INCB Cannabis Control Initiative | UN CND side event

Jun 7, 2021 20:07 · 6072 words · 29 minute read

Excellencies, distinguished delegates, colleagues, ladies and gentlemen. Thank you very much for joining us today for our side event: “Way forward in the control and monitoring requirements of cannabis and cannabis-related substances: the INCB guidelines on the international drug control requirements for the cultivation manufacture and utilization of cannabis for medical and scientific purposes. “ My name is Juliana Erthal-Williamson, I am a drug control officer at the INCB secretariat i’m also the coordinator of the INCB Cannabis Control Initiative and I will be your moderator today.

Thank you for your patience with our technical issues as you know uh we’re all in this same situation of uh our first virtual CND so thank you, please keep your microphones muted during the presentations you may ask questions in the chat but, in order to keep things a bit more organized, we are not allowing participants to take the floor; you’re welcome to write it on the chat. Because of the time we don’t guarantee that we will answer all. I also have here the questions that were sent by participants that pre-registered, and we will give preference to those.

And whatever we don’t answer right now we can follow up with responses to you later. So, without further due, being mindful of the time i will give the floor to our first speaker Mr. Cornelis De Joncheere, President of the INCB. Mister president, you have the floor. Thank you very much, Excellencies, distinguished delegates, ladies and gentlemen, I’m pleased to welcome you on behalf of the International Narcotics Control Board (INCB) to this side-event.

Last December, I had the opportunity to address the 63rd reconvened session of the CND prior to the vote of the WHO ECDD recommendations on cannabis. CND voted to delete cannabis from the schedule 4 of the 1961 convention, but otherwise, no changes were made, and cannabis in cannabis-related substances continued to be subject to the existing control measures. And consequently, INCB will continue to work with member states to ensure treaty compliance pursuant to the decisions taken.

02:44 - One year before the CND, in November 2019, the board held its first informal consultation with major cannabis producing and manufacturing countries to discuss the issue of the application of the control and monitoring requirements for cannabis and cannabis-related substances. The Board called for this meeting as an increasing number of countries was getting involved in the licit cultivation of cannabis. From our discussions with those countries, it had become clear that the requirements on the authorization on the control and on the reporting and information requirements were not always well understood and implemented.

Hence the need to bring countries together and discuss these issues, and to try to come to a common understanding.

03:35 - The participants at the consultation agreed that it was important to have a shared understanding of the control requirements, a consistent approach with regard to imports and exports, and a realistic and uniform reporting at the various stages of the cultivation and manufacturing processes so we could have an effective monitoring.

03:59 - In March 2020 the board launched its International Cannabis Control Initiative, or ICCI, and we’re very grateful for the financial support of the government of Japan that makes this possible. The initiative aims at providing guidance and assistance to member states in the area of control, monitoring, and reporting on cannabis and cannabis-related substances.

04:27 - Following the December 2020 vote by the CND on the WHO recommendations and in response to requests from member states for more guidance on the control and reporting on cannabis the Board has accelerated this process of developing the guidelines to assist competent national authorities in this area. The INCB organized an expert group meeting in January of this year, and an informal consultation in February with major cannabis producing countries.

05:01 - Furthermore, in March 2021, one month ago, an intergovernmental meeting with member states on the guidelines took place. This meeting was the first in a series of consultation with member states that are planned for this year by the Board these meetings are the platform for member states to provide inputs and share practices and comment on the draft guidelines. Representatives of the African Union the European Union, the Organization of American States, WHO and UNODC are also contributing to the process, and consultations with civil society will be done through questionnaires and online meetings.

05:50 - The aim is to provide the international community with a final draft by December of this year, for the member states, and to be considered possibly in the context of a resolution at the 65th session of the Commission (on Narcotic Drugs) in 2022. The draft guidelines aim at strengthening the capacity of competent national authorities and decision makers to (1) implement the requirements of the conventions as they relate to cannabis, cannabis-related substances and derived products, for medical and scientific purposes; (2) to comply with the regulatory control and monitoring requirements of the licit trade in narcotic drugs and psychotropic substances in national settings and to be able to participate in international trade in line with those requirements if countries wish to do so and (3) to meet the reporting obligations in an accurate and timely manner.

