Novel Food Collection

The European Novel Food (NF) application deadline for CBD products in the U.K. and E.U. is fast approaching. To comply, every company must submit an application for what amounts to the exact same thing, for each and every SKU.

The whole thing is odd as CBD has been in the human diet long before member nations even existed, and hempseed oil, which they knew contained CBD forever, is already an exempt NF thus so should be the CBD found in it. It’s a similar situation in the US, where hempseed oil is GRAS but not the CBD commonly found in it. However, an exemption would leave tens of millions of Euros in potential revenue for the associations and consultants on the table and level the playing field for all companies, big and small.

While I believe that lobbying, litigation, and a PR campaign is a better path, so many see it as a goldmine opportunity for them that it appears none of that will happen. That leaves you two options if you want to comply: pay them an unlimited amount of money for an unlimited amount of time, or submit it yourself. Not every company has millions to use to block their competition via NF status, so if you want to apply yourself here are a few free resources from the CannLib Collective. Why free, when everyone else is making beaucoup bucks? Because some of us want the Movement to progress more than we want to buy a yacht. We’re weird that way.

To apply you will need to prove that CBD (Cannabidiol) has been in the human diet in Europe before October 1997. Many of us have made that case many times over, dozens of examples. CBD is the main cannabinoid in hemp, and hempseed and oil have been in the human and animal diet for millennia. Short of extensive cleaning of the outside of the hempseed, the resin containing CBD (and THC) stuck to the shell gets into the food or oil. Thus, humans have been consuming CBD and lesser amounts of THC for a very long time, with no ill effects. I suspect that some of the benefits attributed to hempseed oil might even be from those trace cannabinoids.

Note that it is entirely possible and legal to have a NF-exempt food such as hempseed oil containing CBD which was not added, but is unavoidably and naturally present, thus not a NF. Also, if you sell only in your country, NF status is less an issue, depending on local regulators.

CBD in products is not a safety issue. The World Health Organization determined that pure CBD is “generally well tolerated with a good safety profile” and presents little risk of abuse or dependency potential, recreational use, or public health-related problems. Australia’s Therapeutic Goods Administration concluded that CBD “presents a good safety and tolerability profile at the low dose range of under 60mg/day.” United Kingdom’s Food Standards Agency determined that CBD products can be regulated and marketed as novel foods, provided they meet standards for safety and content, recommending a 70mg daily limit for healthy adults. And despite a notable increase in the use of these products, the number of adverse events reported to FDA continues to be remarkably low. No doubt regulators will counter that CBD was not in sufficiently-widespread use before 1997, but if CBD is a natural and unavoidable component of NF-exempt hempseed oil then that makes no sense.

If you’re short a few hundred thousand to a few million Euros and want to apply yourself, here are some documents to help you. It’s basically the same information the associations and consultants are using, except they are also doing a toxicology study on THC (not CBD), n=200. Time will tell if the Powers That Be will let you use that study also, or if they’ll require you to do your own redundant study.

Will this be required of the other 150+ cannabinoids? Time will tell, but it’s profoundly unfortunate that the associations rolled over on this so quickly and easily. The E.U. said “jump!” and they said “how high?” instead of pushing back on regulators opening gambit. That vastly degrades the potential political power of the industry, and eliminates a golden PR opportunity which otherwise would make every adult aware of CBD and half of them wanting to buy. I consider it a profoundly epic failure of leadership and vision, but a blank check in perpetuity is a heady incentive to not do the right thing. Never assume trade associations are working for consumers, patients, non-members or others in the larger industry or Movement. They all want to leverage government to create economic advantage for certain members. It’s called Regulatory Capture, and every trade group in every industry does it.

“We decide something, then put it in the room and wait for a while to see what happens. If there is no big shouting and no riots because most people do not understand what has been decided, then we go on – step by step until there is no going back.” Jean Claude Juncker in The Brussels Republic, “Der Spiegel,” December 27, 1999.

Documents on consumption of CBD prior to 1997 are included in this collection, as well as other documents providing context, the application process, and other aspects of NFs. The CannLib Novel Food Collection ( contains 66 PDFs, and is 87 megs zipped in size (94 megs unzipped). Most if not all are in the English language. The information here is for educational purposes only and is not to be considered financial or legal advice. There are no warranties whatsoever as to the legality, suitability, ownership, purpose, or accuracy of this information. This information is provided on an “as is,” “as available” basis without warranties of any kind, express or implied. Void where prohibited. Specifications subject to change without notice. All patents, trademarks, service marks, and copyrights are the property of their respective owners. If you don’t agree with the above please do not download it.

