Regulating Cannabinoids One At A Time: Scientific Approach or Delay Tactic?

Here is the good news when it comes to issue of regulating cannabinoids. Last month, the European Commission added Cannabigerol (CBG) to the Cosing List—namely the regional database of allowable ingredients in cosmetics. This after adding natural CBD as an approved substance the month before.

The process of regulating cannabinoids in Europe is well underway. From one perspective, this makes sense. Each cannabinoid is a unique chemical compound. So are other components of the plant—such as terpenes. However, so far, there has never been a regulatory investigation of the entire plant, compound by compound by any national or regional authority. The EU approach to regulation is, in other words, highly unique in the history of the plant itself.

How does this procedure of regulating cannabinoids at the European level integrate with approval of cannabis for both medical and non-medical use? And for what purpose?

The Process of Regulating Cannabinoids For All Uses

Part of the difference now being seen in Europe with regards to regulatory approaches is that first and foremost, certainly after acceptance of its medical efficacy, cannabis as a plant genus is dealt with as a naturally occurring mixture of many different chemical compounds. This is easy to see in the 2019 European Parliament resolution on the same. Namely the EP called on the European Commission (EC) to regulate the drug by its chemical components, given its recognized medical efficacy.

So far, the EC has decided on the status of three cannabinoids. THC is a narcotic (no matter how you slice it). CBD is now not a narcotic and further may be used in its natural form in cosmetics. And CBG may be used in cosmetics.

Since there are 60 cannabinoids (so far identified in the plant) and over 400 chemical compounds, including natural oils (also known as terpenes) the approach taken by EU authorities may take some time.

It is also, however, a wake-up call to all of those now searching for alternatives to introduce into the market (Delta 8 instead of 9 for example) to overcome the regulatory hurdles cannabis and cannabis-containing products still must go through (even if they contain no THC).

The implications, beyond the medical and even cosmetic conversation, stretch far into the future. Namely, at this rate (one cannabinoid approved per year), the European Commission is currently on a 60-year plan to approve just the cannabinoids in the entire plant—let alone the other substances.

There are plenty of rebellions afoot already about the consideration of CBD as a “novel” substance—especially as hemp as a plant has been in human use long before the formation of the EU. Look for the same avenues for every single cannabinoid if this approach holds at the highest levels of the European regulatory decision-making process.

How will all of this play out? Is this even sustainable (as a good use of public money, for example)? Especially when recreational reform begins to take hold in several countries beyond Holland as of next year?

Scientific Evidence or Ongoing Canna Stigma?

There are no known toxic compounds in the cannabis plant. Indeed, one of the reasons cannabis has been accepted medically as an alternative for opioids is that it is literally impossible to overdose on smoked or otherwise ingested cannabinoids.

Further, it is also clear that cannabinoids work together in the plant and in the body—starting with the ameliorating impact CBD has on the ingestion of THC, namely it appears to work to reduce the “high” that particularly recreational users experience.

That said, there are clearly substances in the plant that have been shown to cause serious allergic reactions. Terpenes on skin is one obvious example. So is the growing evidence of the existence of cannabis allergies—which can cause serious if not fatal effects (although it is still unknown what exactly causes the same).

Separating the elements of the plant into various compounds certainly makes sense from this perspective – not to mention the fact that the industry is already coming up with products that use certain compounds alone (see pure THC or CBD extract as just two examples of the same), or even combine the same in new ways.

But again, does regulating cannabinoids separately make sense, especially when bound for a non-medical user? And further to delay full acceptance of the whole plant for all purposes in the meantime?

A Coordinated Strategy On Cannabis At A Regional Level

There are several ongoing initiatives right now at the EU level that might change this conversation and rather drastically starting with attempts (see the European Cannabis Association) to lobby for a different approach to cannabis and at a regional level. 

Cannabis must be regulated first as a whole plant, no matter the different compounds in it. The vast majority of users (both medical and recreational) experience cannabis this way. The sector of the world that does not is in fact, major pharma, and corporate food.

While there is nobody in the industry who would seriously object to more money and government attention being given to the entire topic of cannabis normalization that includes research and testing, there is a growing cynicism that over-regulation—namely what is going on right now—is a delaying tactic, bought and paid for by those who want to slow the progress of reform and the industry down…or have no interest whatsoever in the natural plant, but rather its extracted components.

Regulating Cannabinoids: Are There Any Alternative Strategies?

It is easy to throw stones and get frustrated about all of this. After all, every member of the industry over 40 well remembers full boat Prohibition. 

However, at this juncture, it is important to realize that regulators themselves, even those in charge of regulating cannabinoids, are generally uneducated about these compounds and how the human body uses them. Namely that the human body itself produces endocannabinoids naturally. There is no way the EC (or European Parliament for that matter) can regulate this. 

Further, particularly given the disastrous “scientific” experiments so far (see Rimonabant – which is an agonist, meaning that it blocks the cannabinoid receptors in the body and was approved in the EU in 2006 before being withdrawn), there is a great deal of evidence to suggest that the endocannabinoid system of the human body works as a better regulator of said compounds either individually or in sum than any human-created pharma company or regulatory authority. See the ameliorating effects of CBD on THC as just one example of the same.

There are plenty of other examples of medical plants which are regulated as a single biological entity even though their component parts are used separately. For example, Salvia miltiorrhiza (or Bunge), a staple of Chinese medicine, is widely used this way to treat a variety of conditions, including cardiovascular diseases. 

The reality is that herbal medicine of all kinds, as a subset of medicine, which was almost completely left out of the formal pharmaceutical model developed by the world—certainly, the western part of it—during the last century, is ill-suited to the kinds of regulatory approaches and tactics that are now common in the world of pharma.

The regulation of cannabis, generally, is a challenge to the way such processes have worked for the better part of the last century.

The process of reintegration is going to take some time, if not a revision of procedures to do so along the way. But perhaps not at the schedule currently on offer at the European Commission.