Policy analysis · graduate paper
The Grey Market of Delta-8 THC
Why the definition of hemp needed clarifying in the Federal Farm Bill — a policy paper on the loophole that built an unregulated intoxicant market.
policypublic healthlegislative analysisExecutive Summary
"The legalization of hemp in the 2018 Federal Farm Bill unintentionally allowed for the creation of a questionably legal 'grey market' of Delta-8, Delta-10, and other artificially created hemp-derived THC products. Clarifying the language surrounding hemp in the upcoming Federal Farm Bill to exclude these hemp-derived products from legal industrial hemp will eliminate this loophole market and keep consumers safe from this unregulated product that is causing people, including children, to fall ill."
The full paper covers the history of hemp regulation in the United States, how hemp-derived THC products are actually made and sold, the case against the current grey market, and specific statutory language to close the loophole.
The subject later became a professional focus — see the published white papers on upstream youth prevention from the same policy territory.
Full document available on request.