‘The CBD Grey Market: Next Steps for UK Regulations Following the ACMD’s Recommendations’ – APPG Minutes 26.01.22
All-Party Parliamentary Group on CBD Products
“The CBD Grey Market: Next Steps for UK Regulations Following the ACMD’s Recommendations”
2nd Meeting
January 26, 2022, 10:00-11:00
Porcullis House, Westminster & Online
Minutes
Present
Crispin Blunt MP
Andy McDonald MP
Christine Jardine MP
Baroness Manzoor
Gillian Cowell - office of Stuart McDonald MP
Charlie Beckwith - office of Christine Jardine MP
Ed Warner - office of Crispin Blunt MP
External
Nick Morland - Tenacious Labs (secretariat)
Adrian Clarke - Tenacious Labs (secretariat)
James Bagley - Tenacious Labs (secretariat)
Andrew Cutbill - Tenacious Labs (secretariat)
Mike Barnes - MCCS
Charles Clowes - CIC
Jamie Bartley - CIC
Lorenza Romanese - EIHA
Mark Graham-Woods - CTA
Kyle Esplin - SHA
Rebekah Shaman - BHA or
Renata Legierska - CSAB (Jersey)
Toby Webster - CDPRG
Jade Proudman - Charlotte’s Web
Andrew Richards - Hudson Sandler PR
Apologies
Apologies have been received from:
Ronnie Cowan MP; and
Baroness Finlay of LLandaff
ACMD Consumer Cannabidiol (CBD) Products Report
Crispin Blunt MP, chair of the APPG, welcomed everyone to the meeting, and invited Professor Mike Barnes, Chair of the Medical Cannabis Clinicians Society, to give a scientific view of the recent Advisory Council on the Misuse of Drugs (ACMD) Consumer Cannabidiol (CBD) Products Report.
Science View
Prof. Mike Barnes explained the current regulations in place and advocated a move away from the 1mg rule, as per the ACMD report.
He welcomed the focus on delta-9 THC, and moved to discuss the Lowest Observable Adverse Effect Level (LOAEL).
He welcomed the idea of a limit per “unit of consumption”.
He stated that there is a problem with the advised 50mg limit per unit of consumption, arguing that it has been derived with arbitrary Uncertainty Factors.
Industry View
Charles Clowes, Director of the Cannabis Industry Council, introduced the industry view on the ACMD report. He started with his three key takeouts from the report:
it is a comprehensive report written from academia but lacks the consumer and industry perspectives;
the THC level allowed is still the same but structured differently which introduces additional uncertainty for consumer and industry; and
the UK should look to take control of the industry with an international focus.
The group discussed the No Observed Adverse Effect Level (NOAEL) and LOAEL provided by Health Canada in Charle’s slides. He advocated locking the THC/CBD content into a ratio to protect consumers.
The use of Certificate of Analysis (COA) documents was also advocated, for greater consumer knowledge of the products.
Discussion
Lorenza Romanese introduced the discussion of the report, stating that the level of contamination in a botanical product could not be compared with that of a food supplement - as there would be more natural contamination.
She also proposed that the focus should be on an overall daily intake (TDI), instead of the ACMD focus on a maximum level. She welcomed the idea proposed by Charles Clowes regarding ratios of THC/CBD content.
Lorenza questioned whether we should look at the non-psychoactive dose as a NOAEL. She welcomed the arguments proposed by Prof. Mike Barnes that the Uncertainty Factors deriving the “unit of consumption” are arbitrary and requested the evidence underpinning the recommendations.
Crispin Blunt MP thanked Lorenza for her comments and then welcomed other experts present to help guide the discussion with regards to public interests.
Crispin acknowledged the misgivings around the ‘Uncertainty Factors’. He asked for other comments regarding the discussion and invited Jamie Bartley to speak.
Jamie Bartley stated that the home office would be producing their report at the end of March, so the industry report should be provided within the next 4 weeks.
Katie Stewart (Desk Officer at the Cabinet Office, Economic and Domestic Affairs Secretariat) was recognised as the official Jamie had been talking to.
Crispin Blunt MP then welcomed Nick Morland from Tenacious Labs (APPG Secretariat) to lead the next section of the meeting.
APPG Progress to Date
Nick Morland informed the APPG of the foundation of the SAB (Secretariat Advisory Board), a group made up of all major UK and European Trade Bodies, created to advise the Secretariat on latest CBD industry news, views, and research findings.
Nick explained that the SAB meets as an informal gathering two weeks before each APPG meeting. He welcomed any additional members of the meeting who wished to join the SAB.
He then asked Crispin Blunt MP if it would make sense to bring a summary of the industry position to the next APPG meeting to help move the discussion.
Crispin Blunt MP invited Kyle Esplen to speak.
Kyle Esplen stated that the ACMD report would not be supportive of the domestic industry re production and development, and would favour CBD made from isolate imported from America.
Nicholas Morland recognised the impact of the ACMD report on the Channel Islands. He proposed the Secretariat Advisory Board created a short agenda for the next meeting.
Crispin Blunt MP stated that any document would need to be received within a month from now.
Charles Clowes emphasised Kyle’s point that the industry would miss out on the environmental and economic benefits of growing hemp domestically.
Rebekah Shaman acknowledged that CBD consumers would rather hemp-derived CBD to CBD isolate based products.
Nick Morland emphasised the importance of not missing out on the rapid industry growth. Crispin Blunt MP agreed and recognised the importance of this APPG in achieving this.
Lorenza Romanese agreed with Rebekah Shaman that CBD isolate is less preferable to hemp-derived CBD. She argued that the only product that the domestic industry could compete with is full spectrum CBD.
Crispin Blunt MP thanked Prof. Mike Barnes and Charles Clowes for their presentations, and Lorenza Romanese for leading the discussion.
He stated that he looks forward to receiving any documentation in advance of the next meeting.
The meeting terminated at 11:00am