您的标签是否应包含“CBD”一词？
一年前，我们曾探讨过大麻二酚（CBD）产品的命名变更趋势。许多CBD企业已将"CBD"一词替换为"大麻提取物"和"全谱大麻"等表述，以期降低面临FDA及地方执法行动的风险。正如我们此前所阐述的，这一转变背后的主要动因似乎在于——
CBG是否合法？CBG是什么？
回顾2019年，大麻二酚（CBD）成为大麻产业的焦点之年。这种成分持续渗透至各类消费品领域，从碳酸饮料到运动文胸无处不在。这场CBD热潮酝酿已久：早在2015年我们便开始关注这种大麻素——当时行业正全力推广CBD产品，而美国食品药品监督管理局（FDA）
Hemp and CBD: Submit Your Comments on USDA Interim Hemp Rules By December 30
The hemp industry is up in arms over the USDA’s interim rules establishing a domestic hemp program. As of this writing, you can find some 900 comments published on regulations.gov. The din of complaints about the deleterious effect of several rules caused Senator Chuck Shumer to send a letter on December 3 to U.S. Agriculture
The Risks of Infusing Hemp-CBD Topical Products with Essential Oils and Menthol
As we have previously discussed, the sale and marketing of hemp-infused cannabidiol (“Hemp-CBD”) cosmetics, such as salves, lotions and creams (collectively “Topicals”), present the lowest risk for businesses wishing to enter this booming industry. We have quite a few clients pursuing this path, from small-batch manufacturers to national retail outlets. Generally, a Topical may be
Federal Antitrust Scrutiny and (Certain) Cannabis Deals
If you follow state-by-state legal cannabis legalization, you’re aware that despite the federal illegality of cannabis, certain federal agencies police the cannabis industry like they do any other legal industry. For example, the NLRB has been known to go after cannabis companies engaged in hostile workplace conduct and the Department of Treasury contemplates banking services to
CBD Topicals are Not Immune from FDA Scrutiny, as Recent Warning Letters Show
We’ve written extensively on this blog about industrial hemp-derived CBD products, including CBD comestibles, CBD pet products, CBD in alcohol, and CBD topicals. Of all these categories of goods, the CBD industry seems to have reached a consensus that CBD topical products present the lowest level of risk for businesses, hence companies like CVS, Walgreens,
Why the USDA Testing Rules Will Hurt the Hemp Industry
On Tuesday, the U.S. Department of Agriculture (“USDA”) released its interim final rule for the production of hemp under the 2018 Farm Bill. Although these rules are not final, they will go into effect once published in the Federal Register, at which point a 60-day public comment period will begin. Upon the publication of the
Natural Products, the FDA and Cannabis Regulation
I recently attended two events in Utah headlined by the United Natural Products Alliance (“UNPA”) where its President, Loren Israelsen, discussed the voluminous public comments received by the FDA in response its latest round of questions regarding how over-the-counter cannabis extracts like CBD should be regulated. Israelsen provided numerous takeaways for UNPA members and their
Should You Import Hemp to the United States?
The passage of the 2018 Farm Bill and the legalization of hemp and hemp-derived products has sparked strong business interest from foreign stakeholders. For the past few months, our firm has received numerous inquiries from existing and prospective clients about the legality of importing the agricultural crop and its derived products, particularly hemp-derived CBD (“Hemp-CBD”),
Grading the Presidential Candidates on Marijuana: Overall Rankings
In a recent 13-part series, we reviewed the stance of each of the 2020 presidential candidates’ on marijuana, and we assigned each candidate a letter grade corresponding with our analysis. Our grading criteria is as follows: Current stance on marijuana: What have they recently said about marijuana legislation? When did they adopt this stance? We