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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  255. The Way To Have A Blast Outdoor camping Standard arrangements and knowledge can keep you cozy and secure.These guidance will assist your upcoming outdoor camping getaway successful, though going camping out inside the again land is definitely an fascinating venture. Well before nightfall, find your protection. When it will get darker exterior, getting a great destination for your tent, finding wooden and generating meals can become extremely hard. This can be even more true for those area-residents which are not utilized to pitch-black darkness. Avoid this by discovering the right shelter ahead of time. Enable each of the members of your loved ones possess a selection in terms of picking a campsite. Focus on which express you intend to see. There are thousands upon thousands of alternatives in the united states it really is tough to opt for merely one.It is possible to pick a family vote on to really make it less difficult. You should keep in mind the truth that receiving unclean is unavoidable. Take pleasure in hanging out in the forests and acquire unclean. You may return to getting civilized and thoroughly clean when you’re at the house. Outdoor camping can be very dangerous if you’re equipped or otherwise not. Be geared up before departing over a camping trip. After you have eaten the orange, make use of the inside the peel to rub on epidermis for a chemical free bug repellant. Make your family pet leashed and enjoy them directly in case your canine comes with you. Numerous people are anxious of canines. You have to display respect the needs of other individuals if you camping. When you permit them to operate cost-free, pet dogs can get into difficulty and lead to damage to the site if not supervised, also, canines can cause harm. In case the location through which you’ll be outdoor camping is known for wildlife that creates a danger, get extra care together with your food items. This can minimize the possibility of getting attacked. That they need organized routines, though children typically really like outdoor camping. They is probably not accustomed to thing like to seafood or do stuff in nature. Train them the best way to conduct these matters beforehand to make sure an incredible journey. In order to prevent inadvertently depleting the battery packs in your torches in your up coming camping venture, take steps. It is possible to activate a flash light although you’re hunting through what you have loaded for your getaway. Keep your flash light in backwards.This will allow you need to have them. Outdoor camping can be plenty of fun, but it needs a large amount of preparing and knowledge, as was described before on this page. Be sure to implement the guidelines you’ve just study just before heading out on your following camping out trip. Keeping the ideas showcased over in your mind, your camping out journey will certainly become a big success.

  256. Camping Strategies For Someone To Use Camping outdoors can be a absolutely entertaining encounter for your personal complete household! It includes the chance to instruct your family members about becoming a single with mother nature. It may be a rewarding to learn outside in nature for a time. The following article can assist you have got a productive camping outdoors vacation. Select a kind of resting bag according to what time of year it is. You are likely to roast through the night extended within the summertime should your getting to sleep handbag created for cold temperatures that you simply camp out with during summer season. You may find yourself cold and getting a unpleasant time.You might even agreement hypothermia if you utilize a light-weight sleeping case in the wintertime. Bring a success package that you just and make sure to continually already have it on you. Survival products must incorporate normal water purification pc tablets, a surviving blade, a first support package, flare pistol and water-proof complements. This set might be what helps to keep one to remain full of life in case you go missing or anything poor takes place and you’re caught up outdoors for more than arranged. Be sure you carry it along with you go when you’re out of your camp out. Will not think twice to pack excessive things for your youngsters. Outdoor camping might be a messy and messy once you take your youngsters. Kids are constantly drawn to the debris. This means that the kids can get dirty kids. While you can’t do a lot with that, be sure to pack a little extra garments. Outdoor camping is an excellent time but it could be extremely enjoyable or extremely risky based on how equipped you are. Always be prepared prior to leaving behind on the camping vacation. A bandanna or possibly a fantastic object to take on your own journey. These can be used as several things, towel or even some thing to hold an item in. Ensure that your camp in the course of daylight several hours. Should you be in a Motorhome, park your car it inside a well attached area. Choose a dry and toned part of ground if you have a tent. Accomplishing this while in daylight hours could help you save to understand your setting. Once you complete ingesting them, massage the remove on revealed skin area to help keep irritating pests away. Now you possess the simple information and facts for camping out, start preparing the next outdoor camping vacation! Even should it be your first time, as long as you maintain this data accessible you may do just good being a camper. No matter if you are interested in a weekend escape or even an substantial camping outdoors trip, you may be sure to have a good time.

