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Letters
EU proposes changes in flax and hemp subsidy
In November of 1999, the European Commission announced proposed changes of its subsidy regime for flax and hemp. The new system to discourage increasing abuse of the subsidy (largely by flax farmers), while promoting high-quality long fiber production, is scheduled to come into effect by July 2000. Hemp aid will also be cut to a level comparable to that of linseed growers. The EU subsidizes hemp production provided plants have a level of THC less than 0.3% dry weight. EU officials have proposed that this threshold be lowered to 0.2% dry weight.
The report is summarized immedately below (courtesy of Richard Rose, Hemp Food Association):
Proposal for a Council Regulation amending Regulation (EC) No 1251/1999 establishing a support system for producers of certain arable crops to include flax and hemp grown for fibre. Proposal for a Council Regulation on the common organization of the market in flax and hemp grown for fibre (presented by the Commission) [...]
2.4.4. Seed and shives
In some cases, it is the shives that contribute the greatest value added to the fibre flax or hemp crop, in particular when the fibres produced are short. Bedding made from hemp shives is a quality product that is prized by horse-breeders, although it is still sold predominantly on local markets. Chipboard panels could be major application, provided prices remain very low. [...]
Hemp seed has one traditional but limited application as food for fish and birds. The oil from hemp seed can be used for specialist cosmetics applications. The use of hemp seed or the leafed parts of the plant for human consumption would, however, even in the absence of THC, contribute towards making the narcotic use of cannabis acceptable and, in any event, there is no nutritional justification for this.
None of these products should be encouraged in their own right by Community aid.
2.5. Considerations specific to hemp
[...] Moreover, the International Narcotics Control Board (INCB, a United Nations body) states that: "while illicit cannabis cultivations (sic) have soared, a considerable market for food products and beverages produced with cannabis has developed in the European Union (...). The health effects of these products have not been adequately researched. (...) the wide and unrestricted availability of such products in shops, where cannabis candy bars can be sold to minors without restriction, contribute to the overall benign image of cannabis, a drug under international control." [OICS note of 12.3.1999]
It is therefore important to remain vigilant and step up controls to ensure that illegal crops do not tarnish the reputation of the sector producing hemp for fibre. To avert such dangers, the cultivation of hemp for fibre must be strictly controlled, which means the area cultivated will have to be restricted, and the uses to which it is put must not include human nutrition.
(11) In order to prevent illicit crops from disturbing the common organization of the market in hemp for fibre, provision should be made for checks on imports of hemp and hemp seed to ensure that such products have a low tetrahydrocannabinol content. In addition, hemp seeds intended for uses other than sowing may be imported only if they have been denatured and can no longer germinate.
Following are letters from IHA members concerning the content of these proposed changes amending "Regulation (EC) No 1251/1999 - Reform of the EU flax and hemp regime", their possible impact on the hemp industry and the political climate from which these proposals originate.
On November 10, the Commission of the European Communities issued its final proposal for fiber subsidies, including hemp. In it, the regulations state that "Hemp seed has one traditional, but limited application as food for fish and birds." Such a statement ignores the hundreds of years of use as a food by traditional cultures, practices which continue today in such diverse regions as eastern Europe, China, and Japan.
But the Commission's real agenda soon becomes clear. It states "The use of hemp seed or the leafed parts of the plant for human consumption would, however, even in the absence of THC, contribute towards making the narcotic use of cannabis acceptable and, in any event, there is no nutritional justification for this." Attempting to use nutrition as a justification is ridiculous enough, until you realize that hempseed is one of the most nutritious plant foods on earth!
The report ends the chapter with the bottom-line: "None of these products should be encouraged in their own right by Community aid."
In the next chapter, (2.5. Considerations specific to hemp), we finally see that the old tired prohibitionist war-horse, children, gets hauled out. Using them as the pawns to make hemp foods illegal, the report states "(...) the wide and unrestricted availability of such products in shops, where cannabis candy bars can be sold to minors without restriction, contribute to the overall benign image of cannabis, a drug under international control." [OICS note of 12.3.1999] Evidently the Commission conveniently forgot the Single Convention Treaty on Narcotics, which expressly exempts industrial hempseed from drug laws, instead combining both low- and high-THC varieties under one term, "cannabis".