06:53 - Shared understanding of control and reporting requirements among member states is required to avoid gaps in the monitoring process, to avoid discrepancies in reporting, and to ensure compliance with the international drug control framework; and the draft guidelines will provide guidance towards that shared understanding.

07:17 - In the discussions over the last months, we’ve made a lot of progress, but it’s also clear that there are still issues to be ironed out for instance with regard to the status of cannabidiol (CBD), on what is “industrial use”, on the scientific questions around cannabis, and also on the legal interpretation of the relevant articles of the Convention. The Board is committed to work with member states and resolve these issues one by one, so we all have a shared understanding on what is to be reported and how.

This side event provides another opportunity for interacting with member states, with delegates, with interested parties, and to get your input into this process, and we look forward to a fruitful discussion this morning and to a continuation of this important initiative thank you very much for your attention and for your active participation.

08:19 - Thank you Mr president. I now welcome Mr Hideo Eno, director of counter-narcotics of the Ministry of Health, Labor and Welfare of Japan. Mr Eno, you have the floor.

08:33 - Thank you Ms. Erthal. Good morning, good afternoon, good evening. Distinguished delegates and members of the panel. This year we mark the 60th anniversary of the 1961 Single Convention on narcotic drugs, and also the 50th anniversary of the 1971 Convention. Over time, new findings backed by scientific evidence supporting the medical use of cannabis and cannabis-related substances has emerged, resulting in numerous discussions and an intense review as well as changes in its perceived level of risk.

These significant changes have led to increasing complexities in reporting due to the differences in views on the legal aspects and on the interpretation of the Conventions, especially since more countries have engaged in the production of cannabis.

09:41 - Given these circumstances, national competent authorities seek a common understanding on reporting and control requirements. I would like to express my heartfelt appreciation on behalf of the government of Japan to the INCB, for addressing this complex endeavor through an exchange of ideas, experiences, and best practices with various stakeholders, and by offering its guidance through the INCB cannabis control initiative being presented here today.

10:23 - We know that the circumstances surrounding cannabis and cannabis -related substances have changed significantly over the past 60 years due to enhancement in technology and progress in research and development at the same time, increased disparities in the interpretation and implementation of the Conventions is a serious concern. We believe that the INCB initiative, by advancing guidelines on the international drug control requirements for the cultivation manufacture and utilization of cannabis for the medical and scientific scientific purposes, will provide member states with solutions to improve compliance of the treaties and help governments with their control and reporting obligations on cannabis and cannabis-related substances –that will lead to further harmonization.

11:27 - It is also quite feasible to imagine that these guidelines will also lead to the prevention of illicit cannabis -elated activities such as cultivation, manufacture, smuggling, trafficking, diversion, and abuse, as well as promote its proper use in line with the international drug control Conventions.

11:53 - Japan is proud to support this lofty initiative and looks forward to the final product which, we hope, includes a collection of best practices offered by the expert group meeting that took place earlier this year. You have Japan’s full support. Thank you very much.

12:18 - Thank you very much Mr. Eno, and I would like to repeat the message from the president, that we’re very much thankful to the government of Japan, not only for the financial contribution, but also for the trust and the confidence in the INCB and the secretariat in this journey.

12:37 - So our next speaker is Mr Hendrik Greve, head of legal trade in narcotics and psychotropic substances II, Federal institute for drugs and medical devices of Germany.

12:52 - Welcome hendrick, you have the floor. Thank you Juliana and hello to everyone i repeat the first uh sentences first of all i would like to thank the INCB for inviting us to contribute actively to this important side-event and to share our view on monitoring the medical use of cannabis and cannabis-related substances.