List of Known Cannabinoids

Here’s a list of Cannabinoids known as of June 2020. Such a list will always be growing, as new Cannabinoids are discovered and invented often. Thank you to Palms Island Products for compiling it. Version 1.0.

Generic CBD Company Forecasts

Here’s an Excel file with the model for 4 years of projections or forecasts for a business plan. It’s a generic CBD company including a grow, so change the values and dates to suit. It’s a fairly detailed one, and the product of working on these since 1982. By Richard Rose.

Terpene Content of Popular “Strains”

What gives Cannabis its smell and flavor? Terpenes, the aromatic and medicinal chemicals found in the trichomes of the plant, as many as 200. What makes one variety, or “strain” as it’s commonly called, different than another? The mix of those Terpenes create the characteristic flavor. That’s why Blue Dream smells and tastes different than Sour Diesel. Terpenes are considered Generally Recognized As Safe (GRAS) by the U.S. FDA, so they are legal to use in foods and beverages.

Using radar charts of Terpenes published by Confidence Analytics on Leafly, I keyed-in this table of popular varieties and their relative Terpene mix, or ratio. If one wanted to say make a hard candy or soda with the flavor of Northern Lights, one could mix either non-Cannabis or Cannabis Terpenes in the ratio of Humulene at 9.6%, ß-Caryophyllene at 19.6%, α-Pinene at 12.5%, Ocimene at 4.3%, Terpinolene at 14.2%, Myrcene at 23.1%, Linalool at 4.3%, and Limonene at 12.5%.

Note, the eight main terpenes found in most marijuana are listed below, but there are way more, as many as 192 more! Your formulation might need a little tweaking to get the smell or flavor just right, but this is a good start. Sodas, candies, perfumes, fresh and frozen desserts, room fresheners, all are possible for this application.

By Richard Rose. Download here the Excel file used to make this graph and table:

Hemp Oil Hustlers, A Project CBD Special Report on MMJA, HempMeds, and Kannaway

This is the report which created the “Hemp CBD is Chinese industrial waste” canard in 2014. I wrote at the time it was clearly a hit piece on RSHO by HempMeds, but didn’t know why. Once MMJA sued Project CBD, we found why: Project CBD had a financial interest in CBD company Care By Design and HempMeds and their RSHO was Care By Design’s biggest competitor. This report has since been scrubbed from the internet. Here’s the original.

Secrets of Music Theory Revealed, all 4 eBooks in 1 (98 pages + extras)

Secrets of the Guitar Fretboard Revealed (or 125 Ways to Play “Louie Louie” in C)” eBook (2005) by Richard Rose
You just know there’s got to be a system to the fretboard that ties together all the positions and scales. But what is it? That system is called “CAGED,” and it means you only have to learn 5 of each chord type instead of 11. Once you know CAGED, you’ll be able to play a simple 3-chord song like “Louie Louie” in 125 different ways. Guitar freaks in California’s Redwood Empire passed around this secret formula for generations. Now, for the first time it has been published, by one of their own. There are only 5 major chord types, each played in a different position on the neck and in a different way. Same with minor, and every other chord. Secrets of the Guitar Fretboard Revealed shows the 10 most popular chords in each of the 5 positions. Scales, exercises, explanations, and more. Uses: play a simple C-F-G progression 125 different ways, play close harmony like horn section lines, re-voice a harmony or progression when using a capo or changing key, play any chord in 5 different places and in 5 ways, move up and down the neck when playing rhythm, use the whole neck to play a chord progression or solo. Includes diagrams of 5 types of 10 different chords (M M7 7 m m7 + dim 9 11 13), tricks and progressions (basic and fancy), detailed fingering and patterns, technical exercises, Circle of 4ths, 5ths, 3rds (new!), practical advice. Much more.

