How To Dry, Cure & Store Smokable Hemp Flower

Fellow McAllister Garfield attorney Frank Robison represents the transporters in that case and has represented clients in many similar cases. While the interim guidelines don’t explicitly address the issue of hemp exports, they do categorically rule that states cannot prohibit the interstate transport of hemp material. If this clause remains in the final guidance, this clarity will be central to the future of the hemp transport business. The hemp and hemp-derived CBD industries currently face enormous legal uncertainty. Many clients have questions with regard to the marketing, sale, and transportation of hemp across state lines. Unfortunately, the authorities that define the rights, responsibilities, and liabilities that apply to the hemp industry are currently in conflict, and are also rapidly evolving.

Watching the TDA Hemp Orientation Video is a pre-requisite to applying for a hemp license. To ship CBD with UPS, you must be able to identify where the raw materials grew, how they were processed, and how they were obtained . If you can’t 100% prove that you have met all the prerequisite requirements above, you have a good chance of violating the terms and agreements of the approved carriers below. In this article, we’ll cover how to ship CBD in a way that’s safe and legal for you and your customers. The Fresh Toast is an award-winning lifestyle & health platform with a side of cannabis.

We work hard each day to bring uplifting and informative information about culture, weed, celebrity, tech and medical marijuana. Transport Hemp Biomass Biomass is generally shipped in large quantities. Transport Live Hemp Plants Read our guide on shipping the very difficult Live Hemp Plants. Understanding your requirements and objectives is important to us. We listen and work together to create a truly successful supply chain.

How To Transport Hemp Professionally

The 2018 Farm Bill introduced a groundbreaking amendment that, among other things, legalized hemp and all of its derivatives for production and interstate sale. Though the Farm Bill does not guarantee states the right to cultivate hemp , it does explicitly allow the transportation delta 10 thc effex of hemp across state lines. We always provide our clients with a procedure for the transportation of the hemp shipment. This includes a package documenting all of the COAs, registrations and a bill of lading explaining the weight and lot numbers of the shipment.

Agriculture Industry

Our domestic transportation expertise, advanced supply chain technology & customized transportation solutions will help you develop and implement successful supply. We huile de cbd pour enfant offer quotes within 15 minutes and provide everything included in shipping your goods upfront. To learn more about Boveda wholesale opportunitiesclick hereor email

Shipping CBD is a somewhat complicated matter, as you not only have to comply with any shipping carrier requirements but also ensure it’s legal to ship from the place of origin and legal to receive the product at its destination. Your CBD-containing products must be third-party tested to demonstrate the chemical makeup of the products you’re selling, including the THC content. Third-party testing may be a prerequisite for some of the above requirements. The U.S. CBD market as a whole (both hemp-derived and marijuana-derived, where legal) is expected to reach$20 billion by 2024. Please note, all references to “CBD” or “CBD products” within this post refers to hemp-derived CBD, not marijuana-derived CBD.

ROI of hemp per acre – The average ROI of hemp biomass per acre is not an easy issue to address. Many factors affect the price of hemp per pound, including type, genetic quality, processing procedure,… For more tips on hemp farming and production, visit our blog or contact our team of experts for targeted advice. We offer affordable consultation services beginning with a free introductory call.

It is the responsibility of the shipper to ensure compliance with all such laws, including the Food, Drug & Cosmetic Act, 21 U.S.C. §321, et seq. Raw hemp in plant form is accepted for transportation only for pre-approved shippers as a contractual service within in the U.S. network (U.S. import, export, and international shipments are not permitted at this time). Finding the right carrier to ship industrial hemp can be a challenge. Many trucking companies are still apprehensive about accepting commercial hemp shipments. This is where leveraging the network of a 3PL can come in handy.

420 Intel is the leading source for cannabis news from around the world. Get the latest updates on cannabis legalization, politics and technology, as well as developments in medical and recreational how to use cbd oil for hair growth marijuana news. Our commitment is to bring you the most important cannabis news stories every day of the week. There are a few things that go into achieving a successful hemp shipment.

With its variety of uses and renewability, the plant is eco-friendly and sustainab… For example, a reefer truck – which is a refrigerated, 53-foot trailer capable of hauling a maximum of 45,000 pounds – can cost between $0.05 and $1.00 per mile, depending on the size of the load and the route. Hiring a sprinter van to haul hemp, on the other hand, can range from $0.80 to $16.50 per mile. Our carriers go through a rigorous vetting process to ensure they are compliant with insurance and have a satisfactory safety rating.

