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Questions posed to the FSA
23rd July 2020The Canna Consultants
Questions posed to the FSA
We have reproduced the questions as they have been submitted in order not to interfere with them. If you are unable to answer the question as drafted, we would encourage you to answer what you feel is the import of the question in order that market participant is not disadvantaged by potentially poor language selection in their phraseology.
The FSA’s “New to Market” Policy: Is it Justified?
21st July 2020The Canna Consultants
The FSA’s “New to Market” Policy: Is it Justified?
Is the FSA's policy that any CBD "New to Market" products will be treated differently than those "Already on the Market" justified despite there being no difference in their potential risks? Perhaps the more telling question is whether the policy will be sustained in the face of an inevitable legal challenge?
Is there a Sting in the Kanavape Tail?
Is there a Sting in the Kanavape Tail?
In May we published an analysis of the Judgement of Advocate General Tanchev in respect of the Kanavape case, “Can the movement of CBD within the European Member States be prohibited it if is derived from prohibited elements of the plant?”
What Ever Happened to Trustcanna – The Certification to Solve All?
15th June 2020The Canna Consultants
What Ever Happened to Trustcanna – The Certification to Solve All?
The recent news that Mike Harlington, the now ex-Chairman of the CTA, has been ousted by the organisation’s board (now led by Tom Whettem) was reported by The Canna Consultants here. The news led us to take a delve into TrustCanna... and what did we find?
Who Now Controls the Cannabis Trades Association: An Association for the Many or the Few?
15th June 2020The Canna Consultants
Who Now Controls the Cannabis Trades Association: An Association for the Many or the Few?
It was with interest that on the evening of 13th June 2020 we discovered (from the Business Cann website) that, what we at The Canna Consultants had thought was on the cards for many months, had actually come to pass. The headline read ““Disagreement” sees Europe’s largest trade association lose its Chairman”.
Self Regulation Does not Work
15th June 2020The Canna Consultants
Self Regulation Does not Work
WHY SELF-REGULATION OR REGULATION THROUGH QUASI-TRADE BODIES/ASSOCIATIONS/GROUPS WILL NOT WORK. The Food Standards Authority of Ireland has published a Report identifying the CBD Regulations applicable in the Irish Republic and containing the results of their analysis of 38 products being sold on the Irish market. The analysis results found by the FSAI are very similar to those found by a similar study of UK products undertaken by the Centre for Medicinal Cannabis (CMC) and published in a report the Summer of 2019.
Beware the False Race for Validation
Beware the False Race for Validation
The race for earliest submission of a Novel Food Dossier is a false one. This is especially the case when submissions made thus far, so we understand, lack the appropriate scientific data in respect of end products for which Authorisation is being contended and, in some cases, lack any scientific data in respect of the subject of the application at all.
Can the Movement of CBD within European Member States Be Prohibited if it is Derived from Prohibited Elements of the Plant?
Can the Movement of CBD within European Member States Be Prohibited if it is Derived from Prohibited Elements of the Plant?
On 14th May 2020 the Advocate General (Tanchev) of the Court of Justice of the European Union (CJEU) delivered their Opinion on the above question. The result is both a “Yes” and a “No”: National restrictions by Member States are possible, but such restrictions as are sought to be enforced must be (a) justified and (b) no more than necessary in order to achieve the justified aim.
CBD Products for Athletes
10th March 2020The Canna Consultants
CBD Products for Athletes
Recently we have seen an increase in the marketing of CBD products to professional athletes, which raises headlines in the media, and concerns with ourselves. While it may be that there are real (or perceived), benefits from CBD for professional athletes, we caution the use of products without a thorough program of due diligence. The responsibility for that due diligence cannot be abrogated by the individual and the liability for any transgression rests solely with the athlete.
