Updating the the tens of thousands of PDFs in CannLib, I came across this excellent article on the current hemp THC market in the U.S. from last November, laying bare many of the policy and public health concerns I’ve also had with synthesizing THC and other intoxicating hemp cannabinoids ostensibly from hemp-sourced CBD, which Whitney Economics says is twice as large as the regulated marijuana market in the U.S.

When pressed, the industry responded to many of us not with data proving purity and safety, but with gaslighting, brigading, and miscellaneous lying.

Clearly, we need a bifurcation of the hemp industry into medicinal cannabinoids as completely separate from seed, stalks, and roots both legally and operationally. They require different genetics, agronomy, agricultural practices, equipment, post-harvest handling, processing, and product applications, therefore different regulations. From oversight to fees to stigma, industrial hemp no longer requires the fear-based restrictions of yore, once medicinal cannabinoids are properly regulated.

However, this document has no attribution whatsoever anywhere as to the identity of the creator of it, not even in the 23-page PDF’s Properties. So if you wrote this, please let me know so that I can properly attribute it to you! See at the bottom for free instand download.

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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.

Data and Sources

The precise scale of CBD isolate imports into the United States is difficult to pinpoint due to limitations in federal trade import tracking systems. The Harmonized Tariff Schedule (HTS) lacks specific codes for CBD isolate and distillate. While CBP classified pure CBD under HTSUS 2907.29.9000 (“Polyphenols; phenol-alcohols—Other”) in 2020, this broad category includes numerous unrelated chemicals, making it impossible to isolate CBD import volumes from official trade data.

Throughout the industry, sources repeatedly claim that China supplies “70%” of both global hemp production and U.S. CBD markets. This figure appeared in a prominent blog⁵ which referenced news coverage, yet the original ABC story does not source its claim, making it hard to tell the accuracy of the claim.⁶ However, some sources likewise claim that China supplies anywhere from a third to as much as 70% of the global trade in hemp,⁷ and it is possible these global and U.S. figures are being conflated in reporting. The most reliable estimate of this latter figure appears to be from the USDA in a 2019 report which claimed China produced “nearly half” or about 50% of global hemp supply, but it is unclear how much of that supply is CBD.⁸

It is this uncertainty in imports that is particularly troubling. In reality, we have no real way to know how much Chinese CBD is entering the U.S. to be used to produce synthetic THC products.

This stands in stark contrast to state cannabis programs, where “seed-to-sale tracking” documents every gram of biomass from cultivation through retail sale, and products made from that biomass are all tested before reaching consumers. While cannabis regulators can often trace a potentially contaminated product on a store shelf back to the specific batch of plants that produced the THC, we could not even tell what country produced the CBD converted into synthetic THC products and sold nationwide, much less whether or not it was tested.

Why Unregulated Chinese Imports Are Troubling

The uncertainty surrounding CBD isolate sourcing raises serious public health concerns, particularly given China’s documented history of contamination incidents in unregulated consumer products. When imported ingredients enter the U.S. market without adequate oversight, it places consumers at risk.

In 2008, melamine-contaminated milk products from China killed six infants and hospitalized 54,000 others. Chinese suppliers had deliberately added melamine to infant formula and milk products to artificially boost apparent protein content in standard tests that measured nitrogen rather than actual protein.⁹ The contamination spread globally before detection, affecting products in 47 countries.

In 2007-2008, contaminated heparin imported from China was responsible for 240 deaths and hundreds of severe allergic reactions due to use of oversulfated chondroitin sulfate, a cheaper substitute that mimicked heparin in standard quality tests.¹⁰ FDA investigations identified the Chinese facility producing the active pharmaceutical ingredient and determined that it had never been inspected by Chinese regulators.¹¹

That same year, Chinese-made products accounted for 60% of all U.S. consumer product recalls, including lead-contaminated toys affecting millions of children, antibiotic-laced seafood, and pet food containing melamine that killed thousands of pets.¹² In 2019, an FDA report even found that 89% of active pharmaceutical ingredients used in the highly regulated U.S. pharmaceutical market were manufactured overseas, with China and India supplying the majority – yet FDA inspections of foreign facilities lagged far behind domestic oversight.¹³

Unlike state cannabis programs or the U.S. pharmaceutical industry, CBD isolate can enter the marketplace as a “hemp extract” with minimal scrutiny. Laboratory testing, when performed, typically checks only for CBD purity percentage and THC content – not for contaminants such as heavy metals, residual solvents, biological contaminants, or synthetic byproducts from the extraction process. Most concerning, once in the U.S., the CBD is then chemically converted through another series of steps (also unregulated in many cases), to create semi-synthetic THC products, potentially concentrating contaminants or creating new, possibly toxic compounds.

Without mandatory testing requirements or supply chain transparency, the millions of Americans consuming hemp-derived THC products have no assurance about the safety or purity of the underlying CBD isolate.

Import Trends

The precise scale of CBD isolate imports into the United States remains unknown due to critical gaps in federal tracking systems. The Harmonized Tariff Schedule lacks specific codes for CBD isolate and distillate. While U.S. Customs classified pure CBD under HTSUS 2907.29.9000 (“Polyphenols; phenol-alcohols—Other”) in 2020, this broad category includes numerous unrelated chemicals, making it impossible to isolate CBD import volumes from official trade data.¹⁴

Available data shows U.S. hemp imports (including raw hemp and non-CBD products) increased modestly from $79.8 million in 2018 to $87.8 million by 2020.¹⁵ However, these figures encompass all hemp products—fiber, seed, oil, and extracts—preventing any meaningful analysis of CBD isolate specifically. The increase could reflect normal market fluctuations, inflation, changes in non-CBD hemp trade, or growth in CBD imports; the data simply does not allow us to determine which factors are responsible.

What we do know is concerning: despite the Farm Bill’s intent to support U.S. farmers, no restrictions were placed on importing hemp-derived cannabinoids. By 2022, U.S. hemp production had plummeted 71% by value,¹⁶ while imports remained unrestricted. Industry participants consistently report that imported CBD isolate — particularly from China — has become a major supply source for synthetic THC production, with some claiming foreign sources provide the majority of CBD inputs.¹⁷

This data gap itself represents a significant regulatory failure. When a multi-billion dollar synthetic THC industry relies on imported chemical precursors of unknown origin and quality, the inability to track these imports becomes a public health blind spot.

Drivers of Import Growth

Multiple factors have driven the rise in raw Chinese CBD isolate imports since 2019:

• Competitive Pricing & Oversupply: The wholesale price of US-grown CBD isolate has collapsed by over 90% since 2019,¹⁸ from around $5,000–$6,000 per kg in early 2019 to well under $1,000/kg in recent years. While U.S. overproduction of hemp was an initial cause, the influx of low-cost imports amplified the glut. Large-scale producers in China with its lower costs have been able to export CBD isolate at rock-bottom prices, undercutting U.S. hemp extractors. By 2020–2021, American CBD manufacturers reported being undercut by foreign isolate priced far below domestic production costs, leading to a “commodity price free fall”.^19 20  By this point, Chinese companies were “flooding the market” with cheap CBD extracts, squeezing U.S. farmers’ and processors’ profit margins.²¹

Many believe that China was by then the single largest producer of precursors used in the U.S. synthetic cannabinoid sector. Unfortunately, exact figures are unavailable due to the limitations of HTS code tracking and lack of disclosure by private processors. However, industry sources suggest that the majority of U.S. CBD inputs were sourced overseas by this point, with some estimates placing China’s share as high as 60–70%.²² This dynamic meant that even as U.S. farmers scaled back, imported CBD isolate remained abundant and inexpensive, preventing any shortage, but also keeping U.S. farmers from competing.

