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As an organization promoting product research and development from a consumer/patient-centered perspective , the Medical Cannabis Society hopes that the upcoming legal cannabis experiment will be a stimulus to broad scientific research into the effects of cannabis products, possibly casting more light on the medical and therapeutical potential of the cannabis plant and its compounds.
The Dutch Trial, limited to 10 Municipalities and to a period of 4 to 6,5 years, represents the best chance for The Netherlands to set quality standards to produce cannabis flowers, hash, and edibles for the recreational market.
We have since the very beginning been actively involved in the process that culminated with 149 applications being sent to the Ministry of Health this July. These applications are now being reviewed by a ministerial committee and the final appointment of a maximum of ten growers is expected to take place as soon as January 2021.
For a selected group of professionals and entrepreneurs participating in the selection procedure the Medical Cannabis Society will be organizing a series of events, tackling every time a specific topic pertaining to the implementation of a legal Cannabis Supply Chain.
It will be a technical presentation of a production method, an experts-session over governance and regulatory issues, or any other topic that may be deemed relevant by our workgroup and might contribute to streamline the process and add professional value to it.
Edibles: the “last-minute” product
The First event, scheduled on the 2nd of December 2020, will be about edibles, a quite marginal product category within the Dutch coffeeshop assortment nowadays but with interesting perspectives in a legal cannabis market.
According to a recent Prohibition Partners’ report (Disruptive food) the global demand for cannabis/hemp and CBD-infused edibles has the potential to grow to US$ 6.56 billion by 2024.
Since October 2019 Canada has added edibles to its second wave of legalization. The additional Regulations, issued by Health Canada, contain a comprehensive set of controls for producing and selling edible cannabis, including good production practices, limits on THC content, restrictions on harmful ingredients, and strict packaging and labelling requirements.
Within this regulatory framework a wide variety of edible products can be now produced and distributed in Canada, ranging from cannabis infused candies (like chocolate bars and gummies) to cannabis infused food and drinks.
Will this also be the case within the Dutch cannabis experiment? The short answer is: ” we still don’t know”.
A lot of questions remain unanswered by the experimental regulatory framework and a lot will depend on how the consumers’ demand will develop.
As a matter of fact, the legislators have recognized the importance for the future licensed producers to develop an assortment that meets the consumers’ demand. For this reason, most applicants have done an attempt to include a detailed production plan for edibles in their applications.
Looking back at the legislative process leading to the final draft of the Experiment Law (Wet Experiment Gesloten Coffeeshopketen), edibles make a last minute appearance in the Ministerial Guidelines, allegedly in response to wishes expressed by the Coffeeshops’ Unions for a supply reflecting the full range of products currently available, including cannabis cakes.
Back in 2018, the advisory committee presided by prof. André Knottnerus had advised the government to ban edibles from the experiment.
The reasoning behind this advice was:
- Edibles would lower the threshold for new consumers to get access to cannabis
- Edibles could mistakenly be consumed by children
- The risk of overdosing through ingestion would be too high
Unfortunately by overriding this advice and allowing edibles, the legislators have not addressed the concerns on how to deal with the risk of overdosing, which could have easily been dealt with either by setting a limit on THC content in edibles or by allowing the use of cannabis concentrates exclusively for the production of edibles.
Edibles are defined as end-products and the end-products that are permitted within the Experiment may not contain substances included on list I of the Dutch Opium Act (namely, the hard drugs), cannabis oil, extracts and concentrates being on that list.
According to the experimental law, edibles can be made using “hemp or hash” (hemp being the legal term both for THC cannabis and industrial hemp). The quantity of hemp or hash used for edibles cannot exceed the limit of 5 gr per packing unit and needs to comply with the quality standards for lab testing and labelling and be fully traceable. Edbles need also to comply with the rules set by the Netherlands Food and Consumer Safety Authority (NVWA).
Either than this, the Law does not prescribe a specific method to produce edibles. Chemical concentration processes that might arise during the preparation of edibles have not been addressed and fall outside the scope the Ministerial guidelines.
For example, what about the process of mixing mechanically extracted high grade hash powder (which is allowed) with oil or butter, while cooking? A high quality hash powder can contain a higher concentration of THC than a THC-oil extracted following the Romano-Hazekamp method for galenic preparations.
Adding good manufacturing practices (GMP protocols) to the production process could even result in edibles of almost “pharmaceutical grade”.
Does that mean that we will have edibles that can compete with medicinal cannabis oil, that is so difficult to get legally in The Netherlands?
the “High Cuisine” dinner
Our first event will be a special dinner for a maximum of 15 participants, with a direct stake in the wietproef (the Dutch cannabis experiment). The dinner will take place in a corona-proof environment where we will have the honor to introduce two internationally acclaimed cannabis professionals: the two chefs that have generated excitement all over the world with their High Cuisine concept, Anthony Joseph and Noah Tucker, authors of the cook book of the same name and main actors in the television series dedicated to their work. We will see them in action preparing a four course dinner for our guests and we will have the opportunity to interact with them about the possibilities the Cannabis Experiment offers for the production of edibles and maybe also for cannabis-based food.
The concept Anthony and Noah have developed is based on micro-dosing, participants to their dinners leave feeling a slight euphoria, but still in control, like as if you has a glass of wine per course.