From Import to Intoxicant: How China Exploited the Farm Bill “Loophole” and Helped Fuel America’s Synthetic THC Market

Here is an instant download of the free report From Import to Intoxicant: How China Exploited the Farm Bill “Loophole” and Helped Fuel America’s Synthetic THC Market [PDF, 23 pages, 8,947 words, author unknown].

“From Import to Intoxicant: How China Exploited the Farm Bill “Loophole” and Helped Fuel America’s Synthetic THC Market

Executive Summary

The 2018 Farm Bill legalized hemp with the intent of creating a new domestic agricultural industry for American farmers. However, when lawmakers removed hemp and cannabinoids derived from hemp from the Controlled Substances Act, they failed to establish any trade barriers or import restrictions. This key oversight left the nascent U.S. hemp industry completely exposed to international competition.

When the farm bill passed, other countries – most notably China – already possessed robust hemp industries with global distribution networks. As discussed in this paper, Chinese producers quickly adapted to serve U.S. markets, ramping up extraction processing, and exporting CBD at scale at prices 50-80% below domestic production costs. While U.S. farmers invested millions in hemp cultivation expecting a new cash crop, Chinese manufacturers were already shipping industrial quantities of 99% pure CBD isolate directly to American processors.

However, CBD imported from other countries goes through no testing, tracking, or approval, creating a dangerous health and safety risk to those who consume products made from imports. According to industry leaders and as discussed here, most of the CBD used to create synthetic THC such as delta-8 THC comes from imported, usually Chinese, CBD. There is even cause for concern that the CBD imported into the US is not derived from hemp at all, but rather synthetically produced and shipped as a “hemp” product.

U.S. hemp farmers experienced a devastating boom-and-bust cycle from which they have never recovered. After initial oversupply crashed domestic prices in 2019-2020, most farmers abandoned hemp cultivation, with production plummeting 71% by 2022. When demand for CBD resurged, driven in part by the explosive growth of the synthetic THC market, U.S. companies often turned not to American farmers but to readily available, low-cost imports from China and other countries. Domestic infrastructure had already collapsed, and was now unable to compete with far cheaper and accessible Chinese CBD. This isn’t to argue that Chinese hemp was the primary cause of the failure of U.S. agriculture to widely adopt hemp, but it is clear that China was in a strong position to capitalize when the U.S. market did not materialize, and now undercuts U.S. efforts to compete.

Industry participants reported heavy reliance on imported CBD inputs as the synthetic THC market took off, particularly from China, with one industry leader claiming that Chinese imports account for 70% of the CBD used to create synthetic THC products. Unfortunately the exact share is unknown due to the absence of adequate tracking data in the form of CBD-specific import codes. This imported CBD serves as the chemical foundation for a $2.8 billion synthetic THC industry,1 yet arrives without testing, documentation, or any regulatory oversight.

China’s track record with exported consumer products is deeply troubling. Previous contamination incidents – including melamine-tainted infant formula that killed six babies and hospitalized 54,000,2 lead-painted toys affecting millions of children,3 and contaminated heparin causing 81 deaths4 – show the significant public health risk of accepting unregulated Chinese imports into the consumer product chain in the U.S. Unlike state cannabis programs that test every batch for pesticides, heavy metals, and contaminants, Chinese CBD enters the U.S. with no safety screening.

The health and safety risks are severe and immediate. Untested CBD isolate potentially contaminated with heavy metals, pesticides, and industrial solvents is being chemically converted into synthetic THC products using acids and catalysts, creating unknown byproducts never evaluated for human safety. These products are sold in gas stations and online, marketed even to medical patients and other vulnerable populations, completely bypassing the comprehensive testing required in state-regulated cannabis markets. Emergency departments report increasing adverse events, yet without import tracking or product testing, the true scope  of exposure remains hidden.

The Farm Bill’s failure to anticipate international competition has created the worst possible outcome: an unregulated multi-billion dollar intoxicants industry dependent on imported chemical precursors of unknown origin and quality, operating outside both agricultural policy goals and public health frameworks. American farmers are at a huge disadvantage competing, American consumers are at risk, and American regulators cannot even track what enters the country, much less its safety profile. Until Congress addresses this loophole and establishes proper import controls and safety standards, millions of Americans will continue consuming potentially contaminated products – a preventable public health crisis hiding in plain sight.”

