Hemp CBD Q&A – A Few More Questions and Answers

On September 17,I, along with my colleagues, Griffen Thorne and Vince Sliwoski, held a webinar entitled “Hemp CBD Q&A,” a recording of which is available on our blog.

During the webinar we received more questions than we could answer, so today, we go over a few of these remaining questions.

Does any state have a model law(s) governing the licensing of in-state hemp processors?
Many states, including Oregon and Colorado, expressly regulate the processing of raw hemp. However, there is no uniform licensing program across state lines. That said, most states where processing is allowed mandate that processors secure a license from their state Department of Agriculture and comply with a wide range of regulations, including but not limited to testing and record keeping requirements. If the THC % changes over time in storage does that put the warehouse at a legal risk for non-compliance or the grower/owner? In light of the recently published Interim Final Rule by the Drug Enforcement Administration (the “Rule”), anyone handling hemp that contains more than 0.3% THC level on a dry weight basis is at risk of criminal liability. The Rule, in part, provides that “any such [cannabis] material that contains greater than 0.3% of

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