14:14 - We begin with a brief time travel regarding the medical use of cannabis and cannabis-related substances in Germany. The timeline displays the respective milestones: in 1998, the psychoactive principle of cannabis dronabinol became prescribable in Germany, and in 2005, the medical cannabis and extract preparations became available for patients as last-line therapy, based on exceptional individual licenses, as a result of the court decision. In 2011, the cannabis-based medicine Sativex® received marketing authorization as finished medicinal product, and in 2017, the national narcotic drugs act has been amended so that medical cannabis and extract preparations became prescribable and, moreover, reimbursable by health insurance, and became part of a monitoring survey.

In the same year 2017, the national cannabis agency was established, and the first tender was published regarding the cultivation of medical-grade cannabis. Up to now, 2021, the medical demand for medical-grade cannabis is still covered by imports, but first harvests are expected for this year. Let’s have a look to the international control of cannabis and cannabis related substances as you may know cannabis and its psychoactive principle delta-9-THC belong together, but unfortunately they are controlled internationally by two different régimes: namely the Single Convention on narcotic drugs of 1961, and the Convention on psychotropic substances of 1971, respectively.

On the one hand, the Single Convention of 1961 covers cannabis, its extracts and tinctures, the resin, and its preparations; but on the other hand, the Convention on psychotropic substances of 1971 include delta-9-THC including dronabinol and six more isomers of THC.

16:25 - Therefore, the international control covers more and more products which turned out to be increasingly used for medical and scientific purposes for instance: dried flowers, extracts as intermediates, extract preparations as prescription medicines, and, moreover, as finished medicinal product with marketing authorization. Apart from that, we have dronabinol from synthetic or semi-synthetic or even from natural sources as API (active pharmaceutical ingredient).

16:57 - And we have other THC isomers such as delta-8-THC which become more and more interesting for the international community. This situation poses challenges for the competent national authority.

17:15 - The challenges belong to, among others, fulfilling our estimating assessing and reporting obligations in regard to: total quantities concerning cultivation and production, international trade, manufacture, consumption for medical and scientific purposes, and stocks. The most crucial question in this regard is how to display and account for cannabis and cannabis-related substances in their respective inport and export authorizations, and the INCB forms? We can refer a cannabis-based product either to “cannabis” and the 1961 Convention via conversion factor, or refer to the delta-9-THC content under the 1971 Convention.

18:04 - At present, one can find quite inconsistent practices among member states, leading in losing compliance of the current guidance. To solve this issue we have to keep our overall goals and this context in mind at all times: this is to avoid discrepancies between importing and exporting countries, to avoid to channel-in illicit products into the legal supply chain, and to provide reliable consistent and transparent data to the ANCB. All these efforts are essential to ensure availability of governmental-monitored cannabis and cannabis-related substances for medical and scientific purposes, while preventing their diversion and abuse.

Coming to the results. Please allow me to create some confusion at this point, in order to emphasize the complexity of this topic. As you can see, the displayed word cloud encompasses four different levels differentiated by sizes and colors. The main level is represented by the biggest size and dark green color, displaying the international drug control conventions, the competent national authorities, and the new guidelines by INCB, followed by the white, the light green, and finally the smallest shapes.

19:17 - Our expectations on the new INCB guidelines relate to harmonization of practices, seamless transition in control and reporting cannabis versus delta-9-THC, and to reflect on the essentials.

19:32 - In this context, any double reporting of cannabis versus delta-9-THC needs to be excluded, and details such as the use of conversion factors, along with the distinguishing between dronabinol of natural versus synthetic origin, have to be clarified. Moreover, the impact on the INCB forms and on the respective import and export authorizations is of interest in this context it needs to be clarified which IDS (International Drug System code) has to be used, for which kind of cannabis based product.

The whole system is dependent on the international drug control Conventions whose schedules are continuously under revision of the WHO and the CND, and whose regulations are continuously expanded by ECOSOC and CND resolutions.

