Response to the Cannabis for Private Purposes Bill

We had the privilege to farm industrial Cannabis or “hemp” for research purposes since 2018; initially under the SAHPRA guidelines and more recently under the DALRRD. This research has given us a deep understanding of the complexities of the Cannabis sativa plant and its products. We have done extensive Cannabinoid profiling at varying growth stages of a range a both local and imported genetic material. Sampled plants were grown through different seasons in different conditions.

Our research has highlighted the complex nature of the plant and the practical implications of tracking Cannabinoid content throughout the growth cycle of the plant. We also identified a range of desired traits in African landrace Cannabis varieties that compares with some of the best “hemp” landraces in the world.

Based on my own experience of industrial Cannabis and my understanding of the history and social construct of Dagga smoking and farming in South Africa, I want to make the following comments on the Cannabis for Private Purposes Bill with specific reference to the amendments to include hemp.

1. The farming of Cannabis for industrial purposes has no place in the Private Purposes Bill. The constitutional court ruling by interpretation includes the growing of Industrial Cannabis for personal, non-commercial purposes. Commercial Cannabis farming should be seen as primary agriculture and regulated by the DALRRD.
2. There is no botanical or scientific basis to separate the Cannabis sativa plant into distinct species based on the Cannabinoid content. Industrial Cannabis (or hemp) should be defined as a product from the plant. A suitable definition would be “Hemp refers to the non-psychoactive parts of the Cannabis sativa plant”.
3. A fresh Afro-centric approach is needed to allow existing genetic material to be legitimised into the formal agricultural system. Our farmers must be able to utilise indigenous and naturalised Cannabis varieties for industrial purposes. This will unlock further research and breeding and the potential of South Africa exporting our unique genetic traits to the world; with the necessary benefits going to those deserving of it.
4. Regulations based on Cannabinoid content cannot be enacted without detailed guidelines regarding sampling and testing procedures. These will need a science-based approach that includes consultation with the industry.
5. Any cultivation of hemp should not be regulated under the Plant Improvement Act. The act is complicated and daunting for aspiring commercial farmers and does not apply to any other crops they are growing. The industry should be allowed to regulate itself, which includes the continuation of existing improvement of genetic material.
6. The products from hemp cultivation should be regulated within their sectors, for example grains, food and beverages, engineering, textiles, traditional medicine etc.

It is our opinion that the process to get to this version of the Bill was flawed. It is obvious that many of the guidelines are not based on science and that adequate consultation with industry and other role players has not been done. We reject the Bill in its entirety, including the recent amendments.

We are interested in making a verbal presentation.

Yours sincerely

Ignatius Ferreira

Ignited Unlimited (Pty) Ltd.