Cannabis Light: vendita infiorescenze e derivati della Canapa Industriale

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La commercializzazione dei prodotti a base di canapa, della Cannabis Light e delle infiorescenze, è in realtà molto risalente nel tempo.

Ha però avuto un vero e proprio “boom” con l’entrata in vigore, lo scorso 14 Gennaio 2017, della L. n. 242/2016 recante, appunto, le “norme per il sostegno e la promozione della coltivazione e della filiera della canapa (Cannabis sativa L.), quale coltura in grado di contribuire alla riduzione del consumo dei suoli e della desertificazione e alla perdita di biodiversità, nonché come coltura da impiegare quale possibile sostituto di colture eccedentarie e come coltura di rotazione” (art. 1, co. 1).

Al successivo comma 2 del medesimo articolo si specifica poi “che la presente legge si applica alle coltivazioni di canapa delle varietà ammesse iscritte nel Catalogo comune delle varietà delle specie di piante agricole, ai sensi dell’art. 17 della Direttiva 2002/53/CE del Consiglio, del 13 Giugno 2002, le quali non rientrano nell’ambito di applicazione del testo unico delle leggi in materia di disciplina degli stupefacenti e sostanze psicotrope, prevenzione, cura e riabilitazione dei relativi stati di tossicodipendenza, di cui al decreto del Presidente della Repubblica 9 Ottobre 1990, n. 309”.

La vendita dei prodotti a base di CBD e con THC compreso tra lo 0,2 e lo 0,6 %

A norma del successivo comma 3 dell’art. 1 “il sostegno e la promozione riguardano la coltura della canapa finalizzata a:
a) alla coltivazione ed alla trasformazione;
b) all’incentivazione dell’impiego e del consumo finale di semilavorati di canapa provenienti da filiere prioritariamente locali; […]
d) alla produzione di alimenti, cosmetici, materie prime biodegradabili e semilavorati innovativi per le industrie di diversi settori; […]”.

Dall’entrata in vigore della norma sono sorte una miriade di imprese che si sono imposte nel mercato della vendita dei più svariati prodotti, appunto, a base di
cannabis, con alte concentrazioni di CBD e THC nei limiti di legge (estratti di oli, prodotti cosmetici ed erboristici etc.).

Un grandissimo successo ha avuto la produzione e la commercializzazione della c.d. "Cannabis Light".

La c.d. "Cannabis Light"

Poichè l’art 17 della Direttiva 2002/53/CE del Consiglio del 13 Giugno 2002 (alle cui
varietà si applica la norma) recita che “[…] la Commissione provvede a pubblicare nella
Gazzetta Ufficiale delle Comunità Europee […] tutte le varietà le cui sementi e materiali di moltiplicazione, ai sensi dell’art. 16, non sono soggetti ad alcuna restrizione di
commercializzazione”, la liceità della vendita di prodotti a base di Canapa Sativa appare
chiara.

Ovviamente, ai fini della liceità, il prodotto deve rientrare nei limiti di legge che significa, in base all’art. 4 della Legge, che il contenuto complessivo di THC della coltivazione non deve essere superiore allo 0,2 %.

ll medesimo articolo specifica anche che se il contenuto di THC “della coltivazione risulti superiore allo 0,2 % ed entro il limite dello 0,6 %, nessuna responsabilità è posta a carico dell’agricoltore che ha rispettato le prescrizioni di cui alla presente legge”.

Tale specificazione, a mio parere, consente la vendita di un prodotto con THC fino allo
0,6 %.

Si giunge a tale conclusione interpretando le norme di cui alla legge ed in
particolare in quanto, in caso di raccolto con THC entro tale limite (ma superiore allo
0,2 %) non solo al coltivatore non viene applicata nessuna sanzione, ma neppure viene
previsto un eventuale sequestro o distruzione del raccolto.

Brevi considerazioni sulla Circolare del Ministero dell'Interno

La Circolare del Ministero dell'Interno del 31 Luglio 2018 afferma però che i prodotti con concentrazioni di THC superiori allo 0,5 % dovrebbero essere considerati sostanze stupefacenti (con tutte le conseguenze del caso), circolare che avrò modo di commentare nei prossimi articoli.

Tuttavia, l'interpretazione che consente la vendita di prodotti sino al limite dello 0,6 % di THC pare corroborata dalle più recenti pronunce della Corte di Cassazione.

Da ultimo la Sentenza n. 4920/2019, ha chiaramente dichiarato lecita la vendita di prodotti con concentrazione di THC e Cannabis Light sino allo 0,6 % (come del resto stabilito dalla L. 242/2016) e dei Giudici di merito (che anch'esse verranno affrontate nei prossimi articoli).

Coltivatori e commercianti

E' chiaro che il coltivatore, rimanendo il prodotto con THC entro lo 0,6 % nella Sua disponibilità (la distruzione o sequestro del prodotto, a norma dell’art. 4 è prevista solo in caso di percentuale di THC superiore allo 0,6 %), potrà commercializzarlo.

Se il produttore può commercializzare tale coltivazione, è chiaro che anche tutti gli altri soggetti facenti parte della “filiera” potranno commercializzarlo a loro volta.