20:27 - Apart from that, compliance and active contribution by the competent national authorities is essential for the success of this process. Diverse aspects may have impact on the performance of the competent national authorities, such as capacity and networking, regional differences and national legislation, and, last but not least, new products which newly come on the market.

20:54 - We highly appreciate and welcome the development of new guidance by the INCB in order to achieve satisfying solutions for all stakeholders for this complex and important topic. Thank you very much for your attention.

21:14 - Thank you very much indeed Hendrik, and also, thank you to Germany for the very active contribution in this process, and also thank you for presenting and making it more understandable, not only for us but also for the participants, the complexity of the cannabis industry in Germany. And this is why you’re able to come to us with a lot of issues that need to be solved and discussed among member states and the Board, in the process of producing better guidelines.

We appreciate that. I welcome now Miss Stacy Harper-Avilla, our next speaker, chief of the “UN reporting and quota section, diversion control division, Drug Enforcement Administration (DEA) of the United States. Stacey, you have the floor.

22:05 - Good morning, good evening, good afternoon to the panelists and guests. The United States thanks the INCB and Japan for co-hosting this event and allowing the US to serve as a panelist.

22:22 - The United States welcomes the INCB’s efforts to accelerate international harmonization of the necessary terminology for monitoring and reporting, and to facilitate the worldwide exchange and coordination of scientific and medical information on cannabis and cannabinoids.

22:44 - As member states allow or increase medical and scientific research utilizing cannabis, the import and export of cannabis and cannabinoids will naturally grow more prevalent and more complex. For example, the global research community will need to share sample materials across international lines, to replicate, verify, and build upon research results. As this research leads to the development of new medicines, cannabinoids will be increasingly available on the legitimate market, and complex international supply chains may develop that could involve cultivation in one country, refinement and production in another, and consumption in yet another.

In these cases, it is critical that the importing and exporting countries involved share a common understanding of terms for data collection and reporting purposes. The three drug control conventions envision the creation of domestic regulatory systems that allow for the industrial medical and scientific use of drugs such as cannabis, while effectively preventing their diversion.

23:57 - However, the conventions left many of the details of these regulatory systems up to the discretion of the member states. In 2018, spurred by growing public interest in the industrial uses of the cannabis plant, the US enacted the Agricultural Improvement act to promote the cultivation and use of the cannabis plant for industrial and agricultural purposes.

24:24 - This legislation provided a clear delineation between cannabis for industrial or agricultural purposes, and cannabis that was at risk for diversion and illicit use, by setting a limit of 0. 3 percent delta-9-THC or less in the plant and final products produced from the plant material.

24:48 - Cannabis with 0. 3 percent delta-9-THC or less was classified in this legislation as “hemp” to provide a clear distinction to both the industry and the interested public. As a result of this legislation, hemp and hemp derivatives containing 0. 3 delta-9-THC or less are not controlled under the US Controlled Substances act. In addition to clearly defining what qualifies as cultivation for industrial purposes, this delineation between hemp and cannabis allows for increased scientific and medical research of hemp derivatives in particular the substance cannabidiol or CBD.

In the US, CBD extracted from hemp and containing less than 0. 3 percent delta-9-THC is classified as a hemp derivative, and therefore not a controlled substance. The control status of CBD derived from hemp is based on domestic scientific research and is aligned with the recent WHO recommendation that preparations considered to be pure CBD should not be under international control.

26:02 - In addition to its industrial uses, cannabis and cannabis derive substances such as CBD have been under scientific review to develop treatment medications.

26:16 - This research is promising, and we believe that member states should take action to increase access to cannabis for research purposes in line with their treaty obligations.

26:28 - For example, in 2018, Epidiolex® was approved by the US Food and Drug Administration, for the treatment of two specific forms of severe childhood seizures. Epidiolex®, developed in the UK, is a drug product containing CBD which was originally produced from cannabis, and contains extremely low levels of delta-9-THC. As the country that participated in global clinical trials during the development of this drug prior to its 2018 domestic approval, the US held discussions over several years with both the UK and the INCB, to identify how the controlled substances contained in the drug product should be considered for import-export permits, and annual reporting purposes, and how the import of dosage forms to support clinical trials should be reported.

