Even if the feds can’t make charges stick, a lot of illegal states’ laws are written to outlaw “tetrahydrocannibinols” collectively. They would probably just pass off any of those cases to the appropriate states. Since the Farm Bill isn’t a Constitutional amendment, the state laws in illegal states will at least take precedent. That is, if a court in this day and age would risk reminding people about states’ rights in order to prosecute sellers of an isomer. It will be an interesting saga.
it looks like you just gave them ammunition.
its legal if the d8 is natural but none of us are using natural d8 its all “semi” synthetic.
so my guess would be you will see if its from nature its cool if you isomerize its not.
they are not going to want anyone to just run isomerizations and then sell the result on the open
market.
growing plants is one thing.
using chemistry to turn a non psychoactive into a pyschoactive with impurities and unknowns is another.
you may get away with legal loop holes for now but they will stop it.
it doesn’t even have to do with thc
its to do with a heap of untrained people making human consumables with scheduled
poisons and corrosives.
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I might add this.
$3,000,000 per ounce (troy im a nice guy)
sarin derived from carbon from hemp.
100% legal.
synthetic === synthesis.
did you do any to get what you have.
this is important as if you can sell this you will keep distillates
distillation has no exo or endothermic reaction.
this is what you wish to push.
then you get it back to the growers where it belongs.
no synth but if you distill its not endo or exo so still no synth.
leave the synth to us bee’s we love it illegal or not.
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How would this ruling effect importation of CBD from other countries? Specifically Colombia
In very well might be the most cost effective way to get CBD isolate in the US depending on how this plays out
I could not give a rats arse if they legalize synth.
its either all legal or not as far as in concerned.
but we have made a massive step in the legalization when it came to cbd.
lets not push to fuck that up.
if you want to make money off the black market well good on you (I could probably help if I wanted to)
but the hemp trade must be kept alive.
thc must be illegal.
or it all must be legal (mind altering subtances that is)
its stupid I know but to get a little high might cost people there lives.
it nearly cost me mine and it was only the law that caused the problem.
cbd does not get you high (hell thc is shit if not in the bud)
there must be a line drawn between distill and synth its comming just wait
all those american christians who had jesus die just for them are wanting you to suffer.
STRAIGHT.
at least if we have cbd we can isomerize.
stop selling D8 you greedy bastards
come and dance with the underworld where you belong.
we never stopped loving you 
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There’s a lot more to this IFR than the restriction on synthetic THC. The bigger concern is that the DEA has highlighted the fact that “Work in Progress” hemp (crude and distillate for instance) has non compliant levels of THC due to the nature of concentration. Up until this point, the regulators have sorta known this, and mostly ignored it, as long as consumer end products were compliant. But processors have taken this to mean that as long as they are selling to other processors, non compliant hemp was just part of doing business… The DEA has reminded everyone that this is not the case, and that all hemp, no matter its next step, must be below .3% THC. By dry weight. So no more dilution solution either.
So basically all hemp processors in the US are in violation of federal law, and the DEA IFR let’s everyone know, that they know.
It will be very interesting to see how the DEA moves over the next month
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yep that makes sence.
you have a scheduled compound they dont care how you got it.
there job is to prosecute.
ive heard of people having 0.3% being isolated to more than 0.3% and having to have it remediated.
if the remediation centre does not have a license to deal with scheduled substances then
you have a problem.
your fight is over delta 9 and not synthetic.
dont mix the two or you will loose.
you produce a product that is considered a necesity of society to continue productively
you must separate from getting high now or loose your trade.
we are either making high’s illegaly (im cool with that)
or medicine that still allows you to drive a crane at the docks.
you will win.
you will have to burn many.