Read more at: https://therichardrosereport.com/how-china-helped-fuel-americas-synthetic-thc-market/

Shelling Equipment Package

Many of these are the tools I used in running my HempNut, Inc., which was the first shelled hempseed brand in North America, starting in 1996. Some of the financial tools were brought over from my days running Rella Good Cheese Company, #281 on the 1993 Inc. 500 list of fastest-growing small companies.

A few years later I started importing certified-organic whole hempseed from China, shelled it in Germany, and delivered in bulk to LA for packaging into HempNut brand shelled hempseed placed on thousands of store shelves in the U.S. and Canada.

That was the first global supply chain for hempseed as a food. I was paying 61% less than them for the seed, delivered to Germany for shelling. And since it takes 2.5 pounds of whole seed to get one shelled, the lower cost advantage was magnified. That allowed me to sell organic for below the Canadians’ production cost for conventional shelled hempseed, back around the millennium.

If you have a cost (you grow it) or price (you buy it) advantage for whole hempseed, leverage that 2.5 to your advantage. If you grow for fiber, the seed is “free.” So then grow for seed and get “free” fiber or vice-versa.

It’s all an accounting move anyway, which column on the ledger you realize your gains; at the end of the day all that matters is you end up with more money than you started!

Richard Rose, The Richard Rose Report/Hemp Food Association

ZIP file containing these 27 files, 95 megs, many are exclusive to The Richard Rose Report:

1998 Potential Food Applications for HempNut.pdf
1998 Seed Shelling in Europe Report.pdf
1999 HempNut Product Information.pdf
2000 HempNut Family Fact Sheet.pdf
2001 The HempNut Story.pdf
750Tseedvalue.png
ASTM D37.07.91 and Hempseed.pdf
Australia New Product Label and Claims Checklist.pdf
BucketElevator_PS_English_NV.pdf
Construction Design of High-Capacity Oilseed Huller-2022.pdf
Cost Of Goods Analysis.xls
Economics of Shelled Hempseed.pdf
FDA – HACCP.pdf
FDA Food Labeling Guide.pdf
Food Development With Hempseed.pdf
Generic Hemp Food Company Forecasts.xls
Gravity Separators Destoners_NV.pdf
HempNut Sheller.pdf
NorthValleyAg-Canada.pdf
Oil Equip Quote.pdf
Quote-StreckelShrader.pdf
Seedy! or How To Start A Hemp Food Business.pdf
Shelling Line Analysis.xls
ShellingEquipPix-NorthValley.pdf
The 3 HempNut Books 265pg.pdf
Zhengzhou Dehuller.pdf
!ReadMe.txt

Hemp Food Biz Startup Kit

Many of these are the tools I used in running Rella and HempNut, Inc. Rella was a fast-growing (950% in 5 years) company, #281 on the Inc. 500 in 1993. ZIP file, 46 megs in size.

File list:

1998 Potential Food Applications for HempNut.pdf
1999 Rella Good Broker Book.pdf
2000 HempNut Family Fact Sheet.pdf
2000 HempNut, Inc. Business Plan.pdf
2001 HempNut Inc Broker Meeting Agenda.pdf
2001 Trade Show Checklist.pdf
Aseptic Hemp Milk.pdf
Australia New Product Label and Claims Checklist.pdf
Cost Of Goods Analysis.xls
FDA – HACCP.pdf
FDA Food Labeling Guide.pdf
Financial Projections Template.xlsx
Food Development With Hempseed.pdf
Generic Hemp Food Company Forecasts.xls
Managing Expectations.pdf
New Product Info Grid.pdf
New Product Label Checklist.pdf
Pricing for Problem Customers.pdf
Pricing for Problem Customers.xls
Seedy! or How To Start A Hemp Food Business.pdf
Shelling Line Analysis.xls
Systemizing Your Operations for Fun and Profit.pdf
The 3 HempNut Books 265pg.pdf
Trade Promotion Ideas.pdf
Weekly Financial Tracking.xls
WholeHealthRemedies CBD.pdf
!ReadMe.txt

Generic Hemp Food Company Forecasts

Here’s a great tool for a hemp food start-up needing to write financial forecasts including cashflow, often for investors or the bank. It’s the one I used for HempNut, Inc. By Richard Rose, Excel file. 