27:29 - This drug product raises the question of whether the controlled substance in question, which was a cannabis extract (cannabidiol or delta-9-THC due to its residual trace amounts) should be reported. Further, would reporting it as both cannabis extract and delta-9-THC inflate the actual quantities imported and/or utilized for scientific and medical purposes? For the US, domestically, this drug product is considered to be pure CBD rather than a cannabis extract.

The US believes it is important for international trade, global research efforts, and data collection and reporting purposes, to clarify when a drug product derived from cannabis ceases to be considered cannabis extract and becomes classified only as CBD or THC. The US believes that this is one of the most important issues which the cannabis guidelines can clarify, not only for this approved drug product, but for other products still in the research and development phases in various countries.

The US looks forward to continued work with our international colleagues to further refine the terms, and frame the reporting parameters within the guidelines, to facilitate international trade for industrial, medical and scientific purposes, and INCB reporting of the relevant data. Thank you for your time this morning.

29:10 - Thank you very much Stacy, especially for raising the issues –very relevant issues– of international chains of production and supply and distribution, legislative issues, thresholds for THC, and you’ve touched upon a very important issue: when is exactly the point when a product ceases to be an extract of cannabis and can be considered for issues of control and reporting as CBD and THC; and we look forward to further discussing that with member states and the Board and the experts.

And, speaking of experts, before I give the floor to Justice; thank you again for the United States for all the support to this initiative, as well and the encouragements.

29:57 - I will now give the floor to our expert, Mr. Justice Tettey, chief of the laboratory and scientific section of UNODC, who we are so thankful to, as he’s been supporting us, being present and active in all our consultations meetings, experts meetings, intergovernmental meetings.

30:20 - So, thank you so much Justice, welcome here today, and you have the floor.

30:25 - Thank you Julianna let me first say it’s been a pleasure collaborating with the INCB on this initiative. And UNODC would like to thank you for allowing us to contribute to the discussions on the development of these guidelines.

30:40 - I would like to focus on the analytical challenges we face as we move forward.

30:46 - Cannabis products are the most widely trafficked drugs worldwide with practically every country affected. Yet, very few countries are prepared for the analytical challenges it brings, both from a regulatory and a law enforcement angle. Hendrik, who spoke before me, mentioned the range of products we find on the market. And this ranges from products such as CBD, with trace-amounts of THC, through herbal cannabis, to the more potent cannabis resin.

From the analytical point of view, how low should our methods go or how low should it go. Hendrik also mentioned an important point: the prominence of the cannabinoid delta-8-THC on cannabis markets.

31:36 - Let’s not forget this is a minor component in herbal cannabis, which we normally don’t worry about. But it can be easily made from cannabidiol. Now the question for the analysts: can we separate these various components of cannabis, and be able to report on them? Quite often we assume that analytical data between laboratories are comparable. This will be ideal for a wide range of purposes, including: monitoring cultivation, providing estimates to regulatory authorities, and even understanding the cannabis markets in general.

32:18 - But in real life, legislation in a number of countries does not require detailed analysis of the THC content of different products. The forensic question under a lot of legislations is often whether cannabis is present or not, never how much is present.

32:38 - Where such analysis are carried out, they could involve the use of a variety of approaches and experimental designs, and this can reduce the comparability of results and also impact on useful procedures, like providing estimates to INCB.

33:00 - On the technological side, the analysis of cannabis products is further complicated by the relatively restricted availability of pure, or well-defined reference materials of THC and other cannabinoids.

33:16 - The experience from the UNODC’s international collaborative exercises, has shown that disparities in THC content by different laboratories for the same sample of cannabis could be significant.