Secrets of Chord Substitutions Revealed” eBook (2005), by Richard Rose
Chord subs are how you make a progression sound hip, cool, dissonant, melodic, different, or humorous. Useful for jazz players, composers and arrangers. Tired of writing or playing II-V-I or I-IV-V? I’ll show you 104 ways to do it differently. They are used in most styles of music, especially jazz, fusion, blues, pop, and show tunes. Great for teachers or players of any instrument, including guitar, bass, keys, piano, reeds, horns, winds, strings, vibes, as well as composers and arrangers. Table of Contents Chord Substitutions 7 General Rules for Chord Progressions Cadences Harmony 43 General Rules for Chord Substitutions The Rules Above in Chart Notation Flow Chart of 64 Chord Sub Progressions in the Key of C Table of the 64 Basic Chord Sub Progressions from the Chart Above Notes, Spelling and Pronunciations of 74 Chords Music By The Numbers Circle of Fourths, Fifths, and Thirds This eBook is not specific to the guitar. No reading of music or tab is necessary.

Secrets of Scales and Chords Revealed” eBook (2005), by Richard Rose
Scales are the lifeblood of music. Chords are made of them, and scales give you a roadmap to a solo. I will show you more scales than you knew existed, and even more chords. Includes: 74 Chords including note-spelling and pronunciations, 64 Chord Substitution Rules, 55 Scales and when to use them, 7 Modes, 20 Blues Progressions, Circle of Fifths, Fourths, and Thirds. Table of Contents: Chord Theory, 7 General Rules for Chord Progressions, Cadences, Harmony, The 10 Basic Chords, The 7 Modes, Intervals: the Space Between the Notes, 55 Scales in C, Notes and Spelling of 74 Different C Chords, Chart of 64 Chord Sub Progressions, Table of the 64 Basic Chord Subs, Pentatonic Scales, Linear and Diagonal Exercises, Music By The Numbers, Circle of Fourths, Fifths, and Thirds. This eBook is not specific to the guitar. No reading of music or tab is necessary.

Secrets of Jazz Arranging Revealed” ebook (2005), by Richard Rose
Jazz Arranging is complex and challenging to master. Arranging music for 4 or more voices or instruments has rules to make it easier and sound better. Learn those rules and much more with this eBook. Table of Contents: Chord Progression Rules, Scoring Simple 4-Way Harmonization, Chart of Unresolved Tensions, Additions to Four-Way Harmonization, Alternate Voicings, Four-Way Sax Spreads, Bass Writing in Two, Bass Writing in Four, Background Writing, Low Interval Limits, Drop Two, Available Tensions For Drop Two, Concerted Writing – Constant Coupling, Concerted Coupling – Variable Alto, Concerted Writing With Saxes Spread, Tutti Writing, Counterpoint Rules, Two-Part Counterpoint, First Species Three Part Counterpoint, First Species Chord Substitutions, Cadences, Harmony, Flow-chart of 104 Chord Substitutions, 74 Different “C” Chords, Exercises and Demonstrations, 26 pages. This eBook is not specific to the guitar, but reading of music is necessary.

Hemp Oil Hustlers

A Project CBD Special Report on
Medical Marijuana Inc., HempMeds & Kannaway
By Aaron Miguel Cantú
October 14, 2014, Updated November 4, 2014

A Project CBD Special Report on
Medical Marijuana Inc., HempMeds & Kannaway
By Aaron Miguel Cantú
October 14, 2014, Updated November 4, 2014

A hit piece on Project CBD’s secret affiliated company’s (Cannacraft/Care By Design; owned by Martin Lee’s wife Tiffany Devitt) biggest competitor. The source of the canard “Hemp CBD is Chinese industrial waste.” It resulted in a $100 million lawsuit against Project CBD.

To quote a former partner and founder of Project CBD, journalist Fred Gardner, in a public Facebook comment: “The word ‘unethical’ doesn’t begin to describe Millionaire Marty. With a secret ownership stake in Cannacraft, he turned Project CBD into a publicity operation pushing Care By Design and AbsoluXtracts. His wife Tiffany Devitt-Lee dropped the hyphenate to conceal the link to her ‘independent journalist’ hubby. He is the personification of the Fake Left. Shame on me for getting taken by him. He ripped off Pat McCartney, too, as Pat’s family will attest. I thought the stress of the rip-off contributed to Pat’s death of a heart attack at age 67.

Read more here: The Dark Side of Medical Marijuana’s Miracle Drug, and Why Project CBD Loses Motion to Dismiss $100 Million Lawsuit.