Possess a certificate from a testing facility with all the information about the product. Nothing needs to change on the Bill of Lading but having the proper documentation from a state-approved facility helps cover all angles. The most important information needed when starting a hemp transport quote is the type of hemp pant and how many there are being transported. A similar story played out in Cary, South Carolina where Ayman Tamim Nu Mann Alqazah, a wholesaler of e-cigarettes and other similar goods, was charged with trafficking marijuana after a box of CBD-infused gummies he ordered popped open while in transit. The News & Observer reports that box opened while it was transferred from a truck in Florida. Texas Sued Over Smokable Hemp Ban It only took a few days for Texas to find itself in a lawsuit against its recent smokable hemp ban.

Time is of the essence when it comes to hemp cultivation and processing, and a slow review period could lead to a spoiled product. The answer is simple—a police officer can’t pull over a train. Shipping by train, though potentially more expensive, can solve the problem of overzealous local law enforcement.

We do not hide the facts, we embrace and share them with our clients. Please do your own research to ensure the best service possible, with whoever you chose. When it comes to doing it right, we are the go-to for many large hemp firms. Fide Freight will get you the correct transportation solution with our massive network of drivers and owner operators.

The DOT also regulates the number of hours truck drivers can spend driving, to reduce the risk of fatigue-related trucking accidents on the highways. On longer shipments, especially with a refrigerated cargo, the company will need to book two drivers for a job. This allows for continuous travel and avoids overnight stops for DOT-required rest breaks.

Though not all of these states are as “bad” as Idaho, none of them have CBD-friendly laws. Paying for air-shipment may seem like a solution, but there are numerous regulations and transit-company polices that Hemp Co. must deal with. There are 41 states that consider industrial hemp and hemp products to be legal. Even in stricter states like Idaho and Oklahoma, hemp products are legally sold in stores .

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The most efficient way to package it in a truck is to stack the super sacks on top of each other prior to loading. Hemp flower is packaged in all different types of packaging from boxes, totes, bags, or a combination of both. The most efficient way to package hemp is to vacuum seal the flower and place it in large totes or bags. Hemp is much different than other commodities due to the nature of the cannabis plant. This staff member will be in charge of the Bill of Ladings, checking the product piece count and verifying if everything that was shipped was received. You’ll have to assure the arrival of the product to its destination.

During their time in the hemp industry they have accumulated over 200 clients, while working with about 6,000 independent truckers and around 120 trucking companies. “When you’re transporting general goods you don’t have to worry about weigh stations, or worry about people mistaking the product as being legal or illegal,” Jon told Hemp Benchmarks. “And a lot of the time you don’t have to worry about the carrier rejecting the load. A CHP is defined as any product processed or manufactured for consumption that contains hemp, including food, a drug, a device and a cosmetic. It does not include any consumable hemp product containing a hemp seed, or hemp seed-derived ingredient used in a manner generally recognized as safe by the U.S.

After decades of prohibition, the modern legal hemp industry is still in its infancy. Along with figuring out best practices for growing, harvesting, and processing the plant, the hemp sector is also navigating how best to transport the production generated by hemp farmers and processors. The largest challenge for those involved with hemp transport, Wilcox explains, is finding drivers who are willing to transport the plant. While confrontations with local law enforcement remain a possibility, this might deter otherwise willing truck drivers.

We navigate through complicated shipping requirements so you can ship more efficiently. Whether your business is in a mainstream industry or something totally unique, our extensive knowledge makes us your one stop shop for shipping solutions. Dry Vans and Refrigerated Trucks— largest trucks we have and are best for larger shipments of live mothers and large amounts of wire racks. All dry vans and refrigerated trucks are 8′ wide, 8′ tall, and 53′ long. New interim regulations put out by the United States Department of Agriculture in October 2019 seek to set this conflict straight by ruling that states cannot prohibit the interstate transport of hemp material.