The 3 HempNut Books

HempNutBOOKCover1e

All three HempNut books, The HempNut Health & Cookbook (2000, by Mars and Rose), The HempNut Cookbook (2004, by Mars and Rose, edited by Pirello), and The HempNut Book (2020, by Rose). Plus The HempNut Story, on the first brand to introduce shelled hempseed (“hempnut”) to North America. PDF, 265 pages.

Both editions of the cookbook combined, 200 recipes and tons of original historical and nutritional information.

The HempNut Cookbook

The first two are cookbooks and the last is a reference book, the original version of the second 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 the pages printed. A great reference book, with hempseed history, nutritional info, and more.

If you want a soft-cover copy of either the 1st edition (orange cover) or the 2nd edition (red cover) signed by Richard Rose, it’s $20 including U.S. postage. Just hit me up.

Seedy! or How To Start A Hemp Food Business

What happens when a prolific pioneering hemp entrepreneur retires and starts teaching for free?

Seedy! is what happens, revealing secrets from 44 years of innovation in the food industry.

Starting in 1980 Richard Rose invented, produced, and marketed dozens of products based on tofu, and was the only small or natural food company to be named the “Leading Innovators of 1986” by Food and Beverage Marketing magazine.

Then TofuRella cheese alternative was introduced, sales of which landed his firm on the Inc. 500 list of fastest growing companies in 1993.

But in 1994, Richard Rose proved how to make money on hemp by slightly pivoting his business from using tons of soybean to using tons of hempseed.

Working with the dozens of brokers and distributors that helped make America’s most-hated food (tofu) one of the fastest-growing products in the Reagan ’80s, in 1994 HempRella and Hempeh Burger were on the shelves in thousands of stores in just weeks.

Then in 1996, the same team introduced shelled hempseed to North America, as the HempNut brand. In just a few years dozens of competitors would appear, inspired to enter the hemp food industry.

It’s the business model still used today throughout the industry, the one which made seed for food 90% of Canadian hemp for decades. This “Hempreneur’s Manual” is great for any hemp, or even non-hemp, business startup. Tons of tips, advice, examples, and tools.

“I’ll show you how to start a hemp food business without land, equipment, or a factory, just like I did 30 years ago,” says Rose.

Discover the secrets of hemp, business, and life from her first business icon. Learn how to do well by doing good with hemp foods.

Seedy! How To Start A Hemp Food Business is 173 pages, 51,900 words, 200 images, thousands of links.

Cost: free. Value: priceless.

National Industrial Hemp Strategy (Canada)

Prepared for: Manitoba Agriculture, Food and Rural Initiative Agriculture and Agri-Food Canada. Contract Number: ARDI III B-27.

March 30th, 2008

Executive Summary

Growth of the Canadian Industrial Hemp Sector

The history of hemp cultivation is as old as the history of civilization. In North America, hemp was a crucial crop during the colonial period, and it continued to be produced right up to and through the Second World War. A combination of regulatory pressures and changing public perceptions around drug use led to the disappearance of domestic hemp cultivation in North America in the years following WW II.

In 1998, Canada joined the large international community of hemp producers by permitting the production of industrial hemp, under a carefully monitored regulatory process. While the growth of the Canadian industrial hemp sector over the past decade has been uneven and at times fraught with challenges, as would be expected from a fledgling industry, there is considerable cause for optimism:

• The market for hemp seed materials for human health, nutrition, and personal care applications is strong and growing. Market price for a drum of conventionally grown hemp oil is approximately $1600 Cdn, with organic hemp oil fetching in the neighbourhood of $2500 a drum (Spring 2008).

• A favourable court decision in 2004 re-opened the US market, which had been effectively closed in 2000 by the US Drug Enforcement Agency (DEA). This has allowed for substantial and rapid gains in US exports.

• Recently, there has been dramatic growth in Canadian industrial hemp exports, with the US being the primary importer. Hemp seed exports increased 300% from 2006 to 2007. Hemp oil exports were also impressive, increasing 85%. Hemp fibre exports increased 65%.

• The knowledge base being developed by producers and researchers is expanding rapidly, with experienced farmers now consistently producing good yields.