33:37 - It brings up questions: how can labs provide comparable analytical data to support the INCB system of estimates. How can we reliably differentiate between the different components, including the isomers, delta-8, and delta-9? With the formula becoming so relevant.

33:58 - How can analytical science support the choice of even the cultivars we use in the cultivation of cannabis for industrial purposes and for the production of CBD, whilst reducing the risk of diversion of the THC-containing parts in these plants? There are challenges, and with all these challenges ahead of us, we really welcome the efforts of INCB to get these guidelines in place. From UNODC, we’ve been supporting over 300 laboratories in 85 countries worldwide to be able to analyze cannabis and related substances accurately, and be able to produce comparable data.

34:41 - As we go along, UNODC is ready to make available to INCB resources, such as our manuals on the analysis of cannabis and cannabis products [link in description]. Our reference standards collection will also support countries to be able to analyze products accurately, and to be able to differentiate between the different components of cannabis. And finally, our proficiency test for national laboratories will be made available to anyone who wants to join this program to make sure that they’re able to generate data which would once again be comparable between countries.

35:32 - We look forward to supporting the elaboration of these guidelines, and also to ensure that analytical science is at the core of regulatory and law enforcement efforts. I thank you.

35:49 - Thank you very much indeed Justice, and also for raising these issues that we we are confident that you will continue to work on, to answer all of these questions that you’ve raised together with member states, and we’re happy also to contribute as much as we can.

