HFI Press Statement 18/02/2020
Hemp Federation Ireland calls for the immediate withdrawal of FSAI report.
In response to the publication by FSAI last Thursday of the report; Survey: Regulatory Issues with Hemp-based Food and Food Supplements on the Irish Market. Hemp Federation Ireland has issued the following statement:
Hemp Federation Ireland has consistently called on Irish government departments and agencies to help us to address the precise issues highlighted in a report published on Thursday by the Food Safety Authority of Ireland.
HFI has repeatedly advised state officials that a failure to act would produce a breeding ground for poor quality products within the Irish value chain. There is much common ground between HFI’s position and the FSAI report regarding following findings:
Samples classed as food supplements had not been notified to the FSAI before being placed on the market, as required by the law. Many of those that had been notified also had issues to be addressed, such as notifying changes of labels.
Products tested contained CBD levels which differed by >50% compared to the declared level.
Misleading claims including lactose free, gluten free, non-GMO, along with unauthorised health claims and some which may be considered medicinal claims.
However HFI must take the FSAI to task for unsubstantiated and exaggerated toxicity claims regarding trace quantities of THC naturally occurring in hemp. These claims set an impossibly low bar for all hemp food products in Ireland and are entirely out of alignment with the view of the World Health Organisation.
Throughout the report FSAI applies a previously unheard of THC reference value; one microgram per Kilogram of body weight (1ug/kg) as if it was part of the family furniture - the first time anyone in the industry heard of this reference value from FSAI was when it appeared last Thursday inside the body of this report.
The THC reference value (1ug/kg) is not and never has been a feature of FSAI’s regulatory advice to industry.
In the report, FSAI uses this new value to assign meaning to scientific data which purported to measure industry compliance with advisory standards and to assess the quality of products on the Irish market relative to those standards. If high-quality products removed from the shelves last Thursday are measured against FSAI's actual regulatory advice to industry they fall well within established compliance thresholds.
FSAI issued no prior notification to stakeholders and did not advise or consult with industry bodies regarding any of the above.
The ‘corrective actions’ which the FSAI claimed their analysis warranted, are entirely unsupported by actual compliance standards set for the industry by FSAI themselves. FSAI is aware that the competitiveness of the hemp sector in Ireland is very seriously undermined by an unworkable framework of regulations which the government has so far failed to address and that our industry, our businesses, our investments and our livelihoods are constantly under threat. In this context the vigorous implementation of extreme enforcement measures against responsible industry stakeholders was reckless and damaging in the extreme.
Stakeholder consultation which aims to uphold the values of informed decision making is a core principle of the EU democratic process and was completely disregarded by FSAI throughout this entire exercise. FSAI’s own organisational values, which require them “to conduct [their] work activities employing open and clear channels of communication” and “to be fair and consistent in the enforcement of food law” were also set aside.
Prior to the publication of this report the advice of the FSAI has consistently been that industrial hemp can be grown and sold as food in Ireland so long as the trace THC content of a product did not exceed 0.2%. This FSAI advice reflects the view of the World Health Organisation and the WHO’s recommendation to the UN Committee on Narcotic Drugs (CND) that hemp food products have no narcotic value and should be removed from the 1961 and 1971 Single Treaty Conventions.
HFI supports wholeheartedly sensible, scientifically based food safety guidelines at all times, however, the misrepresentation of established compliance standards in assigning meaning to scientific data in the context of the FSAI report raises very serious questions. The report should now be withdrawn.
The hemp crop supports one of the fastest growing global industrial markets. The importance of this industry to Ireland’s rural economy and the substantial contribution hemp agriculture can make across a range of agricultural and climate policy objectives needs to be fully understood and fully considered before a unique opportunity is squandered.
This is a key time in the hemp growing season as cultivation is just about to begin; seeds must be ordered and the ground prepared. Immediate clarity for our farmers is urgently required.
Hemp Federation Ireland again calls on Irish legislators, regulators and enforcement bodies to work with Irish industry experts to establish a clear, informed and rational framework of rules and regulations governing the sector and to adopt an agricultural policy perspective to support the development of the Irish Hemp Industry.