As if invoking the sacred name of children wasn't sufficiently cynical, the report further takes great pains to protect that sterling image of fiber hemp: "It is therefore important to remain vigilant and step up controls to ensure that illegal crops do not tarnish the reputation of the sector producing hemp for fibre. To avert such dangers, the cultivation of hemp for fibre must be strictly controlled, which means the area cultivated will have to be restricted, and the uses to which it is put must not include human nutrition."
It appears that the Commission didn't do their homework, perhaps seeing "Goo Balls" or "Space Cake" in the Netherlands and confusing it with the many dozens of THC-free hempseed foods available across the planet. Some of them have even been sold for over 5 years, and all of which exceed the nutrition of their hemp-less competitors.
Friends of the noble and mighty hempseed need to let their voices be heard, and hope that this proposal doesn't become regulation.
Richard Rose <richard@hempfood.com>
A proposal was made to the EU member states during mid-November to alter ruling CE n. 1251/99. This ruling offers financial support to cultivators of certain products and includes the growth of flax and hemp destined for fibre production.
We obtained a copy of this document on November 26 and immediately realized that the situation was rapidly worsening for our country and the reborn Italian hemp cultivation sector.
The most important points in this document can be summarized as follows:
1) Only producers using hemp seeds certified as varieties containing no more than 0.3% of the psychotropic substance tetrahydrocannabinol (THC) are eligible for EU contributions. As from 2001/2002 this limit will be reduced to 0.2%. To enforce this regulation it is envisaged that 30% of the area given over to hemp cultivation in each province will be sampled, instead of the current 5%.
2) The maximum surface area, different for each country, for which a contribution is guaranteed, is based on the mean surface area invested in over the last 5 years.
No further points need to be added because these alone are enough to end the slight hope of restarting fibre hemp cultivation in Italy.
The first point is certainly the most questionable one. Indeed, as many scientists have stated in many authoritative publications, a level of THC in fibre hemp equal to 0.3% causes no appreciable hallucinogenic effect in those who smoke it, that is unless an individual has the patience to smoke 50 or more cigarettes. A level of 0.2% of THC would force the "drug" user to smoke 70 cigarettes in order to consume the same dose. We do not believe that this ruling is aimed at increasing the consumption of cigarette papers also made from fibre hemp. It is immediately obvious to anyone with the slightest knowledge of the hemp seed market in Europe who will benefit from this ruling.
French varieties of hemp seed are well represented in the EU list, whereas the other varieties (virtually all dioecious) are either not yet commercially available or come from countries where proper consideration of THC content was only accorded recently. In Italy for example, only the French varieties and a Hungarian variety have been available over the last two years and at a high price. In particular, in order to possess French seeds in sufficient quantity (improved from the point of view of THC content), it was necessary to agree to supply a contract lasting for several years. In light of the new rulings, if this agreement had been accepted, the majority of the seeds would have remained unused.
In our country, for almost four years we have had to deal with certain vested interests who forced us to choose "multicolored" imported hemp varieties when it would have been better to concentrate on lowering the level of THC in our own varieties. This development has indeed taken place, but several years are required to transfer an improved variety to the market. At the same time seed companies must show a clear and active interest to achieve this goal.
Assuming use of the same fibre hemp seed, the climatic conditions in each member country must also be taken into consideration. For instance, environmental variations mean that a southern dioecious variety cultivated in Finland does not even produce seeds and therefore cannot receive EU contributions. This is another absurd condition that must be addressed. Yet the same variety cultivated in Italy or Spain stays in the field for more than 120 days, produces and synthesizes as much as possible, in the presence of very strong light and extreme temperature and watering conditions, with definite effects on the productive level of THC. Some would suggest that avoiding cultivation of dioecious varieties is enough, and perhaps this suggestion would be accepted by the European Commission, given that all the French varieties are monoecious.
As far as checking 30% of the surface area given over to fibre hemp production is concerned, fortunately (if that is the word), there is nothing to object to because the Commission has assisted us on this second point. Maximum surface areas have also been stipulated for each country above which subsidies will not be available.