High Value Density: Raw CBD isolate is a lightweight, high-value product, making it ideal for international trade. Logistics experts pointed out that shipping hemp biomass or crude oil is far less economical (very bulky for the value) compared to isolate. “CBD isolate is 50× more price-dense than biomass,” one industry blog observed.²³ This economic fact has encouraged manufacturers to treat CBD imports as an alternative to domestically produced CBD – a small shipment (in powder or crystal form) that is worth tens of thousands of dollars in CBD can be flown or shipped cheaply. Thus, hemp companies have found it cost-effective to import isolate rather than raw plant material, especially when foreign isolate prices dipped so low. By contrast, “non-CBD” hemp goods like fiber bales or seed have higher shipping costs per dollar value, which naturally limits their import growth more than that of extracts.

• Domestic Production Contraction: The U.S. hemp industry’s boom-to-bust cycle also influenced import patterns. After the 2019 planting boom led to excess inventory, many U.S. hemp farmers exited the CBD market. Hemp acreage for CBD plunged. (USDA reports show licensed hemp acreage fell more than 50% from 2019 to 2021)²⁴ Processing infrastructure also stagnated or shut down in the face of oversupply.²⁵ Paradoxically, this contraction made U.S. buyers more reliant on imports: as domestic supplies of fresh, high-quality CBD isolate dried up, or producers went bankrupt, other stable overseas sources were easily available. In short, the lack of a strong domestic supply chain after the bust and lack of restrictions on imports made cheap imports an attractive alternative for formulators needing CBD inputs.

The End Use of Imported CBD Isolate: Additional Fuel for the Synthetic THC Boom

The surge in imported CBD isolate into the United States likely helped fuel a largely unregulated industry in synthetic intoxicants. Since the passage of the 2018 Farm Bill, tens of tons of CBD isolate have been chemically converted into delta-8 THC, delta-10 THC,“hemp-derived” delta-9 THC, and similar compounds.²⁶ These products are synthesized through isomerization, a chemical process that transforms non-intoxicating CBD into psychoactive analogs, which are then infused into vapes, edibles, and other consumer formats.

From 2019 through 2020, the vast majority of cannabinoid hemp production in the U.S. targeted the wellness market. Estimates from industry analysts indicate that in 2019, over 95% of hemp grown for cannabinoids was used for CBD products such as tinctures, capsules, and topicals.²⁷ Delta-8 THC and its analogs were virtually absent from the market. That changed rapidly beginning in 2021, when CBD prices collapsed due to oversupply. It is believed that during this time, processors began redirecting isolate into higher-margin intoxicants.²⁸ At that time, delta-8 distillate was commanding nearly triple the wholesale price of CBD isolate,²⁹ and sales of delta-8 products began rising sharply across both regulated and unregulated retail channels.

Delta‑8 THC and other hemp‑derived intoxicants were virtually absent from the market through 2020. Starting in 2021, following a steep collapse in CBD prices due to oversupply, processors redirected CBD isolate into higher‑margin psychoactive products. Brightfield Group data show that by 2023, delta‑8 THC alone accounted for approximately $1.2 billion in retail sales (~44% of the hemp‑derived cannabinoid market) – up from negligible volume in prior years, confirming a rapid shift in production and pricing dynamics.³⁰ By 2023, hemp-derived intoxicants – including delta-8, THCa flower, and other semi-synthetic products – generated $2.8 billion in retail revenue in the U.S., compared to $3.8 billion from traditional CBD products,^31 32   In other words, synthetic THC analogs now make up slightly less than half the total retail cannabinoid market by value.

It is very likely that a substantial share of the CBD used in these processes is imported from abroad, particularly from China and India. As mentioned, it is difficult to quantify the volume or percentage of CBD imported to import tracking limitations, however industry stakeholders believe it is a meaningful portion of the market.³³

Imported CBD isolate from low-cost sources undercuts domestic pricing, and the most lucrative use for CBD in the U.S. market is now the production of synthetic THC compounds. The result is a bifurcated supply chain: one in which foreign bulk CBD is the chemical foundation for an unregulated, multi-billion-dollar drug market operating parallel to – and in competition with – state-regulated cannabis and American produced hemp.

Cannabis Licensee Standards in the U.S. Sidestepped

In stark contrast to the import of CBD and conversion into synthetic THC, state-regulated cannabis programs in the United States operate under comprehensive tracking and testing requirements that ensure product safety from cultivation through retail sale. These standards, developed over decades of medical and adult-use marijuana regulation, represent the gold standard for cannabinoid product oversight – yet none apply to imported CBD isolate used in synthetic THC production.

Seed-to-Sale Tracking and Provenance

In regulated cannabis markets, every plant receives a unique identifier at cultivation, creating an unbroken chain of custody through harvest, processing, manufacturing, and retail sale. States require licensed operators to use track-and-trace systems that document every gram of biomass and resulting products.³⁴ This granular tracking enables regulators to:

• Verify that all products originate from licensed, inspected facilities
• • Trace contaminated products back to specific plants or processing batches
• • Execute targeted recalls when safety issues arise
• • Prevent diversion to illicit markets
• Ensure tax compliance and regulatory oversight at each stage of production

Cultivators must document pesticide applications, nutrient programs, water sources, and harvesting procedures. Processors must log extraction methods, solvents used, batch yields, and waste disposal. Manufacturers must record all ingredients, production dates, and quality control measures. Comprehensive documentation creates accountability that simply does not exist for imported cannabinoids under the farm bill regimen.

Mandatory Testing Requirements

State cannabis programs mandate testing for a wide range of potential contaminants before products can be sold. While specific requirements vary by state, most require testing for:³⁵

• Pesticides: Typically screening for 60-100 specific compounds, with action levels in parts per billion
• Heavy metals: Including lead, arsenic, cadmium, and mercury, with limits often stricter than FDA standards for food
• Microbials: Testing for E. coli, Salmonella, Aspergillus, and other pathogens
• Mycotoxins: Screening for aflatoxins and ochratoxins produced by mold
• Residual solvents: Ensuring extraction chemicals like butane, propane, or ethanol are below safe limits
• Foreign matter: Visual inspection for mold, mildew, insects, hair, and other contaminants

Products that fail any test must be destroyed or remediated under regulatory supervision. The testing laboratory must be state-licensed, often ISO-accredited, and always independent from the producer.

