Comments to USP FCC Re: Hempseed

Victory Hemp Foods has asked everyone to comment on the United States Pharmacopeia Convention’s Monographs for Hemp Seed-Based Ingredients. From Victory:

“Call to Action: Submit Your Comments on the FCC Monographs for Hemp Seed-Based Ingredients

You can support moving the hemp grain industry forward by submitting your comments by September 30, 2021.

The Food Chemicals Codex (FCC) is a compendium of internationally recognized standards for the identity, purity, and quality of food ingredients. It features over 1,200 monographs, including food-grade chemicals, processing aids, food ingredients (such as vegetable oils, fructose, whey, and amino acids), flavoring agents, vitamins, and functional food ingredients (such as lycopene, olestra, and short chain fructooligosaccharides).

The comment period for The Food Chemicals Codex (FCC) monographs for hemp as a food ingredient is closing on Thursday, September 30th. We feel it’s important that these monographs accurately reflect hemp as a food ingredient. The better the information contained in these ingredient monographs the more legitimate hemp becomes as a food ingredient, so it is our responsibility as an industry to make sure these monographs are on point.

Victory Hemp’s Director of Research & Development, Ben Raymond, has prepared:
A brief overview of the FCC and monographs

Instructions demonstrating how to register for a free account to provide comments on the “Hemp Seed Oil” and “Hemp Seed Protein” monograph drafts.

Suggested comments for each monograph.

Next Steps:
Step 1: View the proposed monograph along with our proposed changes
Step 2: Go to the FCC’s website and publish your comments
The deadline to submit comments is September 30, 2021.”


Victory gives comments they want us to incorporate into our comments to FCC, but they still need a little more thought. Here’s my reply:

Comments – Hemp Seed Oil

“Hemp Seed” is planted, “Hempseed” is eaten. This long industry standard was the subject of a document to ASTM from me regarding this very nomenclature. Even Victory itself has used “hempseed” this way over 166 times on its own website.

“The oil is obtained via mechanical separation from the whole or parts of seeds using cold pressing. Hemp Seed Oil is clear, light green.” There are other methods to remove the lipids from the hempseed besides mechanical, but this standard eliminates them. Refined hempseed oil is not light green, nor should it be.

“Function” includes nutritional fortification.

“Packaging and storage” should include gas-flushing to displace oxygen.

“Heavy Metals by ICP-MS: Arsenic (1 mg/kg), Cadmium (1 mg/kg), Lead (1 mg/kg), Mercury (0.1 mg/kg)” These are far too liberal, except for Mercury. I suggest harmonizing with Health Canada limits, which are: Arsenic (0.14 μg “arsenic and its salts and derivatives”/kg bw), Cadmium (0.09 μg cadmium/kg bw), Lead (0.29 μg lead/kg bw), Mercury (0.29 μg “mercury and its salts and derivatives”/kg bw).

“Cannabinoids-THC” Canada is at 10 ppm whereas the USA is already 3,000, 300 times higher. I suggest leaving it at 3,000 ppm, and lobbying Canada to harmonize with the USA.

“Cannabinoids-CBD” At only 7.5 times greater than THC, many will fail because almost all hemp varieties are 20 times higher or more in CBD than THC. It’s ironic that the CBD limit will fail most, not the THC limit. If the THC limit is 10 ppm, then CBD needs to be at least 200 ppm.

Comments – Hemp Seed Protein

“Hemp Seed” is planted, “Hempseed” is eaten. This long industry standard was the subject of a document to ASTM from me regarding this very nomenclature. Even Victory itself has used “hempseed” this way over 166 times on its own website.

“The protein is obtained using a mechanical cleaning and cold-pressing process to separate the oil followed by milling and sifting to achieve the desired particle size.” There are other non-mechanical methods to accomplish this, but this standard eliminates them.

“Hemp Seed Protein is a fine, light-green powder.” Not all is green, pressing oil from shelled seed results in a cream-colored material.

“Function” includes coating agent, stabilizer, thickener, emulsifier, texturizer, and as a whipping protein.

“Heavy Metals by ICP-MS: Arsenic (1 mg/kg), Cadmium (1 mg/kg), Lead (1 mg/kg), Mercury (0.1 mg/kg)” These are far too liberal, except for Mercury. I suggest harmonizing with Health Canada limits, which are: Arsenic (0.14 μg “arsenic and its salts and derivatives”/kg bw), Cadmium (0.09 μg cadmium/kg bw), Lead (0.29 μg lead/kg bw), Mercury (0.29 μg “mercury and its salts and derivatives”/kg bw).

“Cannabinoids-THC” Canada is at 10 ppm whereas the USA is already 3,000, 300 times higher. I suggest leaving it at 3,000 ppm, and lobbying Canada to harmonize with the USA.

“Cannabinoids-CBD” At only 7.5 times greater than THC, many will fail because almost all hemp varieties are 20 times higher or more in CBD than THC. It’s ironic that the CBD limit will fail most, not the THC limit. If the THC limit is 10 ppm, then CBD needs to be at least 200 ppm.

“90% to 110% of labelled amount…” The current standard for Nutritional Facts is a 20% variance, not 10%.


Regulatory Capture is supposed to ease the burden on companies, it’s unusual when they seek to increase it instead. That usually happens when they have some advantage over the others, such as pushing for 0.0% THC because they have a 0.0% THC variety and the others don’t.

Read the post from Victory here: https://blog.victoryhempfoods.com/hemp-grain-industry

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