A More Reliable Evaluation of Hemp THC Levels is Necessary and Possible

Abstract

ABSTRACT Most industrial crops that are cultivated within the 27 member states of the European Union (EU) are supported by agricultural subsidies. An official list of the hemp varieties that receive an agricultural subsidy in the EU is maintained by the EU Commission, and EU member states are expected to sample, analyze, and report delta-9-tetrahydrocannabinol (THC) values for eligible crops of each cultivated variety by the end of each year, according to EU Regulation No. 796/2004. Based on this information, additions to and deletions from this list are made early in the following year. The main criteria for being included on the EU list of subsidized hemp varieties seems to depend on two important factors: the variety be included in the EU Common Catalogue of recognized plant cultivars, and the variety, on average, must have less than 0.2% THC, according to the sampling and testing methodologies described in Annex I of EU Regulation No. 796/2004. By comparison, values for common drug-Cannabis typically range from 5–10% THC. The purpose of this article is to point out important features in the EU sampling protocols that favor monoecious fiber varieties from western Europe and disfavor dioecious oilseed varieties from eastern and northern Europe, in addition to other peculiar features. Also, potential systematic problems that exist within the current analytical protocol for analyzing THC are identified and discussed. Direct criticism is leveled at the ignorance and incompetence demonstrated by civil servants who are responsible for correctly understanding and implementing EU Regulation No. 796/2004. Suggestions for improvements in various aspects of reporting, sampling, and analytical methodologies are presented.