Contamination Risks in Unregulated Hemp and CBD Production

Hemp’s nature as a bioaccumulator makes contamination particularly concerning. The plant readily absorbs heavy metals, pesticides, and other toxins from soil and water – a useful trait for environmental remediation but dangerous when the biomass enters human consumption.³⁶

Without regulatory oversight, imported CBD isolate may contain:

• Heavy metals from industrial pollution or naturally occurring soil deposits, particularly in regions with minimal environmental regulation
• Banned pesticides not approved for use on consumable crops, including organochlorines and organophosphates that persist in extracted concentrates
• • Processing contaminants from extraction and purification, including residual acids, bases, and catalysts used in isomerization
• • Synthetic byproducts from incomplete reactions or side reactions during CBD isolation or conversion to THC analogs
• Biological contaminants from improper drying, storage, or handling, including mycotoxins that concentrate during extraction

It should be noted that the chemical conversion process used to transform CBD into delta-8 THC introduces the potential for additional risks. Manufacturers typically use strong acids like sulfuric acid or hydrochloric acid as catalysts, and incomplete reactions can leave residual reagents or create novel compounds not present in natural cannabis.³⁷ A 2022 study found that delta-8 THC products contained numerous unidentified compounds, likely synthetic byproducts of the conversion process.³⁸

The Regulatory Void

There are no federal standards for imported CBD isolate or the synthetic THC products made from it. Unlike state-licensed cannabis businesses that face regular inspections, mandatory testing, and strict compliance requirements, importers of CBD isolate operate with virtually no oversight. The products enter the country with minimal documentation, can undergo chemical conversion in unlicensed facilities, and reach consumers without any of the safety testing required in regulated cannabis markets in which all cultivation takes place domestically.

This regulatory gap means that hemp-derived THC products sold in gas stations and online are known to contain contaminants that would trigger immediate recalls in state-regulated cannabis markets. Consumers purchasing these products have no assurance about pesticide residues, heavy metal content, or the presence of synthetic byproducts.

Foreign CBD Isolate Supply Chain and the U.S. Hemp Intoxicants Market

The synthetic THC market in the United States is aided by lack of federal standards and imported CBD isolate. Even if U.S. acreage is capable of producing enough biomass to supply domestic processors, the economic and logistical reality is starkly different. Following the 2020 price collapse, much of the U.S. infrastructure for refining high-purity CBD isolate at scale was idled or dismantled. While some processors remain operational, the majority of high-volume, low-cost isolate appears to be sourced largely from imports due to price competitiveness and processing consistency.

China’s position in the global hemp cannabinoid supply chain is dominant, with some claiming it contributes around 70% of the global supply of hemp, although as previously mentioned, exact figures are not available.³⁹ By early 2021, China, which was long the global leader in hemp textile and fiber production, significantly expanded acreage dedicated to cannabinoid-rich hemp varieties. Between 2018 and 2020, acreage for CBD-focused cultivation in provinces such as Yunnan and Heilongjiang surged by approximately 300%, driven in part by provincial-level regulatory support and investment in extraction infrastructure, including the opening of the Kunming Economic Development Zone in late 2020.⁴⁰

Chinese extraction firms advertise 99% pure CBD isolate on B2B platforms like Alibaba and Made-in-China.com, with suppliers openly promoting bulk shipments to the U.S. at prices often as low as $300–$600 per kilogram. One supplier, Yunnan Hansu Biotechnology Co., has claimed to generate up to $100 million in revenue, with a substantial portion reportedly directed to North American buyers. While such figures are not independently verified, they are consistent with widespread online listings and supplier claims targeting the U.S. market for bulk cannabinoid inputs.⁴¹ Chinese vendors such as Xi’an Lyphar Biotech Co., Hunan Insen Biotech Co., and others list large stock or warehouse-ready CBD isolate (99 % purity) specifically targeting North American buyers. Descriptions explicitly highlight “warehouse large stock”, “bulk supply”, and “fast delivery”, indicating readiness for large-scale U.S. fulfillment.⁴² Other vendors boast immediate warehouse availability and large-scale fulfillment capacity tailored to U.S. cannabinoid manufacturers.⁴³

By comparison, as of August, 2025, U.S. producers of CBD isolate charge between $450 and $950 per kilogram for wholesale quantities. For example, one U.S. producer emphasizing third-party testing and domestic sourcing, offers bulk CBD isolate starting at $450/kg for orders of 6-10 kilograms,⁴⁴ while another charges $850-950/kg for similar quantities with full GMP certification.⁴⁵ Chinese exporters commonly provide CBD at prices 30-70% below domestic rates, with some suppliers advertising 99% pure isolate from $300 to $600 per kilogram on Alibaba,⁴⁶ and others promoting even lower prices for bulk orders.⁴⁷ For large synthetic THC manufacturers purchasing thousands of kilograms annually, choosing Chinese CBD over domestic sources can mean millions in reduced input costs – savings that come at the expense of quality assurance, supply chain transparency, and consumer safety.

The reason these suppliers dominate much of the U.S. market is simple: CBD isolate from China is cheap, abundant, and available in a form that meets the needs of synthetic THC production, and U.S. farmers cannot currently compete on cost. Even if U.S. acreage could, in theory, produce enough biomass to meet cannabinoid demand, domestic infrastructure remains underdeveloped. Large-scale extraction facilities capable of reliably producing high-purity isolate are scarce, capital investment has stalled, and inconsistent regulatory signals deter new entrants. Building out a domestic supply chain requires coordinated public and private investment, which is currently not in place. As a result, imported isolate remains not only more accessible, but economically rational for manufacturers focused on synthetic THC production.

For processors seeking a stable, high-purity feedstock to convert into delta-8 THC and related products, imports remain the most efficient – and profitable – option.

Industry leaders have raised even more troubling concerns about the nature of Chinese “CBD” imports. In his April 9, 2025 testimony before the House Committee on Oversight and Accountability, Jonathan Miller, chief counsel for the US Hemp Roundtable, a leading advocacy organization, warned that “reports persist of Chinese manufacturers selling purely synthetic cannabinoids – those that have no relation to the hemp plant – in the marketplace, endangering public health and safety.”⁴⁸ Miller states that these compounds “are often mislabeled, lack third-party testing, and in some cases, have been marketed to children,” highlighting that the marketplace was being “swamped with Chinese synthetic cannabinoids that bear no relation to the hemp plant and pose serious risks to public health.”⁴⁹ This raises the alarming possibility that what enters the U.S. as “hemp-derived CBD isolate” may not be derived from hemp, but rather produced through synthetic chemistry and passed off as a natural hemp extract.

The implications of synthetic rather than plant-derived CBD are profound. If Chinese manufacturers are indeed synthesizing cannabinoids in laboratories and shipping them as “hemp extracts,” the entire regulatory framework premised on agricultural hemp production (whether American or Chinese) becomes meaningless. These synthetic compounds would not only bypass agricultural oversight but could contain reaction byproducts, residual catalysts, and novel compounds never present in the cannabis plant – all while being chemically converted yet again into delta-8 THC and other synthetic intoxicants for American consumers. Miller framed this as part of the FDA’s broader regulatory failure, arguing that the agency’s inaction had created an uneven playing field where responsible businesses growing actual hemp were being undercut by bad actors, with Chinese synthetic cannabinoid manufacturers representing a significant portion of those bad actors.⁵⁰ Without mandatory testing to verify botanical origin or comprehensive chemical analysis, there is currently no way to determine whether the tens of thousands of kilograms of “CBD isolate” entering the U.S. annually are actually derived from hemp plants or produced in chemical synthesis facilities.