Tale regime infatti, si deve obbligatoriamente estendere anche al commerciante che abbia ricevuto tale prodotto e lo ponga in vendita.

Nel rispetto di tali limiti dunque, dalla canapa coltivata (art. 2 L. 242/2016) “è possibile ottenere:
a) alimenti e cosmetici prodotti esclusivamente nel rispetto delle discipline dei rispettivi settori;
b) semilavorati […];
g) coltivazioni destinate al florovivaismo”.

Tutti i prodotti rientranti in tali categorie devono essere considerati legali e dunque,
possono essere liberamente posti in vendita.

La vendita delle infiorescenze: la c.d. "Cannabis Light"

Dall’entrata in vigore della Legge, i produttori si sono concentrati (più che su alimenti e cosmetici) sulla vendita delle infiorescenze delle piante con la commercializzazione della c.d. “Cannabis Light”.

La questione è di non poco rilievo, se si considera che, inizialmente esplicitamente
previste nei lavori preparatori alla Legge, la norma finale non le ha prese specificamente in considerazione.

Le infiorescenze sono la parte della pianta che, concretamente, contiene il principio attivo THC e tutti gli altri, come il CBD, ed il problema che si è posto, ad un anno dall’applicazione della norma, è come considerare tale prodotto e, dunque, in quale categoria (lecita o no) inserirlo.

Le infiorescenze, infatti, non compaiono esplicitamente nell’elenco dei prodotti leciti e ottenibili dalla coltivazione della canapa di cui all’art. 2 della Legge.

La Circolare del Ministero delle Politiche Agricole

Pur non chiarendo del tutto la questione che, pertanto dovrà dal mio punto di vista essere normata al più presto, è intervenuto il Ministero delle Politiche Agricole.

Con circolare n. 5059 del 23 Maggio 2018 (circolare che commenteremo nei prossimi articoli), ha chiarito che - pur non essendo citate espressamente dalla legge n. 242 del 2016 né tra le finalità della coltura né tra i suoi possibili usi - le infiorescenze rientrano nell’ambito dell’articolo 2, comma 2, lettera g), rubricato, “Liceità della coltivazione”, ossia nell’ambito delle coltivazioni destinate al florovivaismo.

La situazione rimane comunque incerta, in quanto pur essendo lecita la vendita, non se ne capisce la destinazione d'uso che non rispecchia l'utilizzo che, effettivamente, viene fatto della "Cannabis Light".

Vi è anche da considerare il parere negativo alla vendita in genere di prodotti a base di THC dato dal Consiglio Superiore della Sanità del 10 Aprile 2018.

In ogni caso, a seguito di tale specificazione, la vendita delle infiorescenze è, esplicitamente, lecita.

Tali prodotti debbono derivare da una delle varietà ammesse, iscritte nel Catalogo comune delle varietà delle specie di piante agricole, il cui contenuto complessivo di THC della coltivazione non superi i livelli stabiliti dalla normativa.

Infine, il prodotto non deve contenere sostanze dichiarate dannose per la salute dalle Istituzioni competenti.

Le possibili categorizzazioni della Cannabis Light

Contenendo alte concentrazioni di CBD, le infiorescenze potrebbero anche venire considerate come prodotto medicinale oppure, nonostante non si tratti in linea teorica di un prodotto per combustione, anche come succedaneo al tabacco.

Le imprese produttrici hanno ovviato al problema denominando il prodotto “ad uso tecnico” oppure ad “uso erboristico o cosmetico” e specificando che non si tratta di un prodotto idoneo alla combustione.

Le infiorescenze nella Direttiva 2002/53/CE

Si ritiene che la legalità della commercializzazione delle infiorescenze derivi dal fatto che il contenuto di THC si rinviene soprattutto nelle infiorescenze e non avrebbe dunque senso prevederne dei limiti (art. 4) se non fosse consentita la vendita di tale prodotto.

Anche la disposizione di cui all’art. 17 della Direttiva 2002/53/CE del Consiglio esplicita che non esiste alcuna restrizione di commercializzazione sia per le sementi sia per i materiali di moltiplicazione ed appare indubbio che le infiorescenze siano, appunto, materiali di moltiplicazione della canapa.

Allo stato, dunque, le infiorescenze possono essere liberamente commercializzate a patto che non siano considerate dai distributori, appunto, medicinali o succedanei al Tabacco.

Pertanto, soprattutto relativamente alla Cannabis Light, specificato che il prodotto non è atto alla combustione e non è un medicinale e nel rispetto dei limiti di contenuto del THC, ne è possibile la vendita.

Questa del resto è la soluzione che, nel tempo, è sempre stata adottata anche per la
commercializzazione - ad esempio - dei semi di canapa.

Si auspica, tuttavia, che il Governo intervenga specificando l'effettivo uso delle infiorescenze.

I controlli sul prodotto da parte delle Pubbliche Autorità

In merito ai controlli sul prodotto, vi è da distinguere tra quelli fatti dal Corpo Forestale dello Stato (ora Carabinieri) sulle coltivazioni, e ogni altro tipo di controllo da parte degli organi di Polizia Giudiziaria.

