There are five glaring weaknesses in the National Cannabis Master Plan (NCMP) Version 5 that need to be urgently addressed if South African cannabis reform is to lead to any economic benefits. The most urgent issue that needs to be tackled is for the right regulatory framework to be put in place, but even if the law is changed as the NCMP envisages, the document does not address the most serious threat to SA’s cannabis fledgling cannabis industry. One of the main dangers is one that isn’t even mentioned as a problem in the NCMP: the unspoken danger of an export quota that would limit SA exports to a total of 500 kg a year? Shock, horror? Yes.
SA is building an entire export-based industry around medicinal cannabis without factoring in the possibility that we might be allowed by a UN-designated body to export only a fraction of what we produce. And with no vision for a local market, cannabis reform may well blow up in everybody’s face: companies may lose the millions invested in GMP certified facilities, there will be limited forex tax revenue for the government and most of the R28 million cannabis industry will remain in illegal hands.
5 reasons why the NCMP will fall flat unless government wakes up
These are five main issues SA’s cannabis reformers have to urgently tackle if they want to unleash the economic potential of the plant:
No Vision for a Local Market, Neither Medical nor Adult-Use
Almost every insider has stressed that to develop a successful world class cannabis industry, the local market needs to be developed first. The NCMP acknowledges there are over 3,5 m cannabis consumers in SA, and that the Connotational Court has decriminalized private adult-use consumption, but has no useful suggestion as to how this could be incorporated into any economic growth plan. This is despite the fact that legalizing and regulating adult-use consumption would open the doors for broad-based commercialization of the plant. Right now, the only options for local consumers are to either grow their own or belong to a cannabis club, the legal status of which remain uncertain. And to make matters worse there is no clarity on how CBD medicinal products are going to be integrated into local health-care systems and that the legislated dosage on non-medical CBD products is so low as compromise product efficacy. The craziness is accentuated in that there is no provision in the proposed legislation for local farmers to grow low THC/high CBD cannabis for local processors who will have to import all their raw material requirements?
No Plan How to Legalize SA’s 900 000 Illegal Cannabis Farmers:
SA has a well-established illegal cannabis industry centred mostly in the Eastern Cape. The NCMP makes bold promises to develop agri-processing centres and support services for cannabis farmers to bring them into the mainstream, but offers no answers as to what kind of cannabis it wants them to grow, as long as they’re not growing the high-THC recreational cannabis they’re growing now! Under the current Cannabis for Private Purposes Bill, all these small-scale farmers will remain illegal and open to persecution by the police, which raises the question of who actually benefits from legalization, and why?
Possible International Export Quotas:
The NCMP makes no mention of the fact that SA may face quota restrictions in supplying the international medical cannabis market. At a Gauteng Government webinar in June, the South African Health Products Regulatory Authority spokesperson brushed off concerns about possible export quotas saying that government would keep monitoring the situation. Cannabiz Africa understands that the restrictions on how much cannabis SA will eventually be able to export lie outside government’s hands and is in the ambit of the International Narcotics Control Board. The Vienna-based organization is tasked with implementing United Nations drug covenants and is considering restrictions on how much cannabis sovereign countries can export. Insiders say the SA quota being banded about is 500 kg! If this is implemented, government can kiss goodbye to building an export industry and investors can kiss goodbye to their investments. At the very least the Department of Trade and Industry should be punting the cannabis export market, but they’ve been absent from the debate so far.
Unrealistic Expectations over Hemp:
DALRDD seems set on making hemp the key driver of the local cannabis economy, but a closer look at the strategy exposes serious shortcomings. Among them is that the hemp industry requires substantial investment in processing facilities before small-scale farmers can benefit. DALRDD’s talk of issuing hemp licenses by October doesn’t amount to much because there won’t be any production this year, even if the law is changed in the next month to redefine hemp as an agricultural crop. There’s another danger in that the current classification of hemp is that it has to contain less than 0,2% THC. Some agronomists have noted that SA environmental conditions lend themselves to THC development and that even seeds with the recommended THC levels may give rise to plants with a higher THC level, thus rendering the hemp legally unusable. There is also no framework for growing hemp for CBD purposes.
No Protection of Local Cannabis Heritage from Bio-Piracy
The protection and development of SA’s indigenous knowledge systems, landraces and cannabis “intellectual property” should be the cornerstone of the NCMP. However, because the country’s heritage is so deeply rooted in producing recreational cannabis, the NCMP simply avoids the issue. SA has a number of world-renowned landraces, Durban Poison being probably the most famous. But there is no strategy for research and development and promotion of SA strains and protection against international bio-piracy.
These five areas are precisely the issues the SA government should be tackling in order to get a healthy legal cannabis economy off the ground. The NCMP’s starting point should be to develop our existing strengths as a cannabis producer – SA should be the world leader in producing high-THC, adult-use cannabis because that’s already what we do best.