Make sure the driver is versed or holds general information on the legality of transporting hemp, including the USDA new interim hemp regulations. In January of 2019, an Oregon man operating a commercial semi-truck was pulled by Idaho State Police in Boise. Denis Palamarchuk was transporting 6,700 pounds of legal industrial hemp destined for Big Sky Scientific in Aurora, Colorado. The hemp tested positive for the presence of THC, and the driver, Denis Palamarchuck, was arrested and charged with felony trafficking of marijuana. While hemp is known to contain trace amounts of THC, they are two different substances under federal law. Idaho law, however, makes no exceptions for hemp, and in fact, is known to have some of the strictest laws on cannabis and hemp in the country.

No: You Have Anything Less Than The Above Requirements

Live plants do not have the distinctive smell that easily draws unwanted attention when pulled over by authorities or when parked at a rest stop. Make sure the product is contained in a sealed plastic bag or mylar to both protect it from elements and contain its smell. Creating the bridge between cannabis and hemp producers/processors, and retailers. DEA’s Latest Rule Update Has Hemp Industry Concerned Earlier this month, the US. Drug Enforcement Administration issued their interim final rule regarding hemp processing and distribution in … Such was the case for Zach Wilcox, Senior Transportation Specialist at Fide Freight when he passed through Oklahoma carrying hemp earlier this year.

You may be able to legally import into the U.S. a CBD product, but you should consult an attorney. Even though hemp-derived CBD is much more widely accepted and legalized than marijuana-containing products, CBD is still closely monitored and regulated. Here are the factors that will help you understand whether your supplier’s CBD is legal to ship. Cost Effectiveness – When it comes to shipping larger amounts of hemp product, such as biomass, we can cut costs and use strategic approaches within our network of drivers. If you have your license and COA handy, shipping should be simple.

Unfortunately, there is currently no standard methodology for sampling. You should have a tight and organized schedule for your shipping process. Of course, details like shipping address, routes, etc. should have been arranged before departure, and a total piece count and weight of the product should have been done. Whether you’re bagging up hemp flower or lining your curing totes, make sure you choose the right tool for the job. Professional hemp growers use bags and liners especially designed for hemp. You can either strip off the hemp flower from the stalk or cure the entire hemp stalk.

International Hemp Shipments

Maddux ended up spending 36 hours in jail before being released on a $1,000 bond. Recruit and train drivers to understand the ways your organization is combating their risk out on the road. Drivers versed in the appropriate response will have an easier time when face to face with authorities on the road and will be less likely to be arrested.

Again, this is by using our relationships and our thorough vetting process to enable our customers. What I mean by this is when the police have your shipment pulled over on the side of the highway, do they have the skill to pursued that police officer that it is in fact a lawful shipment? My team and I are fielding calls all day and night to protect our customers and our reputation. We understand that having the proper documentation is enough, but law enforcement can stop your hemp shipment and test it if they want. To avoid this, we answer the phones are make the calls out to protect and legitimize our customers shipments. Hemp Transportation is a combination of knowledge, skill, and availability.


In this post, I’ll walk through exactly how we got into the current mess we are in and why transporting hemp can be such a massive risk—even though hemp is technically federally legal . For this reason, hemp farmers and distributors are still struggling to find qualified drivers and transportation carriers willing to transport the plant. Even when they do, confrontation with law enforcement still looms large. Indistinguishable from cannabis to the naked eye, hemp faces a number of roadblocks to distribution. Find out how your organization can hire the right drivers so that your hemp transportation runs smoothly and safely.

Be sure to retain policies only from carriers that specialize in hemp. Because hemp coverage is not a form policy, it will only cover perils that are specifically negotiated into the policy. Hemp was farmed on 511,000 acres last year by the more than 12,000 active hemp licensed farmers currently held across the U.S.

The company moved over 2 million pounds of hemp over the past year and knows the risks and complications of hemp transport firsthand. Continue reading for information about hemp production plans, guidelines for sampling and testing procedures, disposing of plants not meeting necessary requirements and licensing requirements. The U.S. Domestic Hemp Production Program establishes federal regulatory oversight of the production of hemp in the United States.

While the most common form of transport still appears to be by car or truck, the combination of inconsistent testing and overzealous local police has caused some hemp transporters to utilize other methods of transport. One method of commercial hemp transportation that seems to have caught on recently is trains. Congress drafted and passed the law in order to study the growth, cultivation, or marketing of industrial hemp, and determine the feasibility and benefits of such a program in the United States. The law defines “industrial hemp” as distinct from marijuana, asCannabis sativawith less than a 0.3% of delta-tetrahydrocannabinol concentration . The 2014 Farm Bill did not explicitly state that hemp and it’s extracts would fall outside of the CSA, though all evidence points to that being Congress’s clear intent. If you have a legal team, make sure they read over your statements and clearly identify where you intend to send your CBD products.