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ok here is a solution.
family (you guys helped me your family) owned cannabis remediation corp.
all procededs go to pay operaters rent and the forums bills.
no more glg we are all glg.
then we pay for there dea license.
no probs what a few hundred grand for all of us is nothing.
then it all starts again.
ban all isomeriztion talk from forum and push wanbe bees to a new forum.
then you only deal in legal.
doesn’t matter how you see it if the growers stop we all do better that you only
deal with natural than none.
still not the problem you face but it is a good start to a partition stating you only
wish to do good to the comunity.
where cooking meth and dope if you like it or not hurts none of us.
covid made us all rich
but as ive stated before dope is soul we need you to servive.
I shall stop talking isomeriztion from today and post more on optical rotation and raman of
hemp extract.
this is important that we dont screw it up.
I am sorry I was a bee and excited (though now I think growing kills chem)
The second you concentrate beyond .3% the extract is illegal. Remediation is to deal in illegal goods.
You could sell hemp to a licensed THC operator to have them isolate the CBD… But typically that means it has to then be sold inside of that market. Between the absurd taxes, the restriction on interstate commerce, and it having to compete with THC, that quickly becomes non viable.
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we are proving tachyphylaxis
that means thc is shit bud is good (well first high is great.)
so bud should be kept as bud it is a research center all of its own.
there are reasons to keep bud as it is.
we need everyone sane.
some of us are fucked.
we need drugs (strong drugs to exist)
but we face tachyphylaxis at every step
dope is the proof solution and god.
we have a natural compound that changes tachyphylaxis based on chemical symboysis
so thc is nothing to me now.
I smoke bud why does it get me so fucked yet pure thc does nothing.
can we do that for serotonin dopamine and epinephrine receptors.
isomerization is druggy shit which we all should be legaly allowed to do and give to
our friends.
what you have here is the solution of opiate addiction from tachyphylaxis.
it will take time and it is worth fighting for.
after all how much money you make is nothing compared to an eternity of human suffering.
after all olivetol is not that hard to make trust me if I or us wanted thc we would have it.
but tachyphylaxis that is another thing all together.
if there ever was proof of god it was in marijuana
we need to research getting high without tachyphylaxis
(please quote my entire message)
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every person is in suffering from the time they are born.
we must find the syboisis that is happening between plant thc and synth.
and then we must convert it to all receptors.
perosnaly I think its a push pull thing.
will be quoted in 50 years.
so you put something on the receptor.
in time it gets mutated so the receptor is not 18 years old as we wish it.
so instead we put something on the receptor and then kick it off with something
only …just… strong enough to do so.
im off to bed and the brain heals.
I was gentle (man I was fucked last night as was who ever that was with me)
next day I understood the damage I did to me and my loved ones and I am totaly clean today.
its all in dope man.
why can I smoke your shit and it get me fucked an yet im immune to mine
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Have you heard any good ideas on how to deal with hot crude and distillate yet? Beyond buying thousands of gallons of carrier oil to dilute it to .3%.
I don’t think the closed loop remediation flies. It’ll be interesting because even heavy hitters in the T free full spectrum market use closed loop chromatography coupled to their extraction which means even they have a waste stream problem. I’m not sure any hemp company can survive it without the Feds being selective with their enforcement
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This won’t fly due to the requirements being based on dry weight.
I’ve seen T free CBG crude straight off the plant 
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What’s the definition of dry weight? I can’t imagine any lab being able to pull off MCT oil without also distilling the cannabinoids. I understand diluting with a volatile solvent won’t work, but you think dry weight is determinable when you use a high BP diluent? And for that matter, what if you just extract with MCT oil and get a green, low potency product but at least it’s not illegal? I thought it was an ok idea on paper, but just not practical from a capital and storage space standpoint to have tanks of tincture sitting around.
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gentics 
cpc will fix that from what ive read.
still good gentics makes good money
then again why am I high on your shit and not mine.
It appears that you have provided some definitions of “synthetic” or have quoted someone else providing these definitions. I thought it would be appropriate to provide the legal definition of synthetic from the United States Code.