Maximum production in Italy could reach 50 tons of long fibres (convertible to 250 tons of short fibres), which must be added to the 100 tons of short fibres currently allowed. An overall total of 350 tons which, considering the mean level of Italian production, can be achieved using approximately 30-40 hectares. Sampling to determine THC levels would therefore concern approximately 10 hectares. Given the updated European THC assessment system, this would mean analysis of 2 or 3 samples at most.
In the majority of cases, decisions made on the basis of mean values are objective and balanced. In this case however, to consider the mean surface area given over to fibre hemp cultivation in each country over the last 5 years is undoubtedly a joke for us. In Italy, the laws dealing with controlled substances have, for once, been applied to the letter, as far as hemp is concerned, and since the 1970s it has been illegal to cultivate this plant in that it contains a psychotropic substance (THC). If we examine the surface area cultivated during the thirty year period in which growing hemp meant sustained work (1920-1950), an average of 86,000 hectares was cultivated which produced a mean of 3,000 tons of hemp seeds per year.
Another factor must be taken into consideration. The main aim for Italy is to cultivate hemp to produce good quality fibres destined for the many Italian companies who already operate in the manufacturing sector and are forced to use imported primary materials (almost all from China). In our opinion, this objective has more intrinsic value than many other of the uses found for hemp in Central and Northern Europe. To give some examples, let us not forget horse litter, paper production, insulating panels, recyclable vehicle components and many others. These are all certainly valid and practical uses, but with much lower values added to production than those obtained with fibre hemp production for fabrics. Furthermore, to imagine setting up a processing center (even a pilot one) on the basis of production from 30-40 hectares is completely ridiculous.
In conclusion, we have a slight hope that whoever represents our country at the European Commission, well aware of what has just been said, is able to put forward a clear and decisive argument. The Commission must be made to understand that decisions of this nature must also take into consideration the general interests of the EU. Such important decisions can eventually be implemented without applying long-term regulations which are often very wrong.
Gianpaulo Grassi, Paolo Ranalli <isci@bo.nettuno.it>
It has recently come to our attention that the EU proposes to change details of the hemp permit rules. We understand that a subsidy is a temporary measure to help start a new industry. The European hemp industry is privileged to have received this subsidy thus far. It cannot yet be said that we have a fully functional infrastructure as yet and feel that the proposed reduction of subsidies would be damaging to the future of this European industry. With Canadian, Asian and soon Australian interest in this market, we need further assistance at the current level for at least the next two to three growing seasons. A reduction of such subsidies is very likely to be damaging to the small businesses that currently rely on the subsidies to make hemp a viable crop to process and use as a base for manufacturing facilities. We represent a number of such facilities and cannot justify such an early turnaround in subsidy regulations.
It has also come to our attention that permitted THC levels are expected to be reduced from 0.3% to 0.2%. We would like to state our objections to such a change that would reduce the options available to primary processors whose businesses are directed by the demands of manufacturers who now expect high quality hemp. Such hemp is often found to be at the 0.3% level, which, it must be stated has no detrimental effects to anyone concerned. 0.3% cannot produce any euphoric effect whatsoever and therefore does not create any direct problem for the authorities. We understand that cultivars have been developed that contain 0% THC and we can see the benefits of such crops for policing. However, we represent the processors, manufacturers and end users of hemp. During the past 6-7 years each level of industry has come to know the qualities of hemp that its market demands. We are finding different cultivars for different uses. One strain is perfect for high GLA content seed production, one strain more suited to short fibres and one strain more suited to long fibres. It is unlikely such a choice will be available in 0% THC cultivars within the next 10 years.
For this reason we object to ANY reduction in THC levels in industrial hemp crops until such cultivars are ready for specific markets. These markets are at a crucial stage. The first 3-7 years of any business is the most crucial and such underlying changes to the business, that can be made at the flick of the pen, have the potential to wipe out a variety of small businesses throughout the European Union.
We would appreciate being consulted in any future propositions for changes to an industry to which we have offered all of our time and assistance for many years. With the European Union's support, we have high hopes of making the hemp industry a great employer and supplier of health and environmental products to mainstream industry in the 21st century.
Paul Benhaim <Paul@Benhaim.co.uk>
I am writing in response to the information circulated prior to action to be taken on the above EU regulation. There are four main problem areas with this proposal:
(1) It suggests that use of hemp seed in human nutrition promotes use of the drug "cannabis".
