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05.03.19 Feed, Newsletter

AAFCO updates guidelines on hemp in animal food

By David Fairfield, Senior Vice President of Feed Services

The Association of American Feed Control Officials (AAFCO) on May 2 released updated guidelines on the use of hemp and hemp products in animal feed and pet food.

Key points from the updated AAFCO guidelines include:

  • “Hemp” as defined by the 2018 farm law — Cannabis sativa L., and any part of the plant, including seeds, extracts, cannabinoids (CBD), isomers, acids, salts, and salts of isomers, with a delta-9 tetrahydrocannabinol (THC) of no more than 0.3% on a dry-weight basis —  was removed from the Federal Controlled Substances Act, but the U.S. Food and Drug Administration (FDA) has authority to regulate hemp or hemp-derived products that are intended for use in food for humans or animals.
  • As of April 2019, no hemp or hemp products have been approved or defined through available regulatory processes for use in animal feed or pet food. Therefore, hemp and hemp products may not be lawfully used in animal feed or pet food at this time within the United States.
  • Given that interest in industrial hemp products and production is rapidly increasing in the United States, AAFCO continues to ask the hemp industry to present information for scientific review to establish definitions for animal food ingredients made from the industrial hemp plant. Prior to regulatory approval of hemp or hemp-based products for animal food, safety concerns associated with the presence of certain compounds in parts of the hemp plant, including THC and CBD, must be addressed through scientific studies. 
  • Through collaborative discussions between the hemp industry and FDA, it has been determined that CBD-infused products typically are to be considered drugs because the intended use of such products are largely associated with drug claims. As such, animal foods that contain CBD as an ingredient may be deemed adulterated and/or misbranded by regulatory agencies, and subject to enforcement actions.

FDA is holding a public hearing to obtain additional scientific data and information related to cannabis and cannabis-derived compounds to inform its regulatory oversight of these products. The hearing will be held on May 31 from 8 a.m. to 6 p.m. at the FDA White Oak Campus in Silver Spring, Md. To attend the public hearing, either in person or by webcast, on “Scientific Data and Information about Products Containing Cannabis or Cannabis-Derived Compounds” register here.

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Lacy Holleman
Manager of Legal Affairs and Arbitration

lholleman@ngfa.org

Lacy provides staff support for one of NGFA’s premier member services – its more than century old system of industry trade rules and arbitration that facilitates the efficient marketing of grains, oilseeds and their derived products. She also works on contracting, legal and other related matters.

An Arkansas native, Lacy received her undergraduate degree with a double major in history and Russian studies from the University of Tulsa (Okla.) and her law degree from Wake Forest University in Winston-Salem, N.C. Prior to joining NGFA’s staff in November 2020, she managed a local business at the Pentagon and completed mediation training required by the North Carolina Supreme Court for those seeking to serve as mediators for settlement conferences and other settlement procedures in North Carolina Superior Court civil actions. She also has worked as an assistant for a law firm in her native state.