Additionally, any marketing claims regarding health, including any claim that a product would diagnose, cure, mitigate, treat, or otherwise prevent disease, are strictly prohibited with respect to hemp and CBD products. In fact, if a product is not FDA-approved but may simply appear to have some medical benefits that have not been FDA-approved, products must include a disclaimer stating this. Welcome to the Texas Department of Agriculture Industrial Hemp Program website.

We leverage strong relationships with airlines and US customs to help mitigate the risk. In return, our customers are able to open up to new markets and make more money. Fide Freight has been recognized for our excellence in hemp transportation in Hemp Benchmarks, Hemp Today, Analytical Cannabis, Future4200 and a few smaller outlets. We have helped over 200 customers with hauling hemp bales, biomass , hemp flower, crude, distillate, isolate, and more. UPS reserves the right to discontinue service to any shipper for, among other reasons, tendering a package containing marijuana, hemp or hemp products that does not comply with all applicable laws or the UPS Tariff/Terms and Conditions of Service. UPS accepts products made from hemp (including Cannabidiol – CBD) for shipment only as permitted by all applicable state and federal laws.

Your Source For Global Cannabis Industry News!

The shipment contains hemp or hemp-based products that contain no more than 0.3% of THC on a dry weight basis. The CBD you ship must have THC levels of not more than 0.3%, and you ra royal cbd gummies must be able to verify in writing the CBD and THC levels of the products you are shipping. For some states within the United States, the limit of THC in hemp products is zero.

Under the 2018 Farm Bill, it’s currently legal to transport hemp, and hemp-related products, across the United States. Hempsac is the industry’s first and only packaging solution that helps farmers cure, store and transport this special crop. Post-cure, you can inventory hemp flower for up to a year inside a tightly closed Hempsac.

The CBD you sell should come from hemp plants, not marijuana. Talk to an attorney if your CBD comes from synthetic sources, but the THC level must still be at or below 0.3%. If you’re working with any partners, like a supplier, you’ll need to keep close tabs to make sure that the products consistently hit this standard. We have successfully transported truck loads of hemp biomass into Canada with proper permits and clearance. Fide’s attention to detail helps enable our customers to reach new markets.

You should also be able to provide a Growers License from the hemp’s state of origin, and, in some cases, you may get asked for a Processors License for the end destination of the transported plant. Electronic versions of our publications are provided as a courtesy to facilitate timely dissemination of academic work for individual, noncommercial purposes. Even in airtight curing bags and storage containers, your hemp’s cannabinoids and terpenes are at risk. Unprotected, terpenes start to evaporate immediately without a terpene shield.

These provisions help ensure the transport of hemp through the state with as little friction as possible. Though these requirements are specific to Idaho, maintaining records throughout the entire process can drastically reduce complications along the way. Get notifications about upcoming Hemp Benchmarks® spot pricing reports and new market insights.

It shouldn’t take you long to notice that it’s one of the fastest-growing categories, with products ranging from CBD-infused water and toothpaste, to CBD dog treats and evenactivewear. 420 Intel is your source for up to date news on the marijuana industry. CBD/hemp liquid products intended for vaporization are prohibited in the U.S. network . Please refer to the Tobacco Vape Policy for more information. Bring your weirdest, complicated and most interesting products to ship.

The establishment of hemp as a regulated commodity also paves the way for U.S. hemp farmers to participate in other USDA farm programs. We only transport hemp products below 0.3% total THC – outlined in the USDA interim full spectrum cbd oil stores near me final rule. 357’s compliance and operation teams actively seek out relationships and have daily communication with state and federal officials ranging from the Department of Agriculture to the Highway Patrol.

However, state and federal law tend to butt heads on the definition. For example, Idaho law classifies any cannabis plant with THC as marijuana. Driving through states that totally outlaw anything to do with marijuana poses a threat.