In effect, the 2018 Farm Bill unintentionally created a market for cannabinoid inputs that now operates easily and cheaply through global commodity pipelines, and may or may not involve hemp in the production chain. American processors can easily source CBD not just from U.S. farms, but from Chinese exporters at a significantly lower cost. The “hemp-derived” intoxicants industry has some level of on a foreign chemical supply chain, one that is largely outside the reach of U.S. agricultural or drug policy oversight.⁵¹

Meanwhile, change in Chinese policy effective September 1, 2024 reclassified CBD as a ‘precursor chemical,’ imposing new licensing and reporting requirements domestically.⁵² While this tightened domestic oversight, Chinese authorities have simultaneously expanded legal hemp production beyond the Yunnan and Heilongjiang provinces and there is little to indicate exports will be curtailed.

It is worth mentioning that while U.S. manufacturers face no regulatory barriers when importing Chinese CBD isolate for synthetic THC production, American hemp producers remain effectively barred from exporting CBD. Due to the FDA’s refusal or inability to recognize CBD as a lawful ingredient in food or supplements, most U.S.-made CBD products cannot legally enter interstate or international commerce.⁵³ In contrast, Chinese exporters operate under a legal framework that permits CBD export under precursor chemical licensing.⁵⁴

This analysis does not suggest that Chinese CBD imports caused the collapse of U.S. hemp farming. There are many factors that contributed to an underperformance of the emerging hemp market. Rather, it documents how international suppliers – particularly those in China –  capitalized on a critical gap in the American supply chain that emerged between 2019 and 2021.

The emergence of delta-8 THC and other synthetic cannabinoids in 2021 created new, unexpected demand for CBD isolate – but by then, the U.S. hemp infrastructure had largely collapsed. Processors seeking high-purity CBD isolate for conversion into intoxicants could easily turn to international suppliers offering reliable volume, consistent 99% purity, and competitive pricing.

Chinese manufacturers, operating with established extraction infrastructure, economies of scale, and an export regime, were uniquely positioned to fill this void. While U.S. farmers struggled with regulatory uncertainty and market volatility, Chinese suppliers had already built the capacity to produce hemp, and ramped up their ability to extract CBD isolate at industrial scale. When U.S. processors needed readily available sources of CBD isolate to feed inputs for the booming domestic synthetic THC market, Chinese suppliers maneuvered into a position to meet that demand consistently and cost-effectively. That dynamic continues today, with U.S. farmers unable to compete with Chinese pricing.

Regulatory and Policy Developments Affecting Imports

Regulatory changes since 2019 have largely enabled the growth of CBD isolate imports, with few barriers imposed on raw (unformulated) cannabinoid ingredients:

• 2018 Farm Bill – Legalization of Hemp: Effective January 2019, hemp and its extracts (including cannabidiol) were removed from the Controlled Substances Act as long as THC content remains ≤0.3%. This was the foundational change that made importing CBD possible. Prior to this, any CBD (even from hemp) was generally treated as illegal marijuana. The Farm Bill explicitly protected interstate commerce of hemp, stating that no state may prohibit the importation of hemp or hemp products produced under lawful conditions.⁵⁵ This gave importers a green light, provided their CBD isolate was derived from legal hemp and under the THC threshold. U.S. Customs and Border Protection (CBP) confirmed that hemp is no longer a controlled substance, aligning its practices with the new law. Importantly, no special import license is required for hemp extracts; standard customs procedures apply. (CBP did issue guidance for hemp seed and plant imports for cultivation purposes, but no formal policy specifically limiting CBD extract imports.)⁵⁶

• Customs Classification and Duties: In 2020, CBP issued a binding ruling clarifying the Harmonized Tariff code for CBD isolate. Pure CBD (≥98% cannabidiol) is classified under HTSUS 2907.29.9000 – “Polyphenols; phenol-alcohols – Other”.⁵⁷ This category carries a modest tariff (5.5% MFN duty).⁵⁸ However, several major source countries benefit from trade agreements: for example, CBD isolate from Colombia can enter duty-free under the U.S.-Colombia Trade Promotion Agreement.⁵⁹ This has incentivized imports – Colombian producers tout duty-free access to the U.S. market, and indeed Colombia began exporting hemp derivatives to the U.S. starting in 2019–20 (though their volumes remain relatively small compared to China). Additionally, broad-spectrum hemp oil (not pure isolate) may fall under different codes (e.g. HTS 3824.99 for chemical mixtures),⁶⁰ but those also face no prohibitive tariffs. In sum, U.S. tariff and customs classification policies since 2019 have posed no significant barriers to importing raw CBD isolate.
  
• FDA’s Stance – No Ban on Ingredients: The Food and Drug Administration has not approved CBD for use in dietary supplements or foods, creating a regulatory gray area in the domestic market. However, this FDA restriction applies to finished consumer products, not the import of raw ingredients. FDA has not established a comprehensive regulatory pathway for ingestible CBD. In practice, bulk CBD ingredients continue to  enter the U.S. under general customs procedures where THC content is declared, absent CBD-specific import controls. As long as the product is not mislabeled with unlawful health claims and remains under 0.3% THC, it can pass through customs. FDA officials have focused on warning sellers of CBD foods and pills, but they have not moved to block imports of bulk CBD for processing. This means U.S. companies can (and do) import CBD isolate, then use it in cosmetics, topical products, or hold it as inventory pending a clearer path for supplements. The lack of FDA regulatory clarity since 2019 has arguably stifled retail growth but did not stop the flow of the ingredient itself.⁶¹ Notably, as of early 2023 FDA signaled it will seek new legislation to regulate CBD, but until any new rules emerge, the status quo continues (with imports unrestricted but end-use somewhat limited to non-ingestibles and state-regulated cannabis  channels).

• No Import Restrictions Imposed: Despite complaints from farmers, the U.S. government has not instituted any quotas or bans on hemp-derived CBD imports. During the USDA’s hemp rulemaking in 2019–2021, some commenters urged USDA to ban or limit imports to protect U.S. growers (suggesting a 2-year moratorium on hemp extract imports, for example).⁶² The USDA’s response was that import/export issues are beyond its scope – the agency acknowledged that the 2018 Farm Bill did not authorize it to restrict trade.⁶³ Thus, no action was taken to curb imports. Similarly, no measures from the U.S. Trade Representative or Congress have targeted hemp imports, and Chinese CBD isolate has been freely flowing to the U.S. market. The policy environment from 2019 through 2023 has remained open and permissive toward importing raw CBD isolate.

Health and Safety Implications

The reliance on CBD isolate imports for synthetic THC production creates multiple layers of health risk that compound through the supply chain. Unlike pharmaceutical ingredients that undergo rigorous safety evaluation, or state-regulated cannabis that requires comprehensive testing, imported CBD isolate enters a regulatory blind spot where contamination can occur at every stage – from cultivation through chemical conversion to final product.

