Notes on Teleconference with FSA, 1st February 2019


Peter Reynolds, Cannabis Professionals (CannaPro)

Alison Asquith, FSA

Colin Clifford, FSA

Paul Tossell FSA

1. FSA advised that the industry has “one last chance” to submit evidence of significant consumption of CBD extracts within EU area prior to 1997.

2. CannaPro requested clarification as to which authority stipulates this deadline and how long the industry has to respond.

3. FSA advised that it has set the deadline and evidence must be submitted within one month.

4. FSA further clarified that this action was initiated by the EU Novel Foods Working Group.

5. CannaPro took a robust position that one month was unreasonable and suggested three months.

6. FSA will confirm early next week whether three months is acceptable. There was a suggestion that, if so, an interim submission would be required within a month.

7. CannaPro clarified that the products in question could more accurately be described as whole plant low-THC cannabis extracts.

8. CannaPro requested clarification on differing compositions of extracts, eg, CBD concentrations from 2% to 40%.

9. FSA stated that evidence must be for a broad range of compositions. If all evidence is for use of low concentrations of cannabinoids it would not suffice for a 40% product.

10.  CannaPro requested clarification on CO2 extraction.

11. FSA confimed that use of CO2 extraction does NOT make a product novel. If evidence is of products extracted with a different solvent that will be OK. It is the composition that matters, not the extraction method.

12. CannaPro took a robust position throughout that it is unreasonable to turn vague, general discussions about the issue into a short deadline that is an existential threat to the entire industry.

13. FSA responded that it has had substantive discussions with parts of the industry which have been fully engaged and aware of the imperative to provide the evidence.

14. CannaPro understood this to mean the EIHA and CTA. Clearly these bodies cannot in future purport to represent the industry without open communication.

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