A couple of weeks ago I wrote about the USDA’s decision to reopen commenting on the interim hemp rule for 30 days. (Here is a good article by Hemp Grower magazine on the reopening). The deadline for submitting comments is October 8. So get your comments in! The USDA is particularly interested in comments on certain topics and, in my prior post, I discussed one of those topics, Liquid Chromatography Factor, 0.877, and its importance to the Hemp-CBD industry. Today let’s discuss another topic, Sampling Methodology – Flower v. Whole Plant.
Before getting into that, I would be remiss not to mention another topic that merits comment to the USDA. That is the DEA’s interim final rule suggesting that in-process hemp extract shall be treated as a schedule I controlled substance during any point at which its THC concentration exceeds 0.3 percent on a dry weight basis. Nathalie Bougenies recently wrote about a lawsuit filed against the DEA by the Hemp-CBD industry and we have written several times about the problems with the DEA’s rule:
Although the USDA cannot compel the DEA to revise or withdraw the interim rule, the industry ought to tell the USDA that this conduct