USDA Hemp Comments

Opening
Colorado is and will continue to be, a leader in hemp production.
We have realized the benefits of hemp and embraced the crop as an economic driver for the state. It has attracted scientists, investors, and entrepreneurs who have devoted their time and resources to advance the industry. 
Since the passage of the 2014 Farm Bill through 2017, Colorado accounted for more than half of the nation’s industrial hemp production. As of 2018, Colorado is home to 835 licensed producers, 1,200 registered land areas, and over 31,000 outdoor and 110 indoor acres of licensed cultivation space. We also launched the first certified hemp seed program in the US and hired the first official Industrial Hemp Certified Seed Specialist in the country to give growers greater confidence in the quality of their seeds.

With the passage of the 2018 Farm Bill, a number of issues that impact American farmers remain to be addressed at the federal level.  
Regulatory framework suggestions

•	We need clear direction from the USDA as to how to proceed in order to provide certainty to the industry and create a level playing field for all states.
•	We must create standardized protocols for the collection and analysis of hemp samples.  Disparities in sample preparation and analysis marginalizes test results, resulting in material that is non-compliant in one state becoming a marketable commodity in another state. 
•	We need nationally accepted transportation solutions for the smooth movement of hemp and hemp products.  Law enforcement and state agencies need to work together efficiently.
•	A certified seed system that addresses normal certified seed production plus THC level must be developed and enforced on a national level.  Enforcing the federal seed law is increasingly important.
•	Hemp producers need equal access to agricultural financial services.
•	Federal grant matching funds should be made available to increase research, development, and processing.
•	The hemp industry will see an increase in grain production for human and animal consumption and regulations will need to reflect that.
•	FDA rulings should recognize hemp and its derived products as safe and acceptable in the market and should work to validate label claims of CBD products.

Conclusion
Colorado has more businesses in the hemp economy than any other state. From university research to farm equipment manufacturing to biotech firms, we’re all in on hemp.  We are excited to work closely with stakeholders across the US to treat hemp as any other agriculture crop and find business and consumer-friendly regulatory solutions.