The Conservative Drug Policy Reform Group, Limited Suite 15.17 Citibase, 15th Floor Millbank Tower 21-24 Millbank, Westminster London SW1P 4QP

The Rt Hon Boris Johnson MP The Prime Minister 10 Downing Street London SW1A 2AA

20 November 2020

Dear Prime Minister,

As Chairman of the Conservative Drug Policy Reform Group, I am writing today with a comprehensive set of recommendations prepared by the CDPRG research team, to secure the future of the UK’s cannabidiol (CBD) industry. Though nascent, this industry is already valued at £300 million and it is predicted to grow to around £1 billion by 2025, equivalent to the entirety of the UK’s herbal supplement market in 2016. I am sure you will agree with me that this projected market growth, and the jobs, investment and R&D it attracts, needs safeguarding and stimulating rather than inhibiting. This fulfilment depends on the practicality of the legislations safeguarding this burgeoning industry, which is why I am writing to strongly recommend that the UK votes in favour of recommendations to be proposed on 02 December 2020 by the World Health Organisation at the 53rd United Nations Session on the Commission on Narcotic Drugs (CND), of which the UK is a signatory.

The WHO recommends adding the following footnote to the 1961 Single Convention on Narcotic Drugs, to read: "Preparations containing predominantly cannabidiol and not more than 0.2 percent of delta-9- tetrahydrocannabinol [THC] are not under international control”. This harmonises with a ruling issued this week from the that member states may not prohibit the marketing of CBD lawfully produced in other member states.

We in the UK are taking pride in forging our own regulatory frameworks including in drug control. To insist on CBD products containing less than the WHO’s recommended 0.2 percent THC — the upper limit of the level at which THC content is considered negligible in terms of psychoactivity — will needlessly slay our burgeoning CBD industry at a time when its profits could contribute significantly to the recovery of our economy, swelling job creation and opportunity in the wellness and life sciences sectors. By voting in line with the WHO recommendations, and taking heed, the current barriers to growth of the sector in the UK would be dramatically reduced. This strategy would not only foster the growth of the CBD industry in the UK, it will equip us to establish further related business operations and produce onshore our own CBD-based wellness products.

Whilst regulations allow for CBD products to be exempt where no traces of THC can be found, the Home Office has to date ‘made no assessment of limits of detection in relation to testing for the presence of controlled cannabinoids in CBD products’1 meaning satisfying the exempt criteria is possible in theory but not in practice. An upper limit of 0.2 percent THC in CBD products for sale in the UK — below which there would be no need to apply for a Home Office licence relating to a controlled drug — will enable the proper assessment and regulation of all proposed products and the easy solving of legal disputes in relation to product composition. To classify products containing less than 0.2 percent THC as deserving of controlled drug status would not only be unjustifiable and unprecedented but highly likely incompatible with case law.

Carving our own path in relation to sensible regulation in the sale and distribution of CBD-containing products is something that our country is already preparing to do. The Food Standards Agency (FSA) overseeing the quality control of CBD-containing products and producers are readying themselves to apply for the necessary novel food authorisation to trade in the UK, ahead of the deadline for so doing on 31 March 2021. This is a key opportunity for policy makers to apply common sense to drug policy regulation and help an industry which not only has huge economic benefits for the country but which brings health benefits to thousands of consumers every day.

Ahead of the Commission on Narcotic Drugs on 02 December 2020, I am enclosing a briefing paper produced by the CPDPRG team on this issue for your consideration. Building on the recommendations and contextualising information in the attached briefing paper, The Conservative Drug Policy Reform Group’s recommendations on the motion concerning limits on the content of controlled cannabinoids in cannabidiol products at the 63rd United Nations Session on the Commission on Narcotic Drugs on December 2nd 2020, I would be delighted to meet with any representatives of your Government, offering evidence-based analysis of the issues at stake and providing as much detail as required in order to fully inform your decisions in relation to this important economic issue, ensuring the UK has the best possible chance of becoming a sector leader.

Yours sincerely,

Crispin Blunt

Enc (1)

CC:

The Rt Hon Rishi Sunak MP, Chancellor of the Exchequer The Rt Hon George Eustice MP, Secretary of State for Environment, Food and Rural Affairs The Rt Hon Matt Hancock MP, Secretary of State for Health and Social Care

1 https://questions-statements.parliament.uk/written-questions/detail/2020-05-18/48249

The Rt Hon Priti Patel MP, Secretary of State for the Home Department The Rt Hon MP, Secretary of State for Business, Energy and Industrial Strategy Jo Churchill MP, Minister for Prevention, Public Health and Primary Care MP, Minister for Crime and Policing Emily Miles, Chief Executive of the Food Standards Agency