Policy Statement on Hemp Regulation and Public Health

Society of Cannabis Clinicians (SCC)

The Society of Cannabis Clinicians (“SCC”) is committed to advancing scientific understanding, clinical practice, and responsible policy regarding cannabinoid-based medicine. In reviewing recent changes in the federal Farm Bill (FY2026 Agriculture, Rural Development, Food and Drug Administration, and Related Agency Appropriations Act), the SCC identifies several urgent issues for patient access, public safety, and regulatory coherence.

While the direction of the national conversation is encouraging, there are several issues that warrant clarification to ensure our position is scientifically grounded, internally consistent, and defensible to regulators, journalists, and policymakers.

Short-Term Priorities (Immediate Clarifications and Safeguards)

1. Protecting Public Health through Education and Transparency

The SCC underscores the urgent need for national education on the dangers of synthetic and semi-synthetic cannabinoids—compounds chemically altered or produced outside the plant—which pose well-documented risks including toxicity, contamination, and unpredictable psychoactivity. The current law does not clearly distinguish these substances from naturally occurring cannabinoids, leaving consumers vulnerable.

• Toxicity
• Contamination
• Unpredictable psychoactivity

To avoid confusion between synthetic cannabinoids and minor THC isomers—many of which are commercially produced through chemical conversion—the SCC acknowledges this nuance explicitly. We support transparent disclosure of manufacturing methods and clear scientific criteria for distinguishing natural derivatives from high-risk synthetic compounds.

• Transparent disclosure of manufacturing methods
• Clear scientific criteria for distinguishing natural derivatives from high-risk synthetic compounds

Educational initiatives must empower healthcare providers, regulators, and consumers to differentiate legitimate hemp-derived therapeutics from chemically altered products that undermine public safety and erode trust.

2. Rational, Evidence-Based THC Limits

The federally imposed 0.4 mg per-package THC limit is arbitrary, unenforceable, and not aligned with clinical or toxicological science. However, we also recognize that, at present, it is one of the few population-level retail-dose safeguards.

Clarification: Opposing the 0.4 mg limit does not mean opposing retail-dose controls.

Dry-weight thresholds work for biomass and certain product types but fail catastrophically for beverages, edibles, and concentrates, where volume or mass bears little relationship to psychoactive potential.

As an immediate, short-term measure, the SCC supports:

• Maintaining a dry-weight threshold (raised to 1%) strictly as a temporary differentiator between hemp and marijuana.
• Developing product-specific dose standards to replace the scientifically unsound per-package limit.

This clarification ensures that public health concerns and market-structure positions are aligned rather than contradictory.

3. Ensuring Access to Needed Medicines

The Act’s restrictions on minor cannabinoids and low-dose formulations jeopardize access to essential therapies used for symptom control, particularly among medically vulnerable populations. The SCC calls for immediate review and urges Congress to engage clinicians directly to ensure therapeutic innovation is not compromised.

To avoid the appearance of supporting market expansion under the guise of patient care, we emphasize that:

• Access must be coupled with clinical accountability, including post-market surveillance, adverse event reporting, and real-world evidence collection.

Medium-Term Priorities (Coherent Regulatory Structure)

4. Unified National Framework with State Implementation

The SCC supports a single unified regulatory framework for all cannabis sectors—Legacy, Licensed, and Hemp—to reduce confusion, protect public health, and promote fairness. At the same time, we affirm the importance of state authority in hemp regulation.

To reconcile these positions, we explicitly articulate a federal-floor model:

• Federal government establishes baseline safety, testing, labeling, and age-verification requirements.
• States implement and build upon these standards based on local conditions, agricultural priorities, and public health needs.

This resolves perceived contradiction between unity and state control.

5. Fairness for Small Farmers and Small Businesses

While our policy framework emphasizes fairness for small farmers, we acknowledge that many of the benefits of current proposals accrue disproportionately to downstream processors. To strengthen this section, we clarify:

• The unified framework should include farm-gate protections, cooperative processing infrastructure, and equitable licensing that allow small cultivators to participate meaningfully in the value chain.
• Any THC standard (including the proposed 1% limit) should not inadvertently tilt the market toward large-scale industrial processors.

6. Consistency Between Safety Claims and Dose Controls

Public health claims must align with dose-control policy. We therefore recommend the development of product-specific intoxicating-dose thresholds for beverages, edibles, and concentrates to avoid the impression that we criticize the 0.4 mg limit without offering an alternative.

This includes:

• Volumetric limits for beverages
• Per-serving and per-unit dosing standards
• Clear differentiation between intoxicating and non-intoxicating product categories

Long-Term Priorities (Structural Reform and Federal Modernization)

7. Descheduling with Realistic Expectations

The SCC supports removing cannabis (“marijuana”) from the Controlled Substances Act. However, we clarify that:

• Descheduling does not mean deregulation.
• Descheduling will likely increase, not decrease, federal oversight by shifting cannabis into regulatory frameworks similar to alcohol, tobacco, pharmaceuticals, or dietary supplements.
• This transition will involve substantial new bureaucracy, some of it staffed by existing federal drug-control agencies.

We note that this is not inherently negative, but precision is essential: we must be clear about the type of regulation we want, not merely the removal of prohibition.

8. Transitional Use of the Hemp/Marijuana Distinction

While supporting descheduling, we continue to rely on the hemp/marijuana split for practical regulatory purposes. To avoid philosophical inconsistency, we explicitly frame this as:

• A transitional regulatory strategy
• Used only until a unified cannabis framework is nationally adopted and fully operational

Conclusion

The Society of Cannabis Clinicians advocates for hemp and cannabis policy grounded in scientific evidence, transparency, and public health protection. Federal law must clearly differentiate harmful synthetic substances from naturally derived therapeutics while respecting state authority and preserving access to legitimate cannabinoid medicines.

A short-term focus on education, safety standards, and temporary dry-weight rules; a medium-term commitment to unified national standards with state implementation; and a long-term vision for descheduling with robust regulatory oversight together create a coherent framework for public safety, clinical integrity, market fairness, and therapeutic access.