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Cannabinoids

The cannabis plant produces over 480 compounds, dozens of which are known as cannabinoids. They're the active ingredients that are responsible for the way Cannabis affects people - whether they're enjoying it recreationally or using it to treat an illness. 

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Types of Cannabis
(All legal under 2018 Farm Bill when containing below 0.3% delta9THC )

THCa Dominant flower, A.K.A "Weed", "Pot". (Converts to Psychoactive Delta9 THC when heated). . Federally Legal if less than 0.3% Delta9 THC per gram. Marijuana on avg. only contains about 2% or less of Delta9 THC

Type II

Flower with mixed ratio THCa & CBDa (psychoactive and more medical). THCv could be included.

Type III

CBDa dominant flower (non psychoactive, medical)

Type IV

CBGa dominant flower. Sometimes CBDv & CBCa are included. All non psychoactive.

Type V

Flower with zero cannabinoids. Contains only terpenes and other compounds.

There are over 144 known cannabinoids, and they are all different. Some are found naturally in the plant, while others have been found in various other plants or in burned cannabis resin. Still, the way that these chemicals are produced often entails a chain of chemical transitions from one cannabinoid to another. 

These changes might be slight when it comes to the chemical structure, but these small shifts can cause big differences when it comes to the medicinal effects. As cannabinoids transform from one form to another, their level or type of psychoactivity and their specific therapeutic effects may change. This is evident with THCa and Delta9 THC.

 

Life cycle of Cannabinoids

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Life cycle of Cannabinoids

Cannabinoid Benefits

THCa vs Marijuana
(Chemically similar, Legally different)

You’ve likely heard of the cannabinoid tetrahydrocannabinol (THC),

also known as Δ9 or Delta9 THC, which provides cannabis with much of its medicinal value and also produces the mind-altering effects. Another commonly known cannabinoid is Cannabidiol (CBD), which is praised for its medicinal benefits without the intoxicating effects. While these are the most well-known and abundant cannabinoids, there are a plethora of other cannabinoids produced by the plant. 

 

In fact, the cannabis plant doesn’t actually produce Delta9 (Δ9)THC and CBD at all. Instead, the plants produce all cannabinoids in their acid forms: THCa and CBDa. We usually convert these cannabinoids to their neutral forms, Delta9 ( Δ9) THC and CBD, by applying heat.

 

Some cannabinoids start out as one cannabinoid and then are converted by the plant or by a person into another. For example, Delta9 (Δ9)THC begins in the cannabis plant as CBGa—the plant converts into THCa during growth and when heated by "sparking up" or cooking with it, it turns into Delta9 (Δ9)THC. If you notice similar names for two different cannabinoids, they are likely part of the same chain of transformations.

 

How is THCa flower legally grown?

THCA flower, despite its high concentration of tetrahydrocannabinolic acid (THCa), can be legally grown under USDA hemp laws if certain conditions are met. Let’s delve into the details:

  1. Total THC Rule:

    • The USDA (United States Department of Agriculture) mandates a pre-harvest analytical test for hemp plants. This test calculates the total THC levels, which is the sum of both THCa and delta-9 tetrahydrocannabinol (D9 THC).

    • The formula used is: Total THC = THCa (%wt.) × 0.877 + D9 THC (%wt.).

    • For a hemp plant to be legally harvested, the resulting total THC must not exceed 0.3% by dry weight.

  2. THCA Flower Production Process:

    • Hemp producers who want to cultivate THCA-rich flowers follow a meticulous process:

      • Research and Development: They spend time researching and developing methods to grow hemp plants with high THCa content.

      • Passing the Pre-Harvest Test: The hemp plant must pass the total THC pre-harvest test to ensure compliance with federal regulations.

      • Harvesting Within Legal Limits: Once the plant passes the test, it is harvested within the legal timeframe.

      • Controlled Drying, Curing, and Trimming: The harvested plant undergoes controlled drying, curing, and trimming to create THCA flower.

  3. Legal Status:

In summary, the careful cultivation and adherence to the total THC rule allow hemp producers to legally grow THCA flower while staying compliant with USDA regulations. 

THCa is Federally Legal!

(Check your State and local laws though.)