(2) It suggests that there is no nutritional justification for hemp seed to be used for human nutrition.
(3) It suggests that all hemp seeds coming into the EU should be denatured or sterilized.
(4) It suggests that any farmer growing hemp fibre and collecting a subsidy should not be able to sell any hemp grain into the human nutrition market.
I am not sure how the writers of this proposal justify (1), when at the same time suggesting that use of hemp fibre does not promote use of "cannabis". Of course hemp fibre and hemp seed have the disadvantage of being derived from a plant type (Cannabis sativa) that is also grown illegally to produce a drug. This already works against our sales momentum, we are expending much time and money trying to educate the public that hemp is not a drug. We have recently taken on a full-time marketing manager to work primarily on defusing the myth that hemp is a drug. This is, in fact, one of the main reasons that we use a rope in our logo. When talking to the public about hemp, many of them do immediately think of rope due to hemp's use in the rope industry in the UK's early naval days. We feel that our PR movement is going steadily and we are extremely impressed with the sales of hemp oil that have started to accumulate. It would be safe to say that 75% of our hemp oil sales are to elderly ladies and certainly none of it attracts the "druggies" of society who are hardly the ones likely to be buying products for the benefit of their health. Furthermore, we employ a number of doctors and professors as scientific advisors to the company. This allows us to be credible with our information and to accurately convey the benefits of hemp food to the public. We also have the active support of a number of other medical professionals whose contact details I have provided.
To our knowledge, most leading chemist chains in the UK now stock hemp oil capsules. These all come from Canada, which has recently re-introduced the cultivation of hemp in their country. The majority of Canadian farmers grow hemp for the seed - this going either into nutrition or cosmetics. We are successfully selling hemp oil to these chemists both in bottle form and in capsule form. We feel confident that we will be able to take much of the Canadian's market and furthermore to help this industry grow with the UK emerging as a leading force.
We have invested over £150,000 into research and development of hemp foods and oils. All of this has been based around hemp seed's incredible provision of essential fatty acids. These are the fats that the human body requires for existence. Without these fats, we would die. We currently manufacture and supply bottled hemp oil, hemp oil capsules, hemp seeds, snack bars (with hemp seed) and are soon to add the following items to our collection: hemp muesli, organic sprouted bread with hemp, and hemp milk (a serious competitor for soy milk). I enclose a leaflet of some of our food products.
Currently, we import the majority of our hemp seed directly from France, where it has been grown continuously throughout this century. (It is worth noting that the French have not suffered an increase of "cannabis" consumption due to the existence of hemp products (seed and fibre). However we have just entered into a 10 year exclusive joint-venture contract with the Finola company of Finland for European distribution rights to its 'FIN-314' seed variety, under a joint-venture named 'FIN-UK'. FIN-UK will now grow and sell FIN-314 across Europe (excluding the Nordic countries). We believe that this variety of hemp seed provides the most perfect balance of essential fatty acids for the human diet. It was developed by Dr. Jace Callaway, a researcher in the Department of Pharmaceutical Chemistry at the University of Kuopio, who is a leader in the field of hemp seed fatty acids. Under the auspices of the International Hemp Association, Jace started a breeding program as a partnership with Tero Lakkonnen, a farmer in Finland. 'FIN-314' (already recognized as a registered variety in Canada) originated from two Russian cultivars, and is recognized as unique. It grows only 3 to 4 ft tall, as opposed to standard hemp strains which grow from 8 to 14 ft tall. This shorter stature makes it far easier to harvest with conventional machinery. This is also an extremely early maturing variety, which means that it has more of a chance to produce mature seeds in countries of northern latitudes (i.e., the UK) which have short summers. In addition, 'FIN-314' does not branch. Instead, it just builds seed-bearing flowers all the way up the stem. This means that it is a good yielder with an average of over 500 kg per acre expected in England. Although primarily a seed variety, it also produces modest quantities of a very high quality fibre which is believed to be of great value for specialty markets. (Hemcore grew a test plot this year under license with Jace Callaway.) 'FIN-314' seeds also have more gamma-linolenic acid (GLA) than normal hemp seeds (4.1% as opposed to 1.7%), the nutriceutical valued in evening primrose oil.
