@Bret_HoneyGold had asked that I share the draft CRA rules on conversions that were resoundingly withdrawn by the agency last year after an outcry from small growers and processors in the state. I gave a pretty good speech/report about why we should 100% allow these things, especially since they are already in the state, already in products made and sold in Michigan, and in some cases the people crying FOUL! were the ones making the products using the converted CBD products.
Sadly, I was not loud enough to sway the CRA. So now in Michigan the only way for your to legally have these products (if you wanted to follow the regulations as given by the CRA and the statutes of Michigan) would be for you to have a licensed processor AND then submit a research and development proposal to the CRA, have that proposal approved, and then prove that your products are safe and what not. No one has publicly done this - but I’ve heard that it is being done. Still there are no approved conversion products in Michigan yet - at least not publicly.
In any case - you can read about the old draft rules, which were incredibly flexible here. On pages 26 to 30 of the Michigan Register.
And if you are interested - there are new pending Industrial Hemp rules being considered in Michigan just now. So if you care about these things - you ought to take a look and see how it impacts you and your business/customers/patients, etc.
You can see the draft of the new industrial hemp rules being considered after the rules failed to gain ground. Its possible there will be more changes - you can always go to this section of the ARS if you are interested in these things and search hemp or cannabis or marijuana and any pending rule changes will come up for you to see.
These “new rules” which are in draft don’t include anything about being able to make conversion products and have them available on the market in Michigan. What they do - is make any product which might have hemp concentrates in it have completely limited THC amounts (regardless of 0.3%) limiting each dosage to no more than 1mg THC and each container to no more than 10mg THC. THC in the CRA happens to include D8, D9, etc all rolled into one. -shrug- And there are specific limits to how much d8 there could be as well in the rules.
The new rules don’t appear to apply to topical products. Really just edibles are discussed.
Unfortunately that cat is outta the bag forever. I don’t ever see a time where these conversions are illegal.
Just like the hemp people lobbied for the legalization they will lobby even harder for these conversions. It’s the only thing keeping cbd and hemp alive
These rules went into effect last year. I don’t know that I saw a bunch of stuff being pulled - but I do know that people have been cited in disciplinary actions. So have solid documentation on where your stuff came from - show that its not converted from CBD (which is wholly possible since you can degrade it from THC). Or submit an R&D proposal to the CRA and have them approve it.
But yeah - the CBN gummies would be illegal under the rules that were passed and went into effect last year. Not like anyone seems to care about the rules (but with all the new enforcement going out, I have a feeling people will start to care more soon…)
This new director isn’t fucking around. Which is a good thing!
Between the labs, and now even grows and processors pushing shit out the back door, the only way to make this industry viable is enforcement.
Because of all the poop soup that was slang over the last few years, this is the end result.
I looked at the R&D proposal and while it’s doable, it’s a bit over the top in my opinion. The remediation is the same way. It’s not hard to remediate most things (fuck you pyrherins ), but, they make it damn near impossible for you to be able to do it.
I haven’t seen this. I’ve only seen people bringing stuff in, not bringing stuff out. And that’s what enforcement has been working on mostly (you know out of state stuff…)
I agree that Dir. Hanna is focused on enforcement, as that is what everyone has asked him to do. I still don’t 100% know why that’s what people are focused on. I mean on the one hand people are angry that anyone is going to prison or still in prison for this sacred plant. And on the other - everyone wants the cops to come in and shutdown their competitors.
Its a strange space. I suppose there are restaurant owners who want to see the health department close down other spots… but it seems to me most people (from the outside looking in…) are just focused on creating the best customer experience while being as efficient as possible. -shrug-
I agree that the R&D procedures are a bit lengthy. But I’ve gone through 2 now, and its not as bad as it seems on the surface and the science team is friendly and mostly helpful, even if they make you jump through hoops. The hoops are always big enough for you to jump through and they are MUCH nicer than the FDA. <3
I noticed they also want to have live inventory updates to their monitoring system on industrial hemp side.
(4) A producer shall document all industrial hemp obtained by the facility and shall make those records available to the agency upon request.
(5) A producer shall accurately enter all transactions, current inventory, and other information into the statewide monitoring system as required by the industrial hemp research and development act and any associated rules promulgated by the Michigan department of agriculture and rural developmentagency
CBN has real potential to be an effective anti insomnia cannabinoid. Acetates and other cannabinoid esters have value too I think (when used properly in edible formulations.) The production of these should be standardized and properly regulated. Everything else is kind of redundant and I think should be studied by qualified people rather then unleashed on consumers by greenrushers looking for a buck. It’s sad that regulation in this country is driven by industry lobbyists and moral panic rather then science.
Michigan made a law last year that said you cannot sell other hemp derived products here except through licensed retailers. They fully pulled all those products under the umbrella of the CRA and then licensed operators said “nope we don’t want these products here” and that kind of put a stop to well everything.
You can still get CBD from hemp and CBG - but really anything else is not allowed without a special R&D permit. This happened in July of last year. It was quite a big stink for a minute.
I don’t know that everyone follows the rules. But there are statutes to punish those who do not follow them, should the state decide they want to enforce them. -shrug-
I want to buy and use hemp THCA with our processor-handler license for things like pre-rolls, but CRA says no. @Cassin any idea if that rule could be changed?
Your link to the old rules isn’t working so I uploaded the file.
Thanks for adding the pdf. I noticed the links were not working today and I was like… well fuck where did I put these.
Sure that could be changed. It would require a change of the definition of THC in the MRTMA legislation and 3/4 majority affirmative vote. Right now any THC (THC, HHC, THCv, THCa, THC-O, etc.) counts as THC under the current definition.
So its not a “rule” but a statute. Gotta get with a legislator to ask for an amendment to get it changed. There’s currently bills out with MRTMA open in the House, so maybe someone from the Senate? Or sometime next year.
Otherwise - you’d have to uh… buy the compliant hemp flower with 0.3% of less of THC in it. Michigan doesn’t allow the higher THCa hemp flower, because of the MRTMA definition either.
There is, of course, plenty of THCa in Michigan that’s already in METRC that could be used, including THCa. So its not the THCa that’s the issue, its the source of the THCa. They only want licensed marijuana plants to be able to produce THCs - until the law changes.
There is also a public meeting on 9/11 - where this could be brought up. I’m sure they will say the same though in response, that the statute is currently clear and the law would need to be changed to allow for this.
), but, they make it damn near impossible for you to be able to do it.