Is the solution to this no decarboxylating and leaving THC/CBD in the acidic versions since THCA is not Delta 9 this can be concentrated to the same levels of hot hemp.
Based on the way that the Farm Bill is written and on the way that this new clarification from the DEA is written this would not be the case. The legislation indicates a calculation for the amount of total THC - which includes a percentage ~87% of the THCa and the THC that are present.
Honestly - it seems to me that the key will be removal or degradation of THC before evaporation of the solvent pushes your concentration above 0.3% and making sure that your starting materials are as low as possible.
I’ve been noodling on this for the last few days and working out how to state my thoughts to the regulators.
Please do consider that even if you pull the THCa or THC out - there is still that waste product that has to be dealt with. So coming up with a method to remove that AND then destroy the molecule so that it is no longer THCa or THC - before the concentration goes above 0.3% seems to be process we are all now noodling on.
Skipping decarb won’t work - but I’m sure there are other processes that will.
Doing a search here looks like there are methods for doing a conversion from THC to CBN available. I’ve had limited success with this myself, very low yield/efficiency. If that could be done while still in original extraction solution - that may be the way to success.
Good luck to us all on getting this sorted and quickly.