MotherHemp obtained a research license last year for a 15 acre plot of 'FIN-314, which performed well. We are keen to plant approximately 40 acres next year which will produce roughly 20 tons of seed. This will be produced under organic certification as organic hemp seed fetches excellent margins. This seed will mean that we no longer need to import from France and before long we will be able to compete very favorably in the EU hemp seed and oil market. Furthermore when this seed is developed further and can be sold in the EU as planting seed, it is expected to fetch about £2 per kilo, this will lead to an incredible standing for the UK in the hemp market as the hemp seed market is currently pretty much controlled by the French.
The whole issue of denaturing hemp seeds would be devastating for our business as:
1) The costs that we would incur denaturing any seed that we had make it even harder for us to compete in our competition against soy beans and evening primrose oil.
2) The method of denaturing hemp seeds (as in the US) is invariably steam-sterilization. This method will damage the nutritional benefit of the seed, making all hempseed-derived products much less valuable to the consumer. In fact, heat treatment of seeds turns essential fatty acids into trans-fatty acids that are then toxic for the body. Essentially it starts the process of turning a nutritious food into a toxic varnish.
One of the main benefits of the hemp plant to the farming industry is the fact that it can be used for so many different applications. The more that the farmer can harvest of one plant the more revenue streams he is capable of deriving. If a farmer can make a good margin harvesting for fibre then he will make an even better margin if he can also harvest the seeds on the crop for sale into the highest value market he can find. Clearly human nutrition is a high value market in comparison to animal feeds and cosmetics.
I believe that MotherHemp Ltd is in a strong position to emerge as a market leader across the world in hemp foods and oils. I also believe that we will be able to help the re-emergence of hemp cultivation in the UK, which will benefit UK farmers enormously. It is both strange and shocking that these amendments are being rushed through without a proper analysis of the evidence and consideration of the potential repercussions to stultify the exponential growth of the hemp seed industry. I cannot over-stress how damaging this proposal could be, both to my company and to the farming community of the UK, if passed without proper investigation, and await your response on this matter.
Will Stephens <will@motherhemp.com>
On November 10, 1999, the EU Commission of the European Communities issued its final Proposal for the fiber subsidies (COM-1999 576, 99/0236 CNS, 99/0237 CNS, Proposal for a Council Regulation amending Regulation EC No. 1251/1999). This proposal not only includes regulations for hemp (Cannabis sativa L.) fiber, but also hemp seed, a useful and nutritional grain which does not enjoy a subsidy within the EU agricultural structure.
Although textiles are no longer produced from hemp fibers in Europe, at least not to an economically significant degree, hemp fibers are still needed for the production of specialty papers (particularly in France) such as cigarette papers and bank notes.
While EU regulations have historically denied a subsidy for hemp grain, it is curious that qualifications for this subsidy are partly based on the production of mature seeds before harvest. This peculiar requirement is to the detriment of optimal fiber quality, as the male hemp plants have already begun to die and dry at this point in the normal growth cycle of hemp. In effect, half of the crop has already begun to decrease in value after the production of mature seed by the female hemp plants. This curious regulation puts EU farmers in norther countries, such as Sweden and Finland, at a distinct disadvantage, as the production of mature hemp seed for the approved EU varieties is inhibited by the long hours of day light at high latitude. At lower latitudes, as in France, it is actually impossible to grow a decent crop of hemp fiber without the production of seed. Yet, while the EU regulations deny a subsidy for hemp seed, this pivotal requirement, which is based on hemp seed production, leaves a significant part of the EU farming community out of the hemp fiber subsidy scheme. I know this from first hand experience, as I was the first in Finland to apply for a hemp fiber subsidy after planting EU-approved French seeds in 1995. Subsequently, I was the first in Finland to be denied this subsidy. Since that time, I have planted six other EU approved varieties in Finland, and none of these ever produced mature seeds at my latitude (>60 degrees North). These results have since been supported by government-sponsored agricultural trials of these and other hemp varieties in Finland. Such hemp fiber varieties from Central Europe do grow well in Finland, but as an asexual crop typically reaching three to four meters tall, which results in a substantially increased production of fiber and biomass per hectare at high latitude. Moreover, such a crop is not contaminated by dead and drying male plants, and the quality is homogeneous. This geographic advantage of high latitude should actually be exploited to our advantage, rather than inhibited by irrational regulations.
