I agree. Amazingly enough - the USDA (which has jurisdiction over Hemp, even the DOJ said so…) already has a guide for “natural” vs “synthetic”. It makes very little sense…IMO - but its already a published document. It all goes back to things being “organic or not organic”. And they don’t mean carbon based compounds when they say organic…they mean agricultural practices. (We did have a bit of a discussion on this earlier in the year…)
Here is the paper where the terms we discussed and a plan forward was proposed.
And here is the guidance document - its like a flow chart.
And here is a legal white paper to make it all easier to understand. -shrug- Probably not really better.
So we are back to semantics. I can talk FDA stuff all day, however, in this case the USDA is responsible for the definition (because Farm Bill…) and if the FDA was responsible then we’d all be in the camp that says no cannabis derived products are legally allowed into interstate commerce. Their specific about CBD only - since people seem to care about that specifically. But their rules apply to all cannabis derived products that don’t have more than 0.3% d9THC in them.
I still find this whole conversation to be really interesting. I’m a natural product organic synthesis chemist. I feel like I understand the difference between starting from almost nothing to make what you want and conversions like I posted earlier from Mechoulam. I’ve made hundreds maybe even thousands of new compounds using fully synthetic methods. And I’ve made hundreds of new compounds (and identified them…) using what the Fam seems to be calling semi-synthetic compounds.
Its all synthetic according to the USDA unless you are using a specific set of “biological” processes as shown in the definition and the flow chart. I suppose that’s why there are always lawyers on this stuff…you know trying to prove legality one way or another. Since it has nothing to do with actual science and all to do with semantics of the statutes and Final Rule regulations.