Questi vengono eseguiti su segnalazione e nel corso dello svolgimento di attività giudiziarie, normati all’art. 4 della L. 242/2016, da svolgersi nei confronti del coltivatore, da quelli invece eventualmente eseguiti dalle Forze dell’Ordine sul prodotto finale commercializzato.

L’art. 4 stabilisce infatti la regola del “controllo a campione” secondo una percentuale
massima stabilita annualmente mediante campionamento, prevedendo sequestro e
distruzione del raccolto solo se il contenuto di THC è superiore allo 0,6 %.

Inoltre, la stessa impresa agricola effettua i controlli mediante organismi privati
autorizzati, che li rendono disponibili in via telematica e che l’agricoltore deve mettere
a disposizione dei commercianti.

Il D.P.R. 309/1990 (Testo Unico sugli Stupefacenti)

I controlli sul prodotto finale (e dunque nei confronti dei commercianti del prodotto),
avvengono invece sulla base del Decreto del Presidente della Repubblica 9 Ottobre
1990, n. 309, il Testo Unico in materia di stupefacenti.

Pur se anacronistico, dal momento che la canapa contenente principio attivo inferiore allo 0,6 % non è considerata sostanza psicotropa o stupefacente e dal momento che, già alla base della filiera, vengono effettuati i controlli per dimostrare, appunto, il contenuto di THC, tant’è.

Tale situazione, si ritiene, deriva dall’impossibilità di verificare, per i prodotti a base di
canapa, l’eventuale contenuto di THC ed escluderne, appunto, il novero tra le sostanze
psicotrope o, comunque, droganti, essendo sempre necessario un controllo in
laboratorio.

Ciò ha portato all'emanazione della Circolare, già citata, da parte del Ministero dell'Interno e ad una serie di sequestri (a dir la verità per la maggior parte rivelatisi illegittimi) dei prodotti in vendita all'interno dei negozi da parte delle Forze dell'Ordine.

Sanzioni penali

Il D.P.R. 309/90, all’art. 73 sanziona penalmente chiunque “importa, esporta,
acquista, riceve a qualsiasi titolo o comunque illecitamente detiene:
a) sostanze stupefacenti o psicotrope che per quantità, in particolare se superiore ai limiti massimi indicati con decreto del Ministro della salute emanato di concerto con il Ministro della giustizia sentita la Presidenza del Consiglio dei Ministri - Dipartimento nazionale per le politiche antidroga - ovvero per modalità di presentazione, avuto riguardo al peso lordo complessivo o al confezionamento frazionato, ovvero per altre circostanze dell'azione, appaiono destinate ad un uso non esclusivamente personale;
b) medicinali contenenti sostanze stupefacenti o psicotrope elencate nella tabella II, sezione A, che eccedono il quantitativo prescritto. In questa ultima ipotesi, le pene suddette sono diminuite da un terzo alla metà.

Sanzioni amministrative

All’art. 75, invece, stabilisce una sanzione amministrativa per “chiunque illecitamente importa, esporta, acquista, riceve a qualsiasi titolo o comunque detiene sostanze stupefacenti o psicotrope fuori dalle ipotesi di cui all'articolo 73, comma 1-bis, o medicinali contenenti sostanze stupefacenti o psicotrope elencate nella tabella II, sezioni B e C, fuori delle condizioni di cui all'articolo 72, comma 2, e' sottoposto, per un periodo non inferiore a un mese e non superiore a un anno, a una o più delle seguenti sanzioni amministrative:
a) sospensione della patente di guida o divieto di conseguirla;
b) sospensione della licenza di porto d'armi o divieto di conseguirla;
c) sospensione del passaporto e di ogni altro documento equipollente o divieto di conseguirli;
d) sospensione del permesso di soggiorno per motivi di turismo o divieto di conseguirlo se cittadino extracomunitario.

I possibili esiti dei controlli

In caso di controlli, dunque, le Pubbliche Autorità - viste anche le indicazioni del Ministero dell'Interno e di alcuni Questori - potrebbero procedere al sequestro preventivo della merce (o di un campione delle stesse) per il controllo.

Potrebbero poi elevare immediatamente la sanzione amministrativa nei confronti del responsabile o, se ritenessero di applicare il più grave art. 73, iniziare immediatamente le indagini penali.

Va da sé che, all’esito dei controlli, appurato che il limite di THC è inferiore ai limiti di legge dovrebbero, rispettivamente, annullare la sanzione amministrativa od archiviare il procedimento penale, dal momento che non si tratta di sostanze psicotrope e che quindi non si ricade nell’ambito di applicazione del D.P.R. 309/90 (come chiaramente specificato dalla L. 242/2016) e, conseguentemente, restituire la merce sequestrata.

Con i prossimi articoli si affronterà il problema dei sequestri di Cannabis Light, anche in relazione alla nota Circolare del Ministero dell'Interno ed alle decisioni giurisprudenziali di Giudici di Merito e Corte di Cassazione.


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