The Hemp Hound Agency Webinar 27/10/23



Open discussion with Mark Tallon of Legal Products Group Ltd, and Stephen Oliver of The Canna-Consultants.

Stephen came to talk about the letter from @TheCannaConsultants to the @FoodStandardsAgency(FSA) to request that products exceeding the new “advisory” 10mg Advised Daily Intake (ADI) can be reformulated to ensure that they reflect that ADI should it become enforced.

Let’s put it this way, if the FSA doesn’t provide some ‘get out of jail free card’, they’ve provided a level that when enforced, which it will be, will have a noticeable effect on their public list for CBD products.

Mark came in to talk about the uncertainty surrounding the evidence used to create that 10mg ADI, and the article from NutraIngredients where he calls for the hemp and CBD industry to call out the lack of transparency surrounding the data used to come to such a low number.

Links are available in the comment section for this video.

Questions to Stephen Oliver:

@00:02:39 The recent FSA “10mg Advice” has created a paradox for brands with products exceeding this recommended limit that are listed on the Public List. Can you provide your perspective on the challenges these brands face and the impact on consumer choice?

@00:14:50 In your recent statement, you highlighted the dilemma brands encounter when attempting to comply with the 10mg ADI by reducing the CBD content of their products. Could you elaborate on the FSA’s classification of such products as “new to market,” and how this affects their eligibility for the Public List?

@00:34:57 It’s evident that the FSA’s “10mg Advice” and the subsequent actions of brands and retailers have caused confusion in the industry and among consumers. What measures do you believe the FSA should take to provide clarity and support responsible brands during this transitional period?

@00:50:42 How can the FSA strike a balance between consumer safety and supporting the industry’s growth and economic contributions?

@00:56:44 Your statement emphasises the importance of consumer choice and access to safe products. Can you share your recommendations for creating a policy that allows companies to produce 10mg single-consumption units while maintaining their products’ presence on the Public List?

@01:09:32 With the FSA stating that the ADI applies to all products, the industry appears to be in a challenging position, caught between complying with the FSA’s conservative “10mg Advice” and maintaining regulatory compliance. How can industry stakeholders
collectively address this issue and advocate for a more balanced approach to CBD
regulation in the UK?

Questions for Mark Tallon:

@01:13:45 The recent change in the FSA’s recommended daily dose for CBD, lowering it to 10mg per day, has raised concerns and sparked discussions within the industry. What is your perspective on the information used to determine that figure?

@01:16:45 The FSA has categorization of CBD products into Group A (CBD isolates), Group B (CBD with other cannabinoids), and Group C (hemp extracts). Do you believe that the 10mg ADI should be applicable to all three groups, or should there be distinctions in the recommended dosage for different product types?

@01:21:16 The FSA has recently indicated that the new ADI may impact the CBD public list. How do you foresee this change affecting products currently on the market and either awaiting authorisation, or for those products on the public list still labelled as “awaiting evidence”?

@01:27:44 As an industry, how can we address the concerns surrounding the 10mg ADI while recognizing it as a starting point?

@01:39:01 The FSA initially stated that the current ADI is not legally binding but rather a view, but now we see that there are discussions that will look at the function of the public list, presumably on the basis of the ADI. How can the industry work together to ensure that the FSA is aware of the additional data and studies available?

Q&A:

@01:49:07 Where did GW’s 16 lab reports go?

@01:58.43 Would novel foods for CBD products have been a rockier road without those lab reports?

@02:04:20 (Question from the Chat Box) How does this news affect all of the non-food full-spectrum products?

@02:06:50 (Question from the Chat Box) Irish food regulators are trying to whitewash THC out of the supplement market, have they coordinated with the ACI at all?

@02:11:05 ​(Question from the Chat Box) Is labelling that proposes higher dosages (above 10mg daily) for limited periods of time likely to be compliant in future?

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