Today February 8th 2022 Maryland State Senator Brian Feldman has filed emergency legislative action to stop all production and sale of hemp-derived ▲8 THC outside of the Maryland Medical Cannabis Commission. We appreciate Senator Feldman and Delegate Pena-Melnyk's interest in this issue but we have significant concerns with this legislation. This bill could require all consumers of these products to retain a medical marijuana card and recommendation to be able to purchase these products regardless of personal circumstances that prevent the procurement of the MMCC card. Additionally this bill could only allow these products to be sold at Maryland Medical Cannabis Dispensaries and could in effect place all current retailers out of business as well as totally remove the public's access to these products as medical marijuana dispensaries have no interest in the sale of hemp-derived products. However with that said, we agree with lawmakers on one thing. We need common sense regulation. We want to be able to both ensure public safety while protecting this industry's ability to provide safe access to these products that help people improve their quality of life. Let us as hemp industry professionals, help you draft this regulatory framework. We have already been doing these things. The model is already here. Just lend a legislative ear to us. We have the knowledge base that is needed to achieve these goals.

This bill was put forward using language from the Senator's newsletter that states that these products are being sold to minors without any testing requirements or restrictions. Responsible and ethical companies like us at Embrace CBD as well as other companies including our partners at Georgetown Hemp who have been an integral part of the research and economic development that has given way to a thriving Maryland hemp industry have held ourselves to the highest possible standards as it relates to testing and quality control. We use DEA registered 3rd party laboratories to do full panel lab tests on all of our raw ingredients and finished products. We go beyond the MMCC requirements by using food grade toxicology labs to do additional foreign materials analysis and reagent testing which is in addition to the mycotoxins, heavy metals, pesticides, and residual solvents analysis. We agree that we need to keep these products out of the hands of minors, but stores like ours and our partner's and many others in our coalition have an age requirement of 21 to enter and make purchases. These products being sold in gas stations and convenience stores are contributing to these products landing into the hands of minors. There is a better way to go about this that would not cause our industry so much loss and inflict so much unnecessary damage on its participants. Simple. Stop letting irresponsible people sell it in places that minors have access to and allow businesses who are responsible to continue to operate by selling these federally legal and fully compliant, thoroughly tested products. Again, we want regulation, we just want it the right way. 

Unlike the Maryland Medical Cannabis Industry the Maryland Hemp industry is not confined to the state of Maryland and this legislation could upend our industry in ways that can have a negative effect on the national economy.

Those of us in the hemp industry that have been operating responsibly have many thousands of customers who rely on these products for their well-being. Many of these people do not have the funds or the capability to acquire a medical marijuana card and could immediately lose their access to the products that have helped them improve the quality of their daily lives. We are a resource to underserved communities. These are wonderful people and they come from all walks of life and many of them have already voiced their opposition to this bill. 

Hemp industry professionals take testing very seriously and go far beyond the MMCC. The 4 MMCC approved labs do not have the capacity to be able to do the type of testing that the hemp industry does and as a result this bill will not achieve its stated purpose. We have set the testing standards, we have the model for the best possible regulation of these products. Just let us into the conversation.

The Maryland marijuana dispensary owners have been lobbying against the hemp industry's ability to participate in the free market since the passage of the 2018 agriculture improvement act. Their lobbying efforts have everything to do with their small loss of profits and nothing to do with consumer safety. No hemp industry professionals were consulted in this matter. Passing this legislation would put responsible companies like ours out of business and cost the jobs of all of our staff members, not to mention the countless other companies and employees that would be affected by the passage of this legislation. The Maryland tax contribution by hemp businesses dwarfs that of the medical marijuana dispensaries and even that loss of revenue pales in comparison to the pain and suffering that this would cause to those of us who have been doing the right things in compliance with all state and federal laws. Make no mistake, this bill will end the Maryland Hemp Industry as we know it. 

We the undersigned urge you to please take into consideration the opinion of our coalition of business owners and customers and hear both sides of this argument so that you can be assured that you are well-informed before pushing this bill through committee for a vote. Let us help you draft proper regulatory framework for our industry as we have information that could be of great value to you and to the public at large.

We have put everything we have into building a company that places safety and transparency at the forefront of all we do and you will destroy many lives through the passage of this bill.

Thank you for your consideration.