ADVICE REGARDING THE FSA’s REDUCTION IN THE RECOMMENDED DAILY INTAKE OF CBD FOLLOWING A MEETING WITH THEM HELD TODAY
There is a great deal of doom and gloom today within the industry. In order to assist all market participants, we scheduled a meeting this morning with Paul Tossell, Head of Regulated Products at the FSA, to clarify matters and pass the information to each of you.
Leaving aside the short-term confusion that will be caused by the non-mandatory nature of the 10mg recommendation, it is very evident to us that the FSA is approaching matters on the premise that CBD products will be Authorised in due course. This is our summary for the future:
- The advice concerning the 10mg daily intake is just that – it is advisory and not mandatory: it does not have to be followed;
- No products will be removed from the Public List simply because they are single-consumption units at a dosage of greater than 10mg;
- Manufacturers should not immediately react and change the formulation or packaging of their products – to do so in an unstructured manner would breach the FSA’s “New to Market” Policy and lead to removal from the Public List;
- The FSA recognize the anomaly that were you to seek to follow their safety guidance and change a product’s formulation, you would be voluntarily removing yourself from the Public List via their existing policy. They intend to conduct a review of how the Public List will operate;
- There is an expectation that the Home Office will define an acceptable contaminant level for controlled cannabinoids;
- There is an expectation that CBD, and products therefrom, will be Authorized;
- The Public List Review will also need to address the future anomaly of a product being fully Authorised for use at “X” level per day being detrimentally impacted when compared to an Un-Authorised competitor who is on the Public List at twice that level;
- Following the review of the operation of the Pubic List going forwards the FSA will engage with market participants and set a realistic timescale for the implementation of any consequent changes.
Remember what we always say: Be Careful Who You Listen To.