Concentration and Bioaccumulation of Contaminants

The extraction and purification process that creates CBD isolate can concentrate contaminants present in the original hemp biomass. Heavy metals absorbed by hemp plants during cultivation become concentrated during extraction, potentially reaching levels many times higher than in the raw plant material. A 2020 study found that extraction processes can concentrate heavy metals by factors of 3-10x, depending on the extraction method and metal type.⁶⁴ When this already-concentrated isolate undergoes further chemical conversion to delta-8 THC, contaminants may continue to appear in chemical reactions with unknown results.

This concentration effect is particularly concerning given hemp’s exceptional ability to absorb toxins from soil. Hemp has been used to remediate contaminated soil at Chernobyl and other contaminated sites precisely because it so effectively pulls heavy metals and radioactive elements from soil.⁶⁵ While this makes hemp valuable for environmental cleanup, it means that hemp grown in areas with industrial pollution or naturally high heavy metal content may contain dangerous levels of lead, cadmium, arsenic, and mercury. Regulators in the U.S. cannot know the growing conditions of Chinese hemp, and CBD derived from that hemp can enter the domestic supply chain with few if any restrictions.

Vulnerable Populations and Exposure Routes

The health implications are particularly acute because synthetic THC products are often marketed and sold outside traditional cannabis channels, reaching consumers who may be unaware of the risks or even that these products are synthetic. These products appear in convenience stores, gas stations, and online marketplaces, in many cases without age verification or safety warnings. Young people, who may perceive these products as “legal” and therefore safer than regulated cannabis, face particular risk from developmental impacts of heavy metal exposure and unknown synthetic compounds.

Exploitation of Medical Vulnerabilities

Perhaps most concerning is the marketing of these often untested products to vulnerable medical populations. Delta-8 THC products are actively promoted as alternatives for medical marijuana patients, with websites claiming benefits for cancer patients, those undergoing chemotherapy, and individuals with chronic pain conditions.⁶⁶ In Florida, for example, delta-8 is marketed to those who choose not to obtain state medical marijuana cards, positioning unregulated synthetic THC as equivalent to state-tested medical cannabis.⁶⁷ Some retailers explicitly target medical patients, advertising delta-8 as providing “similar relief” to medical marijuana without the need for physician oversight or product testing.⁶⁸

This marketing is particularly troubling given that medical patients may have compromised immune systems or heightened sensitivity to contaminants. The FDA has warned against companies making unsubstantiated medical claims about delta-8, noting these products have not been evaluated for safety or efficacy in treating any medical condition.⁶⁹ Yet vulnerable patients seeking relief may turn to these products as more accessible alternatives to regulated medical cannabis, unknowingly consuming products originating in a foreign country, outside any regulatory oversight, and potentially exposing themselves to heavy metals, residual acids, and synthetic byproducts at a time when their health is already compromised.

Cumulative Public Health Impact

With the synthetic THC market now exceeding $2.8 billion annually and growing rapidly, millions of Americans regularly consume products made from imported CBD of unknown origin and quality. Even if contamination levels in individual products seem relatively low, the cumulative exposure across millions of users represents a significant public health concern. Heavy metals accumulate in body tissues over time, and chronic low-level exposure can lead to neurological damage, kidney disease, cardiovascular problems, and cancer.⁷⁰

The situation parallels previous public health crises where widespread exposure to seemingly safe products later revealed serious health consequences – from lead in gasoline to asbestos in building materials. However, unlike those historical examples where exposure was inadvertent, consumers are actively ingesting and inhaling these potentially contaminated products, often multiple times daily.

Impediments to Medical Recognition and Response

Healthcare providers face significant challenges in identifying and treating potential poisonings from contaminated synthetic THC products. Unlike regulated cannabis products that can be traced to specific batches and tested for contaminants, synthetic THC products offer no transparency about their contents or origin, including synthetic chemicals. Patients presenting with symptoms may not connect their illness to hemp-derived products they consider “legal” or “natural.” Even when connections are suspected, the lack of product tracking and production oversight makes it impossible to identify contamination sources or warn other consumers.

Emergency departments have already reported increases in adverse events related to delta-8 THC and other synthetic cannabinoids, including seizures, psychosis, and respiratory distress.⁷¹ However, these reports likely capture only acute reactions, not the slow accumulation of heavy metals or long-term effects of exposure to novel synthetic compounds. Without mandatory reporting requirements or systematic surveillance, the true scope of health impacts remains hidden.

Conclusion

The 2018 Farm Bill’s legalization of hemp has inadvertently created a public health crisis hiding in plain sight with synthetic THC products now widely available throughout the country. What began as an attempt to support American farmers has evolved into an unregulated pipeline for potentially contaminated chemical precursors, imported without tracking, converted without oversight, and sold without testing to millions of Americans as “hemp” products.

The data gaps themselves tell a damning story. While state cannabis programs can trace every gram from seed to sale, federal regulators cannot even quantify how much CBD isolate enters the country, identify its sources, or track where it goes. This imported CBD can be contaminated with heavy metals, pesticides, and industrial pollutants based on China’s documented history with unregulated exports and no oversight. These chemicals then undergo further chemical conversion using acids and catalysts that create unknown synthetic byproducts while making synthetic THC and sold as a substitute for marijuana. The resulting products bypass every safety standard that state-regulated cannabis must meet, yet are marketed as “legal” alternatives, even to vulnerable medical patients seeking relief from cancer, chronic pain, and other serious conditions.

The health implications could be staggering. Millions of consumers, including children and medical patients, regularly ingest and inhale products that would trigger immediate recalls in regulated markets. Heavy metals accumulate in body tissues over time; synthetic byproducts have never been evaluated for human safety; residual acids from conversion processes may cause long-term damage when vaporized. Yet without mandatory testing, tracking, or even basic import data, the true scope of exposure remains hidden.

Given the documented history of contamination in Chinese exports, the unknown history of the CBD imported, the known risks of heavy metal bioaccumulation in hemp, and the unpredictable nature of chemical synthesis byproducts, the current situation presents an unacceptable risk to public health.

Recommendations

Immediate congressional and regulatory action is required to address this crisis:

• Address the Synthetic THC Loophole in the Farm Bill Congress should amend the definition of hemp created in the 2018 Farm Bill to explicitly prohibit the production and sale of synthetically-derived intoxicating cannabinoids. Products with intoxicating effects should be subject to the same comprehensive testing, tracking, and safety standards regardless of whether they derive from marijuana or hemp.

• Create Harmonized Tariff Schedule Codes for Cannabinoids The U.S. International Trade Commission should establish specific HTS codes for CBD isolate, CBD distillate, and other cannabinoid products. Proper coding would enable monitoring of import volumes, sources, and trends. Without the ability to track imports, regulators are blind to the scope and source of materials entering the synthetic THC supply chain or the CBD natural wellness marketplace.

• Require Testing and Tracking for All Imported CBD Intended for Consumption The FDA and CBP should implement mandatory testing requirements for imported CBD isolate and other cannabinoid products intended for human consumption, including screening for:

Heavy metals (lead, cadmium, mercury, arsenic)
Pesticide residues
Microbial contamination
Residual solvents
Synthetic byproducts and unknown compounds

Importers should be required to maintain chain-of-custody documentation identifying the source farms, extraction facilities, and testing certificates for all cannabinoid imports.