Scott has spent his entire career representing businesses and helping them comply with municipal, state and local regulations, as well as assisting on transactional corporate and real estate matters. Scott is an accomplished attorney, author and public speaker, having spoke at CannaCon, Cannabis Industrial Marketplace, CannabisAid, and 420 Canna Expo, to name a few. He has also taught Continuing Legal Education on Marijuana business matters, meaning other attorneys see him speak to learn about the nuances of cannabis business law.

As we wrote back in early 2019, the prohibition on interference ONLY applied to hemp cultivated under the 2018 Farm Bill. Provide drivers with appropriate documentation and assurances. Make sure each driver has the right paperwork to support their transport should they be pulled over or arrested in error. This includes registrations for all parties involved in the shipping as well as testing certificates of analysis for the hemp they’re transporting.

If you attempt to ship CBD with a THC level greater than 0.3%, you may face consequences, including arrest, for sending illegal substances through the mail. At the very least, your products can be destroyed in transit upon discovery. Whether you use a CBD supplier or grow it yourself, any CBD product must come from a licensed grower. In other words, you can’t just ship your uncle’s experimental cannabis plants he grew in his shed.

We take seriously our responsibility to have the latest intel on state laws and license requirements to safely transport hemp and ensure our partners investment is compliant from start to finish. Shipping CBD products is one piece of running a successful CBD business. You also need everythingfrom legal payment processing tocreative hemp marketing tactics that follow various regulations and policies set out by everyone from governmental agencies to tech giants like Facebook. Both you and your supplier can face legal challenges and risk getting arrested or shut down for selling illegal products.

All of our trucks are able to be locked up with tamper-proof and security alarm systems. Our drivers are able to provide pictures of the hemp prior to shipping and our hemp specific cargo insurance covers you in case something does happen. Truck drivers who move flower notice a difference when growers store dried hemp in Hempsac products. The drivers don’t have to “air out” their trailers before transporting other goods. Plus, no residual odor transfers to other products when drivers haul a partial load of hemp along with other goods. Selling CBD is a lot more complex than selling apparel or a novelty product, and the industry is moving fast and constantly evolving.

There have been governmental and societal changes recently, but don’t expect it to stop there. Be sure to stay up-to-date on CBD regulations across the globe as well as carriers’ CBD shipping policies to keep a close eye on what changes. Many countries outside of the United States classify marijuana and hemp-related products as illegal and can press charges or destroy products if you try shipping a dangerous substance to their country. With new states allowing hemp to be grown, it will bring a lot of attention to the logistics of transporting hemp. Ask them about how law enforcement tests, what they test for, etc.

Though many states have legalized the cultivation of industrial hemp in some form, the law surrounding Hemp-CBD remains confusing. Other times, law enforcement will seize Hemp-CBD products to confirm that they do not contain THC and then will either destroy or return the products depending on test results. Other times, as was the case with Maddux and CBD for Pets Alqazah, criminal charges are levied against individuals who possess Hemp-CBD. Stories of hemp farmers losing their harvest during interstate transport (and transporters getting arrested for it, too!) currently fill newsfeeds. This has many in the industry wondering if a hemp transport permit could help them avoid the sticky situation themselves.

The Texas Department of Agriculture opened the hemp licensing and permit application process online on March 16, 2020. These major hemp transport hick-ups raise serious concern regarding the safety if interstate hemp sales. While the USDA has reaffirmed its pro-transport stance on compliant hemp products, some states have taken their hemp transportation requirements a step farther. For example, the state of Idaho has developed its first-ever port of entry at which all hemp transporters must report. Drivers must present a copy of the cargo’s hemp production license as well as a U.S. DEA lab report confirming that the product is compliant (i.e., that it doesn’t contain more than .3 percent THC).

On Sunday, August 2, the Texas Department of State Health Se… Curing hemp is one of the most vital steps in cannabis cultivation. Curing ensures the buds produced are potent and of the highest quality possible. The difference between hemp and marijuana is a little bit confusing. Consequently, people tend to lump hemp and marijuana together as one and the same.

Nonetheless, even when transporting hemp grown under the 2018 Farm Bill, there may still be legal issues with respect to interstate hemp transportation. Instead, some hemp batches would test at 0.1%, some at 0.2%, and cbd fruchtgummis sarah’s blessing erfahrungen some may test at 0.3% or greater. If even just one test finds THC levels above 0.3%, then a state could declare that at least part of the hemp is “marijuana” and therefore subject to that state’s marijuana laws.