CannaMed Organics products are in compliance with federal law and therefore legal according to the following:

2018 Farm Bill & USDA Final Rule
In December of 2018, the 2018 Farm Bill was signed into law. It removed hemp, defined as cannabis (Cannabis Sativa L.) and derivatives of cannabis with extremely low concentrations of the psychoactive compound delta-9-tetrahydrocannabinol (THC)(no more than 0.3 percent THC on a dry weight basis), from the definition of marijuana in the Controlled Substances Act (CSA). The 2018 Farm Bill defines hemp as “any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers with no more than a 0.3% concentration of delta-9”. [1]

Additionally, CannaMed Organics complies with the USDA Final Rule [2] , which indicates that a hemp crop is considered to be compliant if it is tested no more than thirty (30) days prior to harvest using a post decarboxylation method and the results show that the delta-9 THC value does not exceed 0.3% on a dry weight basis: [3]

“Post decarboxylation" In the context of testing methodologies for THC concentration levels in hemp, means a value determined after the process of decarboxylation that determines the total potential delta-9 tetrahydrocannabinol content derived from the sum of the THC and THC-A content and reported on a dry weight basis. The post decarboxylation value of THC can be calculated by using a chromatograph technique using heat, gas chromatography, through which THC-A is converted from its acid form to its neutral form, THC. Thus, this test calculates the total potential THC in a given sample. The post decarboxylation value of THC can also be calculated by using a high-performance liquid chromatograph technique, which keeps the THC-

A intact, and requires a conversion calculation of that THC-A to calculate total potential THC in a given sample.” [4]

The post decarboxylation value for THC, as described above, is synonymous with the Total THC in a hemp sample. For this reason, it is clear that a pre-harvested hemp crop is not compliant unless its Total THC concentrations do not exceed 0.3% on a dry weight basis. [5]

 

Total THC Is Not Applicable to Harvested Hemp
The USDA Final Rule [6] only governs hemp production and not the regulation of hemp distribution or hemp products which are governed by the Food and Drug Administration Farm Bill. Therefore, after post-harvest, the USDA has no further jurisdiction over the hemp crop leaving the Food and Drug Administration (FDA) as the only other agency with the authority to regulate the hemp crop. The sole authority on post-harvested hemp is the Farm Bill and its definition specifically defines hemp in terms of its delta-9 THC concentration, not its Total THC content. [7]

One of the key aspects that allows for a higher concentration of THC-A is that during the thirty (30) day harvest window in which a hemp crop must be tested for THC concentrations, the plant’s cannabinoid concentrations, including THC, continue to increase. [8] For this reason, pre- harvest hemp which has been tested and determined to be compliant may have total THC concentrations that exceed 0.3% when harvested. With that being said, the hemp crop will remain compliance with FDA’s 2018 Farm Bill regulations as long as its delta-9 THC concentration does not surpass 0.3%

 

DEA Regulation of Hemp and Hemp Products
On August 21, 2020, the DEA published its Interim Final Rule (IFR) to further clarify that hemp and hemp products are not controlled substances.

In order to meet the definition of “hemp”, and thus qualify for the exemption from Schedule I, the derivative must not exceed the 0.3% delta-9 THC limit. The definition of “marihuana” continues to state that “all parts of the plant Cannabis Sativa L.” and “every compound manufacture, salt, derivative, mixture, or preparation of such plant,” are Schedule I controlled substances unless they meet the definition of “hemp” by falling below the 0.3% delta-9 THC limit on a dry weight basis. [9]

This ruling confirms that products distributed by CannaMed Organics are not controlled substances as long as their delta-9 THC concentrations do not exceed 0.3% on a dry weight basis.

Lawful Transportation of Hemp Products in Interstate Commerce
The 2018 Farm Bill legalized industrial hemp at the federal level and included a provision that makes it illegal for states to prohibit the interstate transportation of hemp and hemp products as follows:

No State or Indian Tribe shall prohibit the transportation or shipment of hemp or hemp products produced in accordance with subtitle G or the Agricultural Marketing Act of 1946 (AMA (as added by section 10113) through the State or the territory of the Indian Tribe, as applicable. [10]

This ruling makes it clear that CannaMED Organics is allowed to transport and ship hemp or hemp products as long as the products are produced in compliance with the 2018 Farm Bill by not exceeding a delta-9 THC concentration of 0.3% on a dry weight basis. Additionally, CannaMED products will not be shipped to states with regulations that have enacted a “Total THC” testing requirement imposing limitations on the requirements set out in the 2018 Farm Bill.

CannaMED Organics Federal Product Compliance
Based on the 2018 Farm Bill, USDA Final Rule, and DEA regulations, CannaMED products which contain delta-9 THC concentrations which do not exceed 0.3% and are not controlled substances under Federal law. The above rules and regulations specifically define hemp in terms of its delta-9 THC concentrations, not its Total THC content meaning CannaMED Organics products are in full compliance for retail sales and distribution.

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