If CBD cannot be used for human consumption, then controls should be established to ensure that is not the purpose to which they are put. FDA’s response cannot simply be that it has no jurisdiction when it already sends warning letters and public alerts related to these products.

Support Domestic Hemp Processing Infrastructure To reduce dependence on imported cannabinoids of unknown quality, Congress should invest in domestic hemp processing capacity through:

Tax incentives for extraction and processing facilities
USDA grants for hemp processing infrastructure
Research funding for safe, efficient extraction methods
Support for farmer cooperatives to develop regional processing hubs

The importation of untested cannabinoids must be regulated. The safety of American consumers must take precedence over the profits of an industry built on regulatory arbitrage and imported chemical precursors.

• Regulatory Oversight and Definitional Updates Congress must establish clear definitions and regulatory lanes under federal law for industrial hemp for fiber and grain as a traditional agricultural commodity; a clear pathway for non-intoxicating hemp cannabinoids, such as CBD, under food and dietary supplement regulations; and a unified framework for intoxicating THC products.

Appendix

Global Supply Chain

A global web of suppliers now markets cannabinoid offlabel feedstocks – primarily as CBD isolate – to U.S. buyers with little regulatory oversight. Today there are numerous overseas suppliers openly advertising CBD isolates and hemp extracts “for further processing.” Listings frequently highlight the purity and suitability of these materials for conversion into THC analogs:

• Alibaba (China): A search on Alibaba.com yields hundreds of Chinese suppliers for CBD isolate. Many advertise “99% pure CBD isolate powder” and large in-stock quantities. One supplier, Yunnan Hansu Biotechnology Co., lists “99.5% organic hemp extract Cannabidiol (CBD) isolate powder” and notes its main products as CBD, full-spectrum hemp oil, and water-soluble CBD alibaba.com. This company reports annual revenue of $50–$100 million, with 80% of its sales to North America alibaba.com – with U.S. demand driving their business. Another Chinese vendor boasts “Large Stock CBD Isolate 99% Bulk Price – Warehouse Stock Available,” indicating readiness to supply sizable orders. These firms position their isolates as crystalline ingredients that buyers (often private U.S. labs or manufacturers) can use to formulate products or synthesize into other cannabinoids including THC.

Alibaba

• Made-in-China / Other Platforms: Similarly, on Made-in-China.com (a directory of Chinese manufacturers), products such as wholesale delta-8 THC distillate and CBD isolate are on offer. Made-in-China.

• IndiaMART (India): Indian exporters also list CBD isolates and oils. Some Indian nutraceutical companies market “hemp extract 99% CBD” on IndiaMART and similar portals, sometimes phrased as “Ayurvedic hemp extract” or API (active pharmaceutical ingredient) grade CBD. For example, an India-based supplier Cannavedic advertises “Pure CBD Isolate – 99% high-quality, no THC,” positioning it for use in foods, topicals, or further formulations cannavedic.in. Indian industrial chemical firms (with pharma licenses) can produce or purify CBD and are beginning to offer it globally for further refinement into synthetic products. While India’s domestic hemp cultivation is limited, companies are likely importing CBD crude (possibly from China), refining it to isolate, and re-exporting – or synthesizing cannabinoids from terpenes in a lab. The net result is Indian suppliers joining the race to provide cheap precursor inputs.

Endnotes

1 Brightfield Group, market data cited in Noelle Skodzinski, “How Big Is the U.S. Market for Delta-8 THC and Other Intoxicating Hemp-Derived Cannabinoids?” Cannabis Business Times, March 6, 2024, https://www.cannabisbusinesstimes.com/business-issues-benchmarks/cannabis-sales-trends/news/15686 872/how-big-is-the-us-market-for-delta-8-thc-and-other-intoxicating-hemp-derived-cannabinoids.

2 World Health Organization, “Melamine-contaminated powdered infant formula in China – update 2” (Geneva: World Health Organization, September 29, 2008), https://www.who.int/emergencies/disease-outbreak-news/item/2008_09_29a-en.

3 The New York Times, “Lead Paint Prompts Mattel to Recall 967,000 Toys” (New York: The New York Times, August 15, 2007), https://www.nytimes.com/2007/08/15/business/worldbusiness/15imports.html.

4 U.S. Food and Drug Administration, as reported in “FDA Links Heparin Deaths to Contaminated Chinese Supply,” PBS NewsHour, April 22, 2008; see also U.S. House of Representatives, Committee on Energy and Commerce, “The Heparin Disaster: Chinese Counterfeits and American Failures,” 110th Congress (2008).

5 Cornbread Hemp, “Is CBD Oil Safe? Ask a Pharmacist,” Cornbread Hemp, July 1, 2020, https://www.cornbreadhemp.com/blogs/learn/is-cbd-oil-safe?srsltid=AfmBOoo8pK7j_2XyWU4RW7pz49LZafjr2i6sSKzDQQaVcPU_6bMpR4HM&utm (accessed August 8, 2025).

6 WJLA-TV, “The Risk of Contaminants and False Labeling in the Exploding CBD Industry,” 7 On Your Side, July 3, 2019, archived at
https://web.archive.org/web/20190703045325/https://wjla.com/features/7-on-your-side/the-risk-of-contaminants-and-false-labeling-in-the-exploding-cbd-industry.

7 Ministry of Hemp, “Here’s Why China Is A Growing Hemp Superpower,” Medium, December 11, 2021, https://medium.com/@ministryofhemp/heres-why-china-is-a-growing-hemp-superpower-4ae4b12ed7bc.

8 USDA Foreign Agricultural Service, “2019 Hemp Annual Report” (Beijing: USDA FAS, February 21, 2020), https://www.fas.usda.gov/data/china-2019-hemp-annual-report.

9 World Health Organization, “Melamine-contaminated powdered infant formula in China,” September 2008, https://www.who.int/csr/don/2008_09_19/en/.

10 Blossom, J.L., et al., “Outbreak of Adverse Reactions Associated with Contaminated Heparin,” New England Journal of Medicine 359 (2008): 2674-2684.

11 U.S. Government Accountability Office, “Drug Safety: FDA Has Conducted More Foreign Inspections and Begun to Improve Its Information on Foreign Establishments, but More Progress Is Needed,” GAO-10-961, September 2010.

12 U.S. Consumer Product Safety Commission, “2007 Performance and Accountability Report,” November 2007.

13 U.S. Food and Drug Administration, “Drug Shortages: Root Causes and Potential Solutions,” October 2019.

14 U.S. Customs and Border Protection, “NY N312116: The tariff classification of Cannabidiol (CBD) in bulk powder (isolate) from Colombia” (Washington, DC: CBP, June 11, 2020), ruling NY N312116, [https://www.customsmobile.com/rulings/docview?doc_id=NY%20N312116].

15 Joe Horner, Ryan Milhollin, Alice Roach, Chase Morrison, and Rhiannen Schneider, “Comparative Analysis of the Industrial Hemp Industry: Guide to the evolution of the U.S. industrial hemp industry in the global economy,” MU Extension Publication MX0071 (Columbia: University of Missouri Extension, December 2019), https://extension.missouri.edu/media/wysiwyg/Extensiondata/Pub/pdf/miscpubs/mx0071.pdf and Hemp Industry Daily, “Chart: US hemp legalization hasn’t cooled imports” (Denver: Hemp Industry Daily, March 9, 2021), https://hempindustrydaily.com/chart-us-hemp-legalization-hasnt-cooled-imports/.