The Novel Food Process
9th March 2020The Canna Consultants
The Novel Food Process
Novel Food Authorisation: The Starting Point, The Principle, The Practical Effect, The Sequence. Member States of the European Union are not the only jurisdiction to operate a system which seeks to manage what novel food and novel food ingredients can be made available to their citizens, but they do operate probably the most stringent system and require the most comprehensive data submissions in order to gain successful market authorization.
Be Even More Careful Who You Listen To
9th March 2020The Canna Consultants
Be Even More Careful Who You Listen To
Is a Novel Food authorisation required for a Brand’s end product? We previously published a document to correct mis-statements that were being made to market participants by, so-called, experts in the industry. Almost a month on from the FSA’s announcement concerning Novel Foods we continue to read the same mis-statements published by those same, so-called, experts.
UN Vote on WHO Proposals
9th March 2020The Canna Consultants
UN Vote on WHO Proposals
The United Nations is certainly not going to be the answer to the THC “issue” in the short-term and is unlikely to be the answer in the long-term either. This month the United Nations was due to vote on proposals made to it by the World Health Organisation, one of which was: “Preparations containing predominantly cannabidiol and not more than 0.2 per cent of delta-9-tetrahydrocannabinol are not under international control”.
FSAI Report Summary
26th February 2020The Canna Consultants
FSAI Report Summary
FSAI DEMONSTRATE THAT REGULATORY COMPLIANCE AND QUALITY CONTROL ARE NO BETTER IN IRELAND THAN THEY ARE IN ENGLAND. The Food Standards Authority of Ireland have published a Report identifying the CBD Regulations applicable in the Irish Republic and containing the results of their analysis of 38 products being sold on the Irish market.
FSAI THC Removals
26th February 2020The Canna Consultants
FSAI THC Removals
FSAI MEAN BUSINESS CONCERNING THE REQUIREMENT FOR THC CONTENT IN CBD PRODUCTS. Previously we published a Summary of the FSAI Report into their testing of CBD products. The FSAI has not waited long to bare its teeth. Certain Brands have had some of their products removed already, including one high profile and “industry-leading” Brand which claims to be THC-free in respect of the very batches tested by the FSAI.
Be Careful Who You Listen To
20th February 2020The Canna Consultants
Be Careful Who You Listen To
Following the FSA’s announcement last week on the Novel Foods position, we observed that many so-called experts were coming out of the woodwork and positing questions that, if they held the expertise that they assert, they would know the answer to.
What is meant by a ‘Valid’ Novel Food application
14th February 2020The Canna Consultants
What is meant by a ‘Valid’ Novel Food application
Clarification of the FSA position statement on 13 February 2020. For those who have not been involved in the design of the structure, the FSA’s announcement took many by surprise. Quite understandably, market participants were digesting the Food Standard Agency’s morning announcement and asking themselves, and the wider industry questions about what it meant and how it would be implemented.
There is no exemption for THC content in CBD products
13th February 2020The Canna Consultants
There is no exemption for THC content in CBD products
What are the applicable criteria for a product which contains THC to receive an exemption from the underlying criminal law? FSA permits continued sale of CBD products provided that certain conditions are met, one of which is that they “do not contain substances that fall under drugs legislation”. The Canna Consultants have always held the opinion that there is no exemption for THC content in CBD products. Read our comprehensive analysis of the law on THC content.
The UK Cannabinoid Industry – The Road to a Better Future
13th February 2020The Canna Consultants
The UK Cannabinoid Industry – The Road to a Better Future
This document was provided to key Stakeholders in October 2019. We are pleased that the FSA has adopted the foundation structure that The Canna Consultants advocated. On 13th February 2020 the Food Standards Agency announced its intended approach to the issue of CBD and Novel Foods classification.
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THE CANNA CONSULTANTS
COMPANY INFORMATION
MAST CONSULTING LTD
Company Number: 12191810
ico. Reg. Number: ZA547887
VAT Reg. Number: 334 8110 23
COMPANY ADDRESS

20-22 Wenlock Road
London, N1 7GU
ENGLAND

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