According to 7 United States Code number 6502: The term “synthetic” means a substance that is formulated or manufactured by a chemical process or by a process that chemically changes a substance extracted from naturally occurring plant, animal, or mineral sources, except that such term shall not apply to substances created by naturally occurring biological processes.
This would not include separation or purification processes. And this would not include naturally occurring biological processes - like combustion or degradation or reaction to light, etc. In my previous experience as a natural product synthesis chemist - the line is not fine here. But is instead a clearly drawn line in the sand. Separation and purification being very key in many other places - especially where patents come in, since it is the method not the natural compound that is being “owned”.
There’s still much time to submit comments. It seems that many are on different sides of this issue. Always the regulators will bring forth rules that limit our abilities to do activities - but it is our voice that will change this road. Our voice must be civil, respectful, and scientific - backed by the specific knowledge of the impact to our communities, businesses, and the general economy of our industry.
So when you are writing your comments, please include your thoughts and stance on these items. And have your friends and family do the same. This is no different than any other regulatory change - the more voices the better.
Cheers all.
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I agree with this. I don’t think there is any traction in debating whether or not d8 or CBN currently being offered on the market is synthetic. It is (unless someone is using chromatography to only get the small amounts present in the original plant which doesn’t seem profitable). It is synthetic whether you used heat, uv light, lewis acid, bronsted acid, inorganic acids, organic acids, food grade chemicals, a pH adjusted adsorbent, ozone, oxygen, chloranil, ddq, etc. That will be classified as synthetic. I can’t comment definitively on whether the Farm Bill excuses hemp-derived synthetic compounds (seems shaky to me but I’m not a lawyer), but I feel that’s the only relevant discussion. If you’re making more d8 or CBN through a deliberate chemical process, it is synthetic. But I think whether or not they are synthetic is a pretty easy discussion to come to a logical conclusion about.
Edit: not the only relevant discussion. I can’t say that. But trying to say they aren’t synthetic products seems like a misuse of the community’s energy.
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How would you define CBD created by decarboxylation of CBDa in the lab?
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How would you define CBD created by decarboxylation of CBDa in the lab?
The different regulatory bodies use the term “natural” in different ways. The FDA is my go to organization for any food, drug, supplement, and often for things related to labs. They have a section specific to the difference between synthetic (aka Artificial) and natural products.
This definition from the FDA:
21 CFR Part 501 Subpart B (3) The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors, include the natural essence or extractives obtained from plants listed in subpart A of part 582 of this chapter, and the substances listed in 172.510 of this chapter.
I realize that we are not talking about “flavorings” - however the difference as provided by the Agency is that naturals can be extracted from plants/animals and that through normal chemical processes: extraction, distillation, hydrolysis, roasting, heating, and enzymolysis are still natural products.
So since Decarb is done via heating one could conclude that it is a natural process. Hydrolysis and enzymolysis really extend the term natural as well, IMO.
At some point standard documentation will be made by the USDA and FDA that will be more specific about this. Already the USDA Final Interim (oxymoron, I know…) Rule clearly states that CBD production is part of the program, so that intent is clear at least.
I’ve almost got myself convinced that appropriate procedures for the collection and documented destruction of any THC is what is required here - the USDA rule and the Farm Bill include the language
procedures for disposing of non-compliant plants
Seems like a bit of a stretch that an extraction product would be a plant. However, the definition of hemp states
any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 THC of not more than 0.3 percent on a dry weight basis.
Which would include this. The real key here is making sure that whatever derivative, extract, cannabinoids, isomers, acids, salts, and salts of isomers does not include THC greater than 0.3% on a dry weight basis.
That’s what they have written to try and tangle this up - and they have done so knowing full well that many of the methods used in the industry (if not all…) may accidentally or incidentally concentrate even undetectable amounts of THC from a raw material. That is why we must provide them the science on why what they have said is inappropriate, direct the conversation back to states rights to define how/when/where THC waste is disposed of safe from environmental damage and diversion.
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