• There is an increasing base of experienced organic producers meeting the strong market pull for organic hemp products, some of whom are now achieving yields that rival conventional farming techniques.

• Acreage under cultivation, while still showing significant annual fluctuations, is now regarded as being on a strong upward trend.

While the growth of the Canadian hemp sector over the past decade has been driven by market demand for hemp seed products, hemp has a broad range of potential product applications. The three primary components of hemp – bast fibres, hurd, and seeds/oil – each have attributes that provide distinct competitive advantages in a multitude of food and health, fibre, oils, and personal care applications. As technologies for hemp processing become commercialized and mature, there is reason to anticipate market penetration by hemp based products in such applications as biocomposites (including bioplastics), textiles, and industrial oils.

Recognizing the need for concerted sector-wide approaches to overcoming roadblocks to expanded commercial production in the Canadian industrial hemp sector, Manitoba Agriculture, Food and Rural Initiatives (MAFRI), the Composites Innovation Centre (CIC) and the Canadian Hemp Trade Alliance (CHTA) have spearheaded the development of the first national industrial hemp strategy for Canada. Working with a broad cross-section of stakeholders representing producers, processors, researchers and research institutions, and the policy community, the goals of this National Industrial Hemp Strategy include:

• Aligning the value chain players towards common goals that will maintain the competing edge of the Canadian industrial hemp sector

• Defining coordinated actions that will open up access to new markets for both seeds and fibres, expanding the sector and increasing the farm gate income of producers

• Attracting more investment into R&D and commercialization in the hemp industry.

The National Industrial Hemp Strategy has defined the following vision and mission for the sector:

Vision
Canada is the global leader with respect to total hemp crop utilization offering solutions along the entire value chain.

Mission
To create an economically sustainable Canadian hemp industry, benefiting all stakeholders along the value chain and enhancing the nation’s health and natural environment.

Major Opportunities and Challenges

The process of developing the National Industrial Hemp Strategy, involving comprehensive consultation with Canadian hemp stakeholders, identified major opportunities and challenges for the industry, examining it in terms of three product categories: health and food (including personal care products), fibre and industrial oil applications, and breeding and production.

Health and Food – Opportunities

• Demographic and societal trends leading to increased interest in natural health products and “healthier for you” foods.

• Increasing recognition of the nutritional and health properties of hemp, including the presence of many different bioactive ingredients in hempseed that have shown promise in disease prevention and reduction.

• Emerging markets, such as pet foods and products, and gluten-free products.

• The rapidly expanding market for natural, organic personal care products.

Health and Food – Challenges

• Lack of clinical research specifically on the health benefits of hemp seed and oil.

• The need to educate the public about the reality of THC in hemp products.

• The Canadian regulatory environment for foods with health claims, both for marketing and for product approval, which is not as favorable or transparent as in other global jurisdictions.

• The need for research into hemp food formulations, required for uptake by mid to large size food companies.

• The need to achieve generally recognized as safe (GRAS) status for hemp with the US Federal Department of Agriculture.

• The lack of approval from the Canadian Food Inspection Agency for the use of hemp and hemp products in animal feed.

Fibre and Industrial Oil – Opportunities

• There is a world of new and emerging markets, driven by the increasing viability of substituting hemp-based bioproducts for petroleum-based products, based on emerging technology platforms and the increasing costs of fossil fuels. There are numerous short, medium and long term opportunities for hemp-based products to make significant inroads in these markets.

• Emerging processing technologies are unlocking new industrial applications. With domestic commercial processing of bast fibres expected to come online in 2009, a whole range of natural fibre applications are enabled. Similarly, new product applications are being brought to commercialization.

• There is increasing market demand for environmentally conscious products. Hemp has promising applications in a wide range of green building products, and the substitute of hemp-based products for fossil fuel-based products will deliver significant environmental benefits.

• With the market for hemp seed products expanding, there are increasing amounts of hemp fibre and hurd available for industrial purposes.

Fibre and Industrial Oil – Challenges

• There are a number of challenges relating to the nature and structure of the market for hemp, including EU subsidies. These subsidies distort the real market value and hence the nature of the market opportunity for hemp. Other market challenges include lack of access to risk capital and competition from imports of jute and sisal, and other natural fibres.

