with the stroke of a pen, if politicians wanted to, and a recreational market could exist with the same action. Farming too could have barriers removed to help the UK compete on a global level, but Novel Foods can't, because there's a wider mess to clean up after any paperwork is filled in.
Look, in an ideal world, it's an interesting document, but it's not an ideal world because there are politicians to go through, as well as civil servants like Paul Tossall, with a whooping great document that calls for wholesale change in regards to cannabis across the board at governmental level. Asking sarcastically of course, but what could possibly go wrong?
But despite what I've said
And concerns aside, this document does give me hope of movement with cannabis in some guise. I am aware that the group who authored it intend to show further down the line that the APPG itself is more inclusive of cannabis as a whole, and it's a bit hard to sneeze at an extra £10 billion in the coffers from recreational cannabis tourism considering the looming recession. Combining that with domestic sales and we're talking in excess of £15 billion a year, or just under 0.5% of the UK's GDP.
With medical cannabis sorted out, that contribution could be more than doubled, and with a derestricted framework for farming, the UK could compete in markets whose access to has been restricted until now by laws that are over 50 years old.
The fact is we've been going around in circles for years, decades even, and this document could break that cycle and lead towards change. So with that in mind, it will be interesting to chart its path through parliament.