22. October 2018 Daniel Kruse

EIHA needs your help. Our industry needs your help.
We would welcome more proofs of use of hemp leaves, flowers and hemp extracts in/as food/supplements to considerable degree in Europe prior May 15, 1997.
Please note that we already know that use of hemp flowers/extracts in beer brewing does not qualify enough for “food use to considerable degree” as these are only considered as flavors and CBD is not found in beer-like beverages in large amounts.
Our industry has to demonstrate presence of CBD in foods on at least percentual level.
There is a formalized procedure in EU to evaluate “consumption to significant degree”.
See attached novel-food_guidance_human-consumption_en. This document can be found here: https://ec.europa.eu/food/safety/novel_food/catalogue_en
As you can see “consumption to significant degree” is evaluated from several aspects and below I highlight few important statements:
– 1.2 Documentation
“These could include for example, invoices, recipes, cookbooks, catalogues etc.”
– 1.3 Geographical aspects
“An established history of food use to a significant degree in at least one EU Member State is sufficient to exclude the food from the scope of Regulation (EC) No 258/97.”
– 1.4 Quantity of use
“In certain cases, Member States have to determine for a food that was used in apparently small quantities, whether such a food requires authorisation under the Novel Food Regulation.”
1.5 Intended purpose
“Regulation (EC) No 258/97 exclusively covers foods and food ingredients.”
“Products that have been used for their medicinal effects/as a drug or as cosmetics (for example, traditional restorative remedies, plant based medicinal products, traditional Chinese medicine, toothpaste) do not indicate that this product was used as food.”
Any input will be evaluated.
Thank you very much in advance for your support!
All the best
Dominik
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European Industrial Hemp Association (EIHA)
c/o nova-Institute
Phone    +49 (0)2233-48-1449
Email    [email protected]
Internet    www.eiha.org