16 Cannabis Business Times, “Hemp Numbers Plummet Across the Board in 2022 USDA Acreage and Production Survey” (Cleveland: Cannabis Business Times, May 25, 2023), by Andriana Ruscitto, https://www.cannabisbusinesstimes.com/business-issues-benchmarks/cbd-industry/news/15687728/hemp-numbers-plummet-across-the-board-in-2022-usda-acreage-and-production-survey.

17 Piotr Liroy‑Marzec, “Cheap Chinese CBD Products Are Flooding the Market — Impacts and Solutions” (LinkedIn post, published approximately 3 months ago [i.e. circa April–May 2025]), https://www.linkedin.com/pulse/cheap-chinese-cbd-products-flooding-market-impacts-piotr-liroy-marzec-o4cgf/.

18 Jonathan Miller, General Counsel, U.S. Hemp Roundtable, “Written Testimony of Jonathan Miller Before the House Committee on Oversight and Accountability” (Washington, DC: U.S. House of Representatives Committee on Oversight and Accountability, April 9, 2025), https://oversight.house.gov/wp-content/uploads/2025/04/Miller-Written-Testimony.pdf.

19 Hemp Industry Daily, “Consumer CBD Prices Are Falling as Companies Seek New Consumers. Is That a Good Thing?” (Denver: MJBiz, August 6, 2020),
https://hempindustrydaily.com/consumer-cbd-prices-are-falling-as-companies-seek-new-consumers-is-that-a-good-thing.

20 Hemp Benchmarks, “August 2021 Hemp Spot Price Index Report” (Stamford: New Leaf Data Services, August 25, 2021), https://www.hempbenchmarks.com/hemp-market-insider/august-2021-hemp-spot-price-index-report.

21 Piotr Liroy‑Marzec, “Cheap Chinese CBD Products Are Flooding the Market.”

22 Ibid.

23 PR Newswire, “North American Hemp‑CBD Imports and Exports Projected to Jump.”

24 Miller, “Written Testimony Before the House Oversight Committee.”

25 Whitney Economics, “U.S. Hemp Industry Continues to Face Problems of Oversupply, Murky Regulation” (Portland: Whitney Economics, quoted in Consulting.us, December 27, 2020), https://www.consulting.us/news/5293/us-hemp-industry-continues-to-face-problems-of-oversupply-murky- regulation.

26 Retail sales of hemp-derived intoxicating cannabinoids (e.g., delta-8 THC, HHC, delta-10 THC) were estimated at $2.8 billion in 2023, with delta-8 THC alone accounting for $1.2 billion. If we assume an average retail price of $0.05–$0.10 per milligram of delta-8 THC, this implies that approximately 12,000–24,000 kilograms of delta-8 THC were sold. Because converting CBD isolate to delta-8 is not 100% efficient, and typical reaction yields are around 60%, it would require ~1.7 kilograms of CBD input for every 1 kilogram of delta-8 output. Applying this yield ratio, the delta-8 market alone would have consumed approximately 30,000–40,000 kilograms of CBD isolate in 2023. Including other hemp-derived intoxicants (e.g., HHC, delta-10, “hemp-derived” delta-9 THC), and using similar assumptions, total CBD input for intoxicant synthesis likely ranged from 40,000 to 90,000 kilograms per year—or 40 to 90 metric tons.

27 Hemp Industry Daily, “Hemp & CBD Industry Factbook 2020” (Denver: Anne Holland Ventures Inc., 2020), cited in Hemp Industry Daily, “2020 Outlook: Licensed U.S. hemp acreage falls 9% from 2019”, noting that 94% of producers in 2019 grew hemp flower varieties for cannabinoid extraction, primarily targeting the CBD wellness market. https://hempindustrydaily.com/2020-outlook-licensed-u-s-hemp-acreage-falls-9-from-2019-but-grower-numbers-increase-27.

28 Hemp Benchmarks, “Delta-8 THC: Another Look” (Stamford, CT: New Leaf Data Services, August 2021), https://www.hempbenchmarks.com/hemp-market-insider/delta-8-thc-another-look/. See also: New Leaf Data Services (Hemp Benchmarks), “Hemp Spot Price Index Report — December 2021” (Stamford, CT: December 2021), https://hempsupporter.com/assets/uploads/HempBenchmarksSpotPriceIndexReport-December2021.pdf; Google Trends analysis cited in Oleson, Jacob J., et al., “Public Interest in Delta-8 THC Increased in U.S. States That Restricted Delta-9 THC Use,” Journal of Cannabis Research 3, no. 1 (2021), https://www.researchgate.net/publication/357224714.

29 Wholesale data from New Leaf Data Services (Hemp Benchmarks) indicate that in July 2021, CBD isolate prices were around $513/kg, while delta‑8 THC distillate traded at approximately $1,065/kg, demonstrating that delta‑8 commanded about double to triple the price of CBD isolate at a time when isolated CBD prices were collapsing due to oversupply. New Leaf Data Services (Hemp Benchmarks), “July 2021 Hemp Spot Price Index Report” (Stamford, CT: New Leaf Data Services, July 28, 2021), noting CBD isolate prices around $513/kg and delta‑8 THC distillate around $1,065/kg, approximately double the former. https://www.hempbenchmarks.com/hemp-market-insider/july-2021-hemp-spot-price-index-report/.

30 Brightfield Group, market data cited in Noelle Skodzinski, “How Big Is the U.S. Market for Delta-8 THC and Other Intoxicating Hemp-Derived Cannabinoids?” Cannabis Business Times, March 6, 2024, https://www.cannabisbusinesstimes.com/business-issues-benchmarks/cannabis-sales-trends/news/15686 872/how-big-is-the-us-market-for-delta-8-thc-and-other-intoxicating-hemp-derived-cannabinoids.

31 Ibid.

32 Brightfield Group (2024) Brightfield Group, “US CBD and Cannabinoids Market Report Q1 2024” (Chicago: Brightfield Group, 2024), https://blog.brightfieldgroup.com/2024-q1-cbd-cannabinoids-market.

33 Cornbread Hemp, “Fake CBD? How to Spot a Fraud,” Cornbread Hemp, May 26, 2023, https://www.cornbreadhemp.com/blogs/learn/fake-cbd?srsltid=AfmBOoq23i5uUCT7r0VlwZCq–kzrso4_o QhrtKahq79bPElo0qhBr6A&utm.

34 Metrc, “Track-and-Trace Systems in Cannabis Regulation,” 2023, https://www.metrc.com/track-and-trace.

35 Cannabis Control Commission (Massachusetts), “Guidance on Sampling and Testing Requirements,” 2023; Colorado Marijuana Enforcement Division, “Retail Marijuana Rules,” 1 CCR 212-3, 2024.

36 Craven, C.B., et al., “Pesticides and trace elements in cannabis: Analytical and environmental challenges and opportunities,” Journal of Environmental Sciences 90 (2020): 176-185.