• The limited processing facilities in Canada pose a significant threat to the long term growth of the sector.

• Many government stakeholders have not yet demonstrated a significant commitment to hemp as a crop. As such, they are funding other “higher” profile products, and provincial agricultural departments may have other priorities, making funding more difficult to access for hemp.

• Potential issues with production and supply threaten the ability of the sector to grow rapidly in response to potential market demand.

Production and Breeding – Opportunities

• Significant benefits can be realized through modest continued investment in developing best management practices for industrial hemp.

• There are a number of opportunities to breed hemp for specific characteristics such as the introduction of a retting gene, increased water, less lignin, increased pectin and maximizing fibre. These activities will be aided by gene mapping and other activities.

• There are a number of emerging opportunities for Canada to export germplasm, with the international community looking at Canada for our hemp genetics. In the near term, breeding for the US market may afford significant opportunities, if current US prohibitions on industrial hemp cultivation were lifted.

• There is a potential opportunity to create and derive additional revenue for the production of hemp from green markets (e.g bioremediation, carbon credits).

Production and Breeding – Challenges

• Most manufacturers in North American are moving to use rotary combines. The use of rotary combining damages hemp fibre.

• There are issues in protecting the hemp cultivar, including the potential for cross contamination of cultivars.

• The cost and labour involved in testing and proving seeds.

Strategic Areas for Action

In order to capitalize on identified opportunities for the growth of the Canadian hemp sector, the following strategic areas for action were identified through the extensive stakeholder engagement undertaken in developing the National Industrial Hemp Strategy. Some of these strategic areas for action are common to all of the industrial hemp sub-sectors, while others are specific to a particular industrial hemp industry.

Common to All Platforms

• Work towards improving access to risk capital, including educational efforts targeting the sources of capital, and ensuring that successful projects are well publicized.

• Develop a more detailed understanding of domestic and export hemp markets.

• Continue to work with Health Canada vis-à-vis optimizing the regulatory regime to ensure required oversight while minimizing the cost to producers.

• Support efforts to incorporate sustainability criteria into Canadian policy, with the goal of realizing competitive advantages for hemp and other biomass based products as compared to fossil fuel-based products.

• Work to maintain access to the US markets, including maintaining a close watching brief on the US situation, the forging of alliances with key US industry stakeholders and other industrial hemp proponents

• Continue work on low THC breeding, and broad-based education campaigns as to the benefits and safety of industrial hemp.

• Develop multiple value propositions that make hemp attractive versus competing crops.

• Grow the national industrial hemp network, to establish a strong and unified national industry voice, and a body to act as proponent for many of the actions outlined here.

• Establish increased market stability through improved relationships between producers and processors more closely aligning supply and demand.

• Communication and marketing efforts targeted toward market acceptance from potential end-users of hemp products, including consumer awareness campaigns explaining the benefits, and assuring the public that it is in no way a source of illegal drugs. Industrial end-users will also need targeted campaigns to make them aware of the benefits offered by hemp feedstock.

• Ensure access to highly qualified people for industry stakeholders, involving the identification of required skill sets and collaboration with academia to meet identified industry needs.

• Work with the relevant links in the value chain to ensure required infrastructure (storage, availability of harvesting equipment, pre-processing capacity, and others) keeps pace with the growth of the industry.

Health and Food

• Work with the Canadian Food Inspection Agency (CFIA) to achieve regulatory approval for the incorporation of hemp nutrients into animal feed and treats.

• Research to fill the existing gaps in the knowledge of the health benefits of hemp. Credible evidence of health benefits will be needed to maintain and expand the market for hemp food and health products over the long term.

Fibre and Industrial Oil

• Develop commercial bast fibre processing in Canada. The lack of commercial scale bast fibre processing in Canada is a primary barrier to growth in this sector. Production of sufficient (commercial) quantities of high quality bast fibre and hurd is required to enable the development of downstream applications.

• Identify end-user interest in utilizing hemp as a component of their product. While the broad spectrum of potential industrial hemp products are increasingly understood, there is considerably less understanding of the potential industry receptor capacity interested in commercializing these products.

• Establish test methods of Canadian hemp fibre for specific product applications.

• Develop technologies and methodologies for the increasing variety of market applications.