While we certainly recommend that you still include all the paperwork that you would have when shipping by car or truck, there appears to be significantly less risk of local law enforcement holding up or seizing shipments. For this reason, transporting hemp by train is growing in popularity and was a commonly discussed topic at the 2019 NoCo Hemp conference. With the passage of the 2018 Farm Bill and the legalization of the commercial hemp market in the United States, you would think that transporting commercial hemp and hemp derived products between states would be a non-issue. This is especially true since the 2018 Farm Bill actually contains a provision guaranteeing the right of hemp farmers and hemp producers to transport hemp across state lines.

Marijuana is another name for the cannabis plant, and the term definition varies by usage and legal classifications all over the world. Cannabinoid synthesis has caused a heated debate among researchers. Could it be the key to unlock the mass production of cannabinoids? Live plants, Zach continued, are loaded on to roll-on carts, “or if they’re mother plants they oftentimes are floor-loaded,” meaning the plants are placed directly on the floor in their pots.

Hemp Co. has a large order to fill for a natural food store in Billings, Montana. Hemp Co. decides that the fastest and cheapest method of delivery is ground shipping through Idaho. However, according to a 2015 informal opinion from the Idaho Attorney General,the state makes no distinction between industrial hemp and marijuana. Therefore, Hemp-CBD, even without the presence of THC, is not permitted in Idaho. Even though Hemp Co.’s products come from a farmer who cultivates in-line with Oregon’s industrial hemp program , that does not insulate Hemp Co. from liability if the shipment is inspected by Idaho State Police. Even if Hemp Co. re-routes to travel through another state, it still would likely have to pass through Idaho, Wyoming, South Dakota, or North Dakota.

There have been several different shipments and methods – some of which include shipping clones, mother plants, and seedlings. The most common methods to transport live hemp plants tend to be loading wire racks full of plants or floor loading the mother hemp plants. Once you have your hemp plants ready for transport you may wonder how much can fit in each truck. When you need to transport hemp plants, it can be quite an undertaking, especially if you are new to the hemp plant shipping game. With all the preparation of the plants for the long journey and the specific documents you need in order to actually ship them.

With the industrial hemp market poised to reach $13.03 billion by 2026 and strong hemp growing seasons ahead, there’s plenty of hemp that’ll need to get from point A to point B. One of the joys of working in logistics is partnering with businesses across a variety of fascinating industries. There are all kinds of fun cargo in niche markets that needs to get hauled. Industrial hemp has all the ingredients of an oddball, polarizing and intriguing product which needs its place on the highways. Transport Hemp Crude Oil We receive a lot of questions around shipping Hemp Crude Oil. Box Trucks— All box trucks are 7.5-8′ wide, 8′ tall, and vary from 12-26′ long depending on the clients needs.

This site will provide access to the online forms and information needed to participate in agricultural production of hemp in the Lone Star State. “We recommend 357 to all of our hemp clients. Kevin has extensive experience in the highly regulated cannabis and hemp industries and along with his team, they provide compliant logistics services with a level of professionalism and care.” Make sure you fully understand the destinations to which your business is allowed to legally ship CBD products. Even if CBD is legal in a certain country, you may have trouble shipping items to that country. If you are located in the United States, for example, it may be wise to ship exclusively within the states before expanding anywhere else.

The hemp was later tested and showed a THC level of just 0.043 percent, far lower than the federal permit, 0.3 percent. But the equipment available to the state troopers didn’t make the distinction, and the arrest went ahead. The shipper retains records establishing compliance with such laws, including laboratory test results, licenses, or compliance reports. UPS will not accept shipments containing Hemp products from any location that sells Marijuana or Marijuana products. USPS allows you to ship CBD if possess a license from a state’s Department of Agriculture authorizing the licensee to produce industrial hemp, and the requirement that the tetrahydrocannabinol concentration of such hemp may not exceed a 0.3 percent limit.

Mr. Roberts is also an attorney with McAllister Garfield P.C., a national cannabis and hemp firm with a devoted Hemp and CBD legal practice group. The industrial hemp, or products produced from industrial hemp, contains a delta-9 THC concentration of not more than 0.3% on a dry weight basis. While there are some things you can do to protect yourself when driving hemp across state lines—e.g. Choosing your route carefully and having documentation available—this will continue to be a problem until such time as the FDA or the U.S. courts address the testing issue head-on.

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