World’s. Worst. Laws.

Worlds Worst Laws for Hemp, by Richard Rose. 1 page. The Hemp Industries Association (HIA) is behind some of the worst hemp laws in the country, designed to block hemp while appearing to legalize it. Check it out.

The HempNut Book (2020)

This is the original version of the 2nd edition cookbook except without the recipes, but including a Glossary with 48 terms and full Bibliography with 514 references. It was what was sent to the publisher before it was edited to fit into 192 pages printed. I’m offering this version free as it’s a great reference book, with hempseed history, nutritional info, and more. By Richard Rose, 2020, 80 pages, PDF. FREE.

Cost of Goods Sold Analysis Model

A Cost of Goods Sold Analysis Model by Richard Rose. Excel file. For calculating total direct cost of goods of a product, including packaging, shipping, box, gross profit margins, suggested retail prices, etc. The values are useless to you, as the formulas are where the magic happens. Just add your products and data. FREE, $999 value.

Cash Flow Analysis Model

A Cash Flow Analysis Model by Richard Rose. Excel file. For forecasting cash flow for three years, also use it for P&L forecasting: sales less cost of goods sold less selling expenses less operating expenses shows you gross profit, net profit and net cash, and percentages. The values are useless to you, as the formulas are where the magic happens. Just add your products and data. FREE, $999 value.

The HempNut Cookbook (both editions)

Here’s a free download of my The HempNut Cookbook, both editions combined. 200 recipes, 180 pages, tons of original historical and nutritional information. Perhaps the first consumer mention of CBD (2000).

FDA Report on CBD to Congress

Report to the U.S. House Committee on Appropriations and the U.S. Senate Committee on Appropriations on Cannabidiol (CBD) by U.S. Food and Drug Administration.

On December 20, 2019, the Further Consolidated Appropriations Act, 2020 (P.L. 116-94), was enacted into law, which provided FDA with appropriations under Division B, the Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Act, 2020, for the fiscal year ending September 30, 2020. The accompanying Joint Explanatory Statement directed the Food and Drug Administration (FDA or the Agency) to report on Cannabidiol (CBD):

“Within 60 days of enactment of this Act, the FDA shall provide the Committees with a report regarding the agency’s progress toward obtaining and analyzing data to help determine a policy of enforcement discretion and the process in which CBD meeting the definition of hemp will be evaluated for use in products.”

In response to this directive, FDA prepared this report. 18 pages.

US Customs Laboratory Methods for THC (2000)

11 pages. Cut-off = 1 ppm THC, which is why DEA’s 2001 Interpretive Rule legalizing all Hemp products meant “‘no THC’ = 1 ppm”, thus HIA v DEA 1 and 2 were unnecessary and an intentional mis-reading of DEA’s Interpretive Rule, greatly hurting the industry. Yes, HIA asked for DEA’s opinion on the legality of hemp products, after due deliberation DEA decided to legalize all hemp products, then HIA sued DEA for it.

What Is Hemp? (lyrics)

1 page, by Richard Rose (with apologies to Tower of Power, the biggest baddest funkiest band ever straight outta Oakland)

New Product Label Checklist

1 page, by Richard Rose. Need a reminder of what goes on your food label? Use this to prevent costly mistakes, I did for years.

Trump’s Border Wall in Hempcrete

Excel file, by Richard Rose. Can Trump’s Wall be made of hemp? Why yes, yes it can! This is the original work tying the wall to hemp.

Forecasts for a 5-acre CBD Grow

Excel file, by Richard Rose. Want business plan forecasts for a small CBD farm? Here you go. This is the source of the popular 5-acre CBD model.

Cannabinoid Facts label

Excel file, by Richard Rose. Use this to express Cannabinoids and Terpenes on a label in a familiar format. Blow FDA’s collective mind.

Cannabinoid Facts

Hemp – Our Newest Crop

1 page, by Richard Rose. This is the flyer given to state Secretaries of Agriculture at their meeting in 2015.

Generic Weekly Financial Update Tool

Excel file, by Richard Rose. Use this tool to calculate standard financial ratios and metrics, and track them week-to-week. I used it for years to manage my fast-growing Inc 500 company.

New Product Info Grid

1 page, by Richard Rose. This is the tool I used for the 150 new products I introduced. It could help you too.