In order to comply with the curious requirement to produce mature hemp seed before the harvest of fiber, and in order to receive the EU hemp fiber subsidy, I developed an early-blooming variety of hemp, registered in the EU Common Catalogue under the generic name 'FIN-314' and with the common name of 'Finola'. 'FIN-314' produces abundant seed at high latitudes. Unfortunately, however, this variety is not on the EU list of approved cultivars, although it has a fiber quality that is finer than other industrial varieties of fiber hemp, and produces almost entirely primary (long) bast fibers. In fact, the fiber quality of FIN-314 is more akin to flax, and the production of fiber per hectare is even greater than flax. Moreover, FIN-314 is a hardy industrial crop that does not require either herbicides or pesticides; a distinct advantage over flax in both production cost and environmental impact.
It is apparent that the EU Commission's recent proposal is concerned with the THC levels in hemp. This natural component of hemp is mistakenly referred to as a 'narcotic' in this proposal. In fact, THC is actually not a 'narcotic' in the scientific and pharmacologic sense of the word, and I would like to assume that the decision makers within this Commission are basing their decisions on sound scientific judgement. Although much effort has been focused over the past 30 years on attempting to demonstrate the alleged toxicity of even high doses of THC, I am not aware of any scientific studies that support this allegation. To the contrary, in this prolonged effort of searching for alleged cannabinoid toxicity, we have only discovered new medical applications for THC and other cannabinoids. However, if the EU Commission is truly concerned about the putative toxicity of the miniscule levels of THC in hemp, then, again, the Commission would be interested to learn that 'FIN-314' has THC levels that are at least five times lower than the current limit of 0.3% THC.
This report not only takes advantage of the common ignorance on alleged cannabinoid toxicity, but also completely ignores the nutritional potential of hemp seed as a food for human consumption. Not only has hemp seed been used to feed animals in Europe, as acknowledged in the proposal, but this seed has been used to feed humans since the dawn of history in many other parts of the world. It has not gained popularity in the Western diet because of its hard outer shell. From a nutritional point of view, hemp seed is one of the most nutritional industrial grains known to man. Its oil is 75-80% omega-3 and omega-6 fatty acids, which have been known as essential to human health for at least 60 years. In addition, hemp seed protein is comprised of two globular proteins that are easily digested; albumin (a protein found in human blood and egg whites, for example) and edestin. Both of these proteins are complete, meaning that they contain all of the essential amino acids in nutritionally significant amounts. In fact, the amino acid profile of hemp protein is superior to soy protein, as hemp proteins are non-allergenic and lack the trypsin inhibiting factors that are present in soy. Moreover, and again of economic concern to Nordic climes, soy crops cannot be produced at high latitudes because long day lengths. Thus, hemp seed currently represents the only high quality vegetable protein that can be grown at extreme northern latitudes. Personally speaking, I have spent most of my life in the medical sciences, and I am not aware of another single food source from the plant world that has so much to offer, from a nutritional point of view, than the hemp seed.
There are several ridiculous claims and assumptions throughout this report. I must assume that the people who have voted to approve this resolution are intelligent individuals, that unfortunately must rely and trust on others to inform them of the validity of such claims. If this is the case, I am sorry to inform these honorable members that they have been misinformed by people who do not know the truth. Or worse, they have actually been lied to by people who do know the truth!
I would very much like to have to opportunity to debate those individuals who insist on suggesting that hemp can converted to drug substances and, particularly, I would like to debate those individuals who insist that hemp seed holds no nutritional value. It is apparent to me, that certain institutions and individuals are desperately trying to hold on to their precious monopolies by manipulating EU regulations to their own favor. I particularly question the agenda and objectivity of Mr. Gazagnes in the Department of the Commission, and I openly wonder about his personal ties and loyalties to the producers of French hemp seed and fiber; i.e., the Fédération Nationale des Producteurs de Chanvre.
J. C. Callaway <callaway@uku.fi>
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