Why Your CBD Oil is Going to Triple in Price: The 2020 USDA Interim Rules

The rules that will be screwing over Flower strain growers are highlighted below:

• Delta 9 THC was reclassified as being Total THC (THC-A plus DELTA-9)

• Hemp must be tested by DEA registered labs 15 days before harvest from the top 2” of the plant with bud

• The USDA encourages using GC method for hemp testing (Which over bloats the THC numbers and is generally inaccurate in results.) 

• ALL states must comply with the points highlighted in their plan and adjust all their plans to include their points. Any laws a state has now get thrown out the window for the USDA’s.

• USDA refused to put out an official seed program as they speculate a seed will turn into a legal plant in one state will grow hot in another.

In simple, to grow Hemp for CBD growers’ biggest worry is no longer just DELTA-9 but now it’s THC-A, the non-psychoactive pre curser to DELTA-9. THC-A only turns into DELTA-9 if it is smoked, and does not convert in the CBD oil making process. All of hemp is now being discriminated as though it is all for smoke able bud. The legal limit is still 0.3% which is a number too small for total THC as THC-A will be on average 0.3% on a flower strain HEMP plant, not marijuana.

To add to the mayhem the testing practices the USDA is enforcing will overbloat THC numbers so that no flower strain will test legal. In their report: 70% of all people growing hemp went into CBD oil. Meaning all 70% will lose their whole crop and no one is going to make money under that. In all full spectrum CBD will become scarce and other CBD oil will be low quality.  Add to this that with the test 15 days before harvest you will have growers cutting down their hemp early leading to mold and mycotoxic fungi issues from higher moisture content that will translate to the CBD oil.

To help change this and save CBD email the USDA these Comments at this email:

https://www.federalregister.gov/documents/2019/10/31/2019-23749/establishment-of-a-domestic-hemp-production-pr ogram#open-comment 

If you want to know more about hemp and the complications that can ruin a  crop and how to fix them go buy our book Farming Industrial Hemp: Not Your Daddy’s Tobacco.

Comments:

The rules are contradictionary. The testing methods only benefit fiber yet the report itself confirms hemp for CBD oil purposes. These rules will lead to the destruction of the American farmer as many do not have the experience to grow hemp in the very specific way the USDA presents with the interim rules. Many will lose 10’s-100’s of thousands of dollars. With High CBD strain’s variability in THC numbers and can go hot on a moments notice add on inaccurate and discriminatory anti-CBD practices that are being enforced and it will kill the market.

Total THC:

The reason this was implemented was because its’ seen THC-A when burnt will turn into DELTA-9. This only applies to the smoke-able bud market. That’s it. Even then Total THC is discriminatory as THC-A is a variable science with no accurate ways to make that number go down. They even confirm in the report that a legal plant will go hot depending on where it’s grown.  This will make it impossible to grow hemp for CBD oil as when CBD goes up THC-A will be on average 0.3%-04%, already over the legal limit. Under Total THC, THC-A will be the killing factor for many growers making a loss in profit for the whole industry. THC-A doesn’t get converted to DELTA-9 THC in the CBD oil market because the process never heats up the acid enough to decarboxylate it.

The definition should be brought back to the original European definition where they test for the DELTA-9 pre decarboxylate or Total THC should be brought up to 0.6% at least if a growing and prosperous CBD market is possible. Total THC’s legal number of 0.3% is based of the European definition where they test differently meaning that if the number is going to be inflated by THC-A, then the legal limit must also be brought up with it.

With these rules unchanged it will be more likely to win the lottery as a career then grow hemp for profit.

DEA Registered labs:

There aren’t enough labs to make this possible. The wait period alone will kill profit on crops as they sit and wait for either the slow process of a lab getting approved or a long wait list of an over worked lab. Most states have under 20 state approved labs and even less DEA approved labs and states like Tennessee where there are thousands of growers there would be a horribly long wait list that could get into the 6 month to 1 year range. Add on top of this if a crop comes in hot that will lead to a full loss of profit when it will be automatically reported due to the inflated numbers of total THC. Add that the grower takes on the cost of testing, the price will inflate because of high demand leading to inflated testing process and a severe stopgate in price a grower has to incur just to sell their crop.

There should be a plan of action to make sure there are enough labs in relation to the number of growers or make simply make this unnecessary. The more of a closed group you make the labs the harder it will be for the majority to get their items tested.

Testing methods:

Everything that was encouraged will further bloat numbers where a normally perfectly legal hemp plant will test hot. It’s a system that sets up the grower to fail and punishes them for growing. Taking from the top 2” of the plant will lead to the misleading results as THC-A grows upward. Being THC-A is the deciding factor now it, it makes it so no flower variety will come in legal. It will be legal hemp discriminated as marijuana because it was setup to fail. GC method already is documented as inaccurate in measuring THC and bloats the numbers overall because of the post decarboxylating process. With labs being needing to use the method to be certified will lead to a lot of failed crops. Add this with Total THC and the CBD industry is stifled and destroyed as something that would traditionally test 0.1% DELTA-9 could be inflated to the point of testing 0.3% just from practices alone before Total THC is added on.

The testing 15 days before harvest will lead to low quality plants. This will lead many growers to harvesting early and will not show accurate numbers. In 2019 alone many growers kept their plants in the ground until October because of a very unbeneficial hot wet summer. Because of this delay there no way to make a specific date to harvest. The practice of harvesting early will lead to a wetter plant more likely to develop mold and mycotoxic fungi that could hurt people in the long run. These rules should be changed to 6 weeks after planting, as this will lead to a consistent date of testing.