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  262. Outdoor camping Journeys Can Be A Wind Using This Type Of Suggestions All of your family members can take advantage of a outdoor camping to get exciting. Anyone can find out new stuff about the outdoors and learning much more about themselves. It could be extremely gratifying encounter to discover outside in character for quite a while. The next lines have several ideas that one could help make your the very next time which you camp out. The hardwood you find could possibly be damp and never want to burn up, while you may possibly suppose that nature posseses an inexhaustible availability of fire wood. It’s essential that you deliver extra timber and make certain it stays in the dry region. Deliver a survival system that you just and be sure to continually have it on your man or woman at all times.Your surviving set must consist of a emergency knife, water-purifying pills, the first-support kit, first aid kit, and water-proof complements. This set could keep you in existence when you are shed and dying. Be sure you carry it just about everywhere you and do not leave it within your camp out. When investing in via consuming an orange, preserve all of your peels and rub them close to your body for an all-natural insect pest repellent. These things can help to make you stay happy and then make your entire day! Clothes dryer lint can make fantastic kindling to start out your campfire. Gather some lint from the dryer to bring along with you. Suspend a shopping handbag next to your clothes dryer and acquire the lint inside. This is a good way to have kindling by leaving when you’re all set. Be sure you program actions for them, although youngsters usually adore outdoor camping. They might not be utilized to issue like fishing or generating a tent. Teach them these routines ahead of departing. There may be spiders or bears that may create a risk.Each camping out place has its own hazards. When you locate your website, look for the softest, most degree terrain it is possible to find. Before the tent is set up to keep water from getting into, deciding on a slanted or rocky area to camp at could make you unpleasant while in your tent.A tarp must be placed on a lawn. In order to prevent inadvertently depleting the battery packs within your lights on your after that camping outdoors journey, make a plan. You can easily switch on a flashlight although you’re looking by way of what you have stuffed to your journey. Keep your flash light in in the opposite direction.This will allow you require them. With the assistance offered in the following paragraphs, you have the information you need to organize a successful camping out trip. Even when it is the first time, provided that you always keep this info readily available you may accomplish good being a camper. Whether you are vacationing in close proximity to or far from house, you should have a excellent time.

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  264. Program A modern day Camping out Getaway To Not Forget When you haven’t been camping, You’re passing up on an actual treat. Resting and awakening to mother nature is one of the most calming than maybe you have actually envisioned.This short article will support assuage any fears you might have about outdoor camping. There is a pretty good possibility the wooden is going to be damp, even though you may well suppose that mother nature has an inexhaustible availability of fire wood. It’s crucial that you take your very own hardwood along with you that one could stay in a free of moisture location. Don’t anxiety that you will be overpacking for your children. Camping out will get really untidy. Children are very seriously fascinated by soil. Because of this by day’s finish the kids will get filthy in the daytime. As there is absolutely nothing you can do about that, make sure to package some additional apparel. Make an effort to match skating for your schedule in some manner. You may miss the shower room if you are camping outdoors. Camping is a good time but it may be very exciting or unbelievably harmful depending upon how ready you are. Often be geared up just before leaving behind over a outdoor camping vacation. A ‘jungle breakfast’ can be a terrific way to include enthusiasm to your trip.Fasten up small cases of fruit juice, tiny cases of cereal and fresh fruits to trees and shrubs from the forests.This activity brings just a little mix of enthusiasm and experience to any outdoor camping trip. There may be spiders or bears near you that may present a threat to your security. Every single outdoor camping location has various risks. You need to at first keep close to residence.You could come across troubles with your products, or even your getaway isn’t whatever you imagined it will be, in case you are a novice to camping. You could possibly realize there is no need adequate outfits or food. Several things can develop for your very first-time camper, so camping out close to where you reside can help you. Outdoor camping is a good activity for everybody. Right after right now, at this point you understand how to get the best from the next camping out trip and strategy pursuits that even people who are the indoors-kind can also enjoy. Get out and about and make the most of what Mother Nature is offering.