37 Meehan-Atrash, J. and Rahman, I., “Novel Δ8-Tetrahydrocannabinol Vaporizers Contain Unlabeled Adulterants, Unintended Byproducts of Chemical Synthesis, and Heavy Metals,” Chemical Research in Toxicology 35, no. 1 (2022): 73-84.

38 Chemical & Engineering News, “Delta-8-THC craze concerns chemists: Unidentified by-products and lack of regulatory oversight spell trouble for hemp-derived products,” August 8, 2021.

39 Ronald Bethea, “How Is China Poised to Be a Hemp Fiber Superpower?” Positive Change Purchasing Cooperative, May 27, 2021, noting that acreage devoted to CBD-oriented hemp increased by 300% from 2018 to 2020 before domestic regulatory reversal. https://positivechangepc.com/how-is-china-poised-to-be-a-hemp-fiber-superpower/.

40 Ibid.

41 Yunnan Hansu Biotech Revenue and Exports
Alibaba.com, “Yunnan Hansu Biotechnology Co., Ltd – Company Profile,” Alibaba International Marketplace, accessed July 2025, https://hansu.en.alibaba.com.

42 https://www.alibaba.com/cbd-isolate-suppliers.html.

43 Alibaba Supplier Listings
Alibaba.com, “CBD Isolate Powder – Search Results,” Alibaba International Marketplace, accessed July 2024,
https://www.alibaba.com/trade/search?fsb=y&IndexArea=product_en&CatId=&SearchText=CBD+isolate.

44 Crescent Canna, “Wholesale CBD Isolate Powder,” accessed 2025, noting prices starting at $450/kg for 6-10 kilogram orders of U.S.-grown, third-party tested CBD isolate, https://www.crescentcanna.com/bulk-cbd-isolate-wholesale/.

45 Kanavive, “CBD Isolate Wholesale,” accessed 2025, listing prices of $850-950/kg depending on volume for USA-grown, organic hemp-derived CBD isolate, https://kanavive.com/pages/wholesale.

46 Yunnan Hansu Biotech Revenue and Exports Alibaba.com, “Yunnan Hansu Biotechnology Co., Ltd– Company Profile,” Alibaba International Marketplace, accessed July 2025, https://hansu.en.alibaba.com .

47 Xi’an Sonwu Biotechnology Co., Ltd., “China CBD Isolate Powder Suppliers,” accessed 2025, https://www.sonwuapi.com/api-powder/cbd-isolate-powder.html.

48 Jonathan Miller, “Testimony Before the U.S. House Committee on Oversight and Accountability, Hearing: Restoring Trust in FDA: Rooting Out Illicit Products” (Washington, DC: U.S. House of Representatives, April 9, 2025), as reported in Business of Cannabis, “FDA Hammered by Lawmakers on Capitol Hill for Allowing Intoxicating Hemp Industry to Flourish,” April 10, 2025, [https://businessofcannabis.com/the-us-food-and-drug-administration-fda-was-dragged-through-the-mud- by-lawmakers-yesterday-who-said-its-bureaucratic-red-tape-inefficiencies-and-weak-oversight-was-responsible-f/].

49 Ibid.

50 Ibid.

51 USDA Data – Hemp Acreage Collapse U.S. Department of Agriculture, National Hemp Report – 2024 Edition (Washington, D.C.: USDA, April 2024), https://downloads.usda.library.cornell.edu/usda-national-hemp-report-2024.pdf.

52 United States Department of Agriculture (USDA), “Cannabidiol to be Regulated as Precursor Chemical” (Beijing: Foreign Agricultural Service, Voluntary Report CH2024‑0101, August 2 2024), unofficial translation, https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName?fileName=Cannabidiol+to+be+Regulated+as+Precursor+Chemical_Beijing_China+-+People’s+Republic+of_CH2024-0101.pdf.

53 U.S. Food and Drug Administration, “FDA Concludes Existing Regulatory Frameworks for Foods and Supplements Are Not Appropriate for Cannabidiol,” January 26, 2023, https://www.fda.gov/news-events/press-announcements/fda-concludes-existing-regulatory-frameworks-fo ods-and-supplements-are-not-appropriate-cannabidiol.

54 Made-in-China.com, “Product Listings for CBD Isolate Suppliers,” accessed July 2025, https://www.made-in-china.com/.

55 USDA, “Establishment of a Domestic Hemp Production Program.”

56 Maggie Craig, Jae Kim, Kelsey Tavares & Stefanie Fogel, “Federal Agencies’ Current Positions on Hemp‑Derived CBD Products” (May 25, 2022) (DLA Piper Cultivate blog), https://www.dlapipercultivate.com/2022/05/federal-agencies-current-positions-on-hemp-derived-cbd-products/.

57 U.S. Customs and Border Protection, “NY N312116: The tariff classification of Cannabidiol (CBD) in bulk powder (isolate) from Colombia” (Washington, DC: CBP, June 11, 2020), ruling NY N312116, https://www.customsmobile.com/rulings/docview?doc_id=NY%20N312116.

58 Ibid.

59 Ibid.

60 Craig et al., “Federal Agencies’ Current Positions on Hemp‑Derived CBD Products.”

61 Miller, “Written Testimony Before the House Oversight Committee.”

62 USDA, “Establishment of a Domestic Hemp Production Program.”

63 Ibid.

64 Craven, C.B., et al., “Pesticides and trace elements in cannabis: Analytical and environmental challenges and opportunities,” Journal of Environmental Sciences 90 (2020): 176-185.

65 Citterio, S., et al., “Heavy metal tolerance and accumulation of Cd, Cr and Ni by Cannabis sativa L.,” Plant and Soil 256 (2003): 243-252.

66 Hemponix, “Delta-8 For Cancer & Chemotherapy: Does It Work?” July 24, 2022, https://www.hemponix.com/delta-8-for-cancer-and-chemotherapy/.

67 Compassionate Healthcare of Florida, “Everything You Need to Know About Delta-8 THC,” December 30, 2021, https://www.flmmjhealth.com/everything-you-need-to-know-about-delta-8-thc/.

68 My MMJ Doctor, “All You Need To Know About Delta 8,” May 9, 2024, https://mymmjdoctor.com/all-you-need-to-know-about-delta-8/.

69 U.S. Food and Drug Administration, Warning Letter to Delta 8 Hemp, May 4, 2022, https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/delta-8-hemp-618368-05042022.

70 World Health Organization, “Ten chemicals of major public health concern,” 2020, https://www.who.int/news-room/photo-story/photo-story-detail/10-chemicals-of-public-health-concern.

71 Akpunonu, P., et al., “Delta-8, a Cannabis-Derived Tetrahydrocannabinol Isomer: Evaluating Case Report Data in the Food and Drug Administration Adverse Event Reporting System (FAERS) Database,” International Journal of Drug Policy 104 (2022), noting that the most common adverse events reported included dyspnea, respiratory disorders, and seizures; see also Seitz, N.N., et al., “Delta-8-THC association with psychosis: A case report with literature review,” Frontiers in Psychiatry 14 (2023), documenting cases of psychosis and other psychiatric symptoms in emergency department presentations.

END

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