• Develop fibre grading standards, which are an important component in providing hemp product manufacturers and downstream users of hemp fibre with the stability of supply and quality assurance that they require

• Develop a cost-effective oil processing system.

• Develop market applications for co-products of the hemp decortication process. While much of the attention is focused on hemp oil and bast fibres, it is imperative that valuable markets be developed for all co-products of hemp processing, including short fibres and hurd, hurd only, fines and dust, and seed meal (left after oil extraction).

Breeding and Production

The areas for strategic action in breeding and production are all oriented towards realizing increased yields per acre of hemp crops, optimized for desired applications. These areas include:

• Bioresource engineering, to address properties of hemp such as tough stems and growth that may reach several metres tall.

• Ensure that sufficient supplies of hemp seeds are available for a variety of cultivars, covering the full range of Canadian growing conditions.

• Optimize and develop cultivars for specific Canadian growing conditions.

• Continue the development of best management practices around hemp cultivation, including response of hemp to fertilization, seeding rate, row spacing, harvest management / improved practices, and retting.

• Promote Canadian-bred cultivars internationally to help carve a distinct niche for Canada in the global industrial hemp industry.

Table of Contents

Introduction 1
Why Industrial Hemp? 3

  1. Competitive Advantage in Food and Health 5
  2. Competitive Advantage in Fibre Markets 5
  3. Competitive Advantage in Industrial Oil applications 6
  4. Competitive Advantage in Personal Care markets 6
    Profile of the Industry 9
    Definition 9
    Industrial Uses for Hemp 9
    History of Hemp Cultivation 11
    International Context for Industrial Hemp 11
    US Context for Industrial Hemp 14
    The Canadian Industrial Hemp Sector 16
    Production 18
    Acreage under Cultivation 20
    Economics of Production 21
    Markets 22
    Objectives 28
    Vision and Goal for the Canadian Industrial Hemp Sector 28
    Framework for Action 28
    Summary of Key Strategic Areas for Action 29
    I Health and Food (including personal care products) 36
    Overview 36
    Health and Food Market Opportunities for Hemp 42
    1.0 Market Opportunities – Short Term 43
    2.0 Medium Term Opportunities 46
    3.0 Long Term Opportunities 48
    The Market 49
    The Consumer 56
    Regulatory Issues 57
    Hemp Oil and Skin Care 60
    II Fibre and Oil for Industrial Applications 64
    Overview 64
    Opportunities for the Use of Fibre and Oil 64
    SWOT Analysis 68
    Specific activities to address the opportunities/challenges 77
    III Production and Breeding 81
    Overview 81
    SWOT Analysis 81
    Strengths 82
    Weaknesses 84
    Opportunities 85
    Threats / Challenges 86
    Specific Activities to Address these Opportunities / Challenges 87
    Communications Strategy 91
    Elements of a Successful Communications Strategy 91
    Core Audiences 91
    Core Communications Activities and Tools 96
    Optional Communications Activities and Tools 96
    Appendix A – Literature Review of Nutritional Properties of Hemp 100
    Appendix B – Health and Food Market Assessment 148
    Appendix C – Literature Review of Hemp for Industrial Applications 253
    Appendix D – Literature Review of the Agronomics of Industrial Hemp: Seeding and Harvesting 284

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 (NovelFood.zip) 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.

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:

Secrets of Music Theory Revealed, all 4 eBooks in 1 (98 pages + extras) v4

“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.

All are copyright Richard Rose 2004-2024. Yeah, they really are that old!

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.

Hemp Production eGuide

Hemp Production eGuide, by the Canadian Hemp Trade Alliance (© 2019 CHTA). 275 pages, compiled by Richard Rose. As found at http://www.hemptrade.ca/eguide/.

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.

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, years ago.

Trump’s Border Wall in Hempcrete

Excel file, by Richard Rose. Could Trump’s Wall fantasy have been made of hemp? Why yes, yes it could have been! 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.

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  in the ’90s.

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.

Hempseed Shelling Analysis

Download Hempseed Shelling Analysis, an Excel file by Richard Rose. Use to calculate number of acres or tons of whole hempseed (grain) needed to run a shelling line at 1 shift/day annually, and annual revenue.

Model State Hemp Regs

Download Model State Hemp Regulations, per 2018 Farm Bill. 7 pages, by Richard Rose