36:08 - With that we’ve come to the end of our list of speakers, and I will read a few of the questions. Some of them were pulled together, and i will count on the chief of the narcotics control and estimates section Stefano Berterame, who will give us a few clarifications regarding the questions that were sent if we have enough time we will also go to questions in the chat. Stefano, one of the first issues that were raised by participants who pre-registered was the terminology so could you please tell us why in the title of the guidelines we use the term utilization instead of use or use of and where it is defined and thank you julian and thanks to the speakers it was very interesting to hear from the experts from the company national authority as well as from the unodc as you can see the matter is very complex and we are in a in an effort to try to work with member states to get some clarification regarding the question why it was in the document the draft guidelines the term we use was utilization and not use or use of we are trying to refer as much as possible to the terminology that is used in the conventions and in the conventions the utilization is referring to the use of a drug to manufacture another drug so if you’re taking cannabis to extract cannabinoids then dead would be utilization from the point of view of the convention uh also we you when we describe the instead the convention describe the therapeutic use of medical scientific use they talk about consumption and consumption is considered when a drug is distributed to the retails being it pharmacies or hospitals and then it’s considered to be consumed at that point so these are the two um terms that we prefer to use making reference to what is in the convention thanks thank you stefano also about the source that are being used to produce the guidelines what is the process or processes that incb has developed to consult and consider scientific literature and other relevant pieces of evidence thank you so first of all i think we need to clarify that the effort of the incb is in support of the decision of the member states regarding scheduling and as you know the determination for the scheduling is based on scientific analysis by the expert committee on drug dependence so for the ncb the process of the review of scientific literature or relevant piece of evidence is only related to the development or clarification of the control mechanism so we are not doing a reassessment of the uh uh you know this the medical use of cannabis because that is being done already by who has been already considered by member states however in this process we had been able to carry out a review of literature and also we had engaged a consultant who conducted an extensive review of literature engaged with experts in the field of the manufacturing utilization of cannabis and cannabis related substances as was mentioned also by the president in his opening we had an expert group meeting that took place in january uh 2021 and we continue to work with the member states through an intergovernmental consultations but also from a scientific community and ngos and as you was mentioned also by the president there is foreseen the possibility to consult with civil society to see what is their point of view on on this particular aspect i hope this answered the question that was submitted thank you stefano also to reinforce that we welcome submissions of papers some of you have already submitted papers documents uh any any kind of supporting material that you you may find relevant we’re welcome to receive them and take them into consideration we like to think of these consultations that the president mentioned as a platform that the incb has launched for uh broad consultations in in the context of the production of these guidelines so thank you in advance for your contributions and thank you for the ones who have already sent us material stefano the next question is about um control of cannabidiol cbd is cbd extracted from cannabis plant controlled internationally under the 1961 drug convention and if so how should member states report on the quantity of cbd thank you juliana and i think this is something that was already um discussed by some of the presenters and i think in particular the representative of the united states stacey arpera pointed out that there is the need to clarify uh when an extract ends and when it becomes pure cbd from the legal point of view so that kind of border need to be considered because as it’s been one of the major issue of concern is that cannabidiol is not explicitly scheduled as a substance in the convention however it is extracted from the cannabis plant and therefore could be considered controlled under the 61 convention as an expert of cannabis as you all know the there was a discussion in the commission narcotic drugs based on the recommendation of who and what some of the recommendations of which would have tried to address this problem but unfortunately they were not uh accepted or adopted by the by member states anyway from the point of view of the board we think the member states are mandated to report on the production utilization and trade stock and consumption of extracts of cannabis containing cbd however when considering cbd as a pure substance it would be possible to understand it as a non-scheduled substance as cbd is not listed in any schedule this is something that we think needs to be discussed further with member states and the incb is in is making every effort to facilitate the discussion in the intergovernmental meetings on the the guidelines and we hope that in the context of the debate it would be possible to identify a common ground on uh reporting um the the issue i think that remains is the that some of the preparations cbd continues to con contain traces of thc and therefore it is important for um country to be aware of what is the use of this cbd and one of the concerns that we have if you have a very big production of cbd extracts then it would be possible through a manufacturing process to extract and separate the cbd from the thc and there may be you know the possibility to have a big amount of thc being produced that needs to be reported nevertheless so this is one of the concerns that we have and also i think uh justice tete from unodc mentioned earlier the possibility of converting from cbd to delta a thc which is also an issue that needs to be addressed so this is something that we think together with member states and experts we will try to see what is possible to um to conclude as a common understanding on reporting and control thank you stefano i have another question here that also brings together some of the questions from the chat about hemp so maybe you could give a broader answer is there any initiative are there any initiative actions for the regulations towards the cannabis slash hemp derived edibles and consumer products such as dietary supplements skin care products etc thank you juliana i think this brings also back some of the issue related to uh cbd used as cannabis derivatives for certain preparations uh first of all in the convention there is no mention of amp per se but only of the cannabis plant meaning any plant of the genus cannabis so this is what is in the conventions from the legal point of view so the as you know the convention required that control substances including cannabis and cannabis related substances and i underline controlled substances be used exclusively for medical and scientific purposes so the use of cannabis related substances for purposes other than those uh is not in line with the convention however i the if the the in the question the the references to products or dietary supplements that contain cbd if cbd is not considered to be controlled then there would be something that would need to be left to the national authorities to determine the level of control that needs to be applied to these uh preparations or products if the the preparations contain substances that are under control from the point of view of the international convention national authorities needs to control them and they need to be prescribed with proper medical prescription for related health condition uh so if uh let’s say thc for example that is clearly controlled is used in a preparation there needs to be used for medical and scientific purposes um not for skin care product that this is what the convention requires if it was instead let’s say a skincare product or dietary supplement containing cbd that would not uh seem to you know fall into the control of the international conventions however are still a product that may have an impact on the health of those who are taking them and we you know we would expect that the national authorities medical authorities would put in place regulation on the assumption or the administration of these substances thank you very much stefano thank you very much to all who sent questions unfortunately we have reached the time of our side event um it’s been in my opinion incredibly successful we’ve had uh at one point we’ve had 220 attendees now we have 218 this was quite stable so thank you very much for this great interest that our side event generated thank you to all um speakers thank you very much to our co-sponsors japan the european union finland germany and thailand thank you united states for providing stacey as a speaker we very much appreciate that thank you mr president thank you to the incb thanks to everybody and have a great day evening afternoon wherever you are thank you very much and hope to see you again in one of our consultations bye-bye you.