Yes. I am interpreting this - because it changes the sections of the FD&C that drive the CFR and instructs the FDA to promulgate those rules.
Will it be a totally new section - I doubt it, because they are given a very short window of time to get this done.
So I think they will point to 111 for dietary supplements (the bill language actually says to do that and gives specifics for cannabinoids on dietary supplement labels).
And I think they will point to 117 for food.
And I think they will point to 700 for cosmetics.
And I think they will point to 510 for veterinary products - although its possible that they will lump those into the human stuff too (they seem to commingle them in the bill language).
There are many places where this draft is very different than the previous draft. For instance - previously the draft was much more flexible on cannabinoids coming from just about anywhere (especially from foreign sources). And now it seems to indicate that its more focused on only registered hemp plants (although since that doesnât exist as a rule in other countries, Iâm not sure how that would work).
But thatâs why we talk about this here. This bill impacts all of us. We should rip to shreds and rebuild it. We should figure out ways to get around it. We should consider the opportunity to comment on the future of our industry from a government level a civic duty or privilege, you know?
I think this could be be wonderful, theyâve needed to roll hemp and canna together since, idk, foreverâŚ
My excitement is seeing how this will play into the standard medical industry, thats where I think the most interesting applications will take place.
When it comes to allowing for the âlittle guyâ i think the concept of being omitted from certain rules until proven scalability is a good route, but the small producer still has to jump certain hurdles for health and safety.
I was one of those little guys just trying to stay afloat and any and every extra was a much bigger burden than say a corporatized/well funded group could pull off. Provisions need to be ensured for what I call a âmotileâ market place, thereâs gotta be a way for people with decent talent/skills/capacity to move up or away.
Very curious to see how this unfolds. Super curious to see what will happen to the small time âhemp/thca/cbdâ people will float through any and all changes.
This 100%. I donât care about stringent regulation for nothing, Iâd love everyone to be doing it. Iâm concerned that some well intentioned people canât due to scale and that needs to be accounted for just like in all other industries.
When I was told that id need to produce BHO/PHO at $1/g I knew it was time to re-evaluate capacity, and that the market needs to rationalize itself better. I knew the race to the bottom was in full tilt.
I could make my margins pretty low, but at that rate its slave labor to me.
I keep going back to the fact as to why the market isnât rational and I get all these funny looks because people donât understand simple markets or economics. We have a national shortage of cannabis, quality at that, with over half the nation still prohibiting it. Oregon, Washington, and Oklahoma markets will chastise me because that doesnât reflect their reality. No one thinks about any kind of national market to get pricing, quality straightened out.
As @lolwut expressed, market consolidation and raising of quality is inevitable if we let capitalism play out⌠Right now our cannabis market much more closely reflects communism in my opinion, certain players are chosen to win by the government (need for expensive licensing, threat of this FDA over bearing regulation, etc.)
100% Iâve always said âit isnt a poor mans sportâ but it has absolutely become a game of who has the most money, and connections.
State lawmakers are playing favoritism, and more so, producers can run on capital from investments and sell at below market value costs (usually a last minute tactic to get SOMETHING back to their investors).
Whole game is a tough oneâŚ
There isnt really a shortage though, sure theres still black market areas, but its common knowledge that âlegalâ states over produced to fulfill that glut, my take on it, its going to get worse before it gets better. As more states legalize, the respective markets will regionalize more, and there wont be places to ship it, as theyâll have local producers to cover the regions needs.
Theres reasons theres been reports that California, Oregon, Oklahoma markets have struggled in recent years, theres less and less places to ship it out to, and theyâre left with serving their regions which is disproportionate to how many producers popped up.
(8) it bears or contains, or has been manufactured, prepared, or processed from, artificially or synthetically derived cannabinoids of any kind.
Itâs a relief to see some form of enforcement enacted. Down will go the D8 production and all the other converted-semi-full synthetic garbage along with it.
Yeah, politically I call anything I donât like Communism LOL.
@TheGooMan Iâd agree with you about state markets over producing and there being no outlet, but I think thatâs more due to logistics and convenience than lack of demand. I know this because people in other states still buy D8 over black market weed. They canât find it, donât want to break the law, or black market is too expensive because of the middle man factor. I think if the supply were able to be distributed itâd be fine, but thatâs the biggest problem I see in my not legal area. No one over the age of 30 is trying to do black market anymore in my areaâŚ
Oh, 100%, itâs getting it to the right people. It is hard to have a robust sales network and to grease everyoneâs palm. The hardest thing to do is get everyone paid to make the links happen.
Iâve made this joke before though, wait till the midwest has it fully legalized. The bread basket is gonna make California, and colorado seem like chumps. With their cost of living and viable land mass. Its gonna be harder to profit in higher cost of living areas, and I believe that the movement will shift eventually. Higher cost/taxed areas are going to be importers eventually just due to costs of doing business. If it cost me 50-100k to fire up my operation in one place, but 10k in another, why wouldnât I just ship it from 10k place to 50-100k place to cover/save that margin.
I think this is why the THC-A farm bill loophole created such a nightmare for standard canna. Why would I spend 10âs or sometimes 100âs of thousands for licensing and all this over head, when I could pay a few hundred bucks to the tax assessor and be good to go with hemp licenses?
Yes, you could scrape that goo off the wall and have an excellent antibacterial agent to put on a wound. It will also alter transcription events governing scarring.