INSIGHTS ON THE CANNABIS INDUSTRY FROM REGULATORY BARRISTER MATTHEW (MATT) LAWSON
Matthew (Matt) Lawson, a UK Regulatory Barrister has penned a series of discussion pieces under the rubric “Insights on the Cannabis Industry”.
In Part 1 of Insight into the Industry: Cannabis Industry Regulation, barrister Matthew (Matt) Lawson looked at the Canadian Regulatory Framework. In Part 2 we looked at the US regulatory position relating to adult-use and medicinal cannabis. In Part 3 we looked at the US Regulatory Framework in respect of CBD. In Part 4, we looked at the European Medicinal regulatory structure. In this final Part, barrister Matthew (Matt) Lawson looks at the European CBD regulatory structure.
CBD has been classified as a novel food, and not a narcotic, however, currently no company has received Novel Food Authorisation. The EU continue to resume applications for novel food authorization and CBD for the use of food and supplements must be evaluated for consumer safety and risk and need EU authorisation to be placed in the market. Currently, the Directorate-General for Health has been reviewing applications to further process them on to the European Food Safety Authority. For non-ingestibles, the EU has recently approved naturally derived CBD as an ingredient for cosmetic products.
As there are currently very few regulations regarding the manufacturing and extraction of CBD, many companies have taken it upon themselves to set quality and safety standards by achieving ISO and HACCP certifications as seen in the food and beverage sector. The most common ISO certificates used in the CBD industry are ISO 9001, 14001 and 22000.
ISO 9001 primarily focuses on the quality management system ensuring that operations are followed to standards that benefit the company as well as the end consumer.
ISO 14001 is the international standard for the maintenance and formulation of environmental management systems.
ISO 22000 has been common in the industry as the standard specifies the requirements for a food safety management system that demonstrates a company’s ability to control food safety hazards.
Hazard Analysis and Critical Control Points (HACCP) is a production safety management system for the food and beverage sector. As CBD extracts are being produced for human consumption many CBD companies are looking to become HACCP certified. It addresses food safety through the analysis and control of biological, chemical and physical hazards during the handling, manufacturing and distribution process. Extractors and CBD manufacturers looking to become HACCP certified have to undergo a qualified third-party certification audit which validates the following relating to the HACCP; identifies hazards, establishes critical control points and limits, measures and controls hazards, monitors controls, has a corrective action plan and establishes record keeping procedures.
Matthew (Matt) Lawson is a UK Barrister who has advised Governments and Corporations for over 25 years in respect of human impactors – Food & Ingestibles, Medicines, Medical Devices and inhalation mediums. He provides worldwide Cannabis advice to clients who stem from Governments, to some of the largest multinational CPG corporations, to pharmaceutical giants, through to niche pre-IPO Start-Ups in the CPG and medical fields.