La nuova Direttiva di Salvini sui Cannabis Shop

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Oggi commentiamo la nuova direttiva di Salvini sui Cannabis Shop , visto infatti il grandissimo clamore suscitato dalle Sue ultime dichiarazioni.

Il Ministro Salvini, infatti, ha proclamato in pompa magna l'intenzione di chiudere tutti i Cannabis Shop.

Per far ciò, afferma di aver emanato una Direttiva ad hoc, che dunque oggi andremo a commentare.

Vi è da dire però che di altro non si tratta se non dei soliti proclami a fini propagandistici.

Tali proclami peraltro denotano, oltre che una scarsa conoscenza in materia da parte del Ministro, una scarsa comprensione del fenomeno "Canapa Industriale" e del sistema giuridico.

Appare però illogico e autoritario, a parer mio, che un Ministro dello Stato possa permettersi di mettere alla gogna un settore economico sorto in forza di legge ed in continua crescita.

La stessa Lega di Salvini, peraltro, ha a suo tempo approvato la L. 242/2016.

Cominciamo innanzitutto con il precisare che nessuna Direttiva Ministeriale può, in alcun modo, scavalcare la normativa statale, in questo caso, l'ormai famosa L. 242/2016.

Si tratta, semmai, di una serie di indicazioni operative date alle Forze dell'Ordine.

In ogni caso, ciò che conta è il contenuto della direttiva.

Come ben si poteva immaginare, la direttiva n. 11013/110 (4) del 9 Maggio 2019 del Ministero dell'interno, nulla dispone riguardo alla chiusura dei "Cannabis Shop".

Al contrario, il contenuto denota una completa ignoranza in materia.

Denota, inoltre, un disinteresse verso la normativa statale, le Direttive di altri Ministeri competenti e le interpretazioni date in sede giudiziaria.

Le premesse della Circolare

La premessa della nuova Direttiva di Salvini sui Cannabis shop afferma che "tra le finalità della coltivazione della canapa industriale non è compresa la produzione e la vendita al pubblico delle infiorescenze".

Ciò, "in quanto potenzialmente destinate al consumo personale, in quantità significative da un punto di vista psicotropo e stupefacente, attraverso il fumo o analoga modalità di assunzione".

Tale affermazione è fuorviante e, peraltro, falsa.

Come infatti detto nei precedenti articoli, il Ministero della Salute, con Circolare n. 5059 del 23 Maggio 2018 ha chiaramente affermato la liceità della vendita delle infiorescenze, che rientrano nella categoria delle coltivazioni destinate al florovivaismo.

Inoltre, come si è visto nei precedenti articoli, la legalità della commercializzazione deriva dalla normativa europea che, all'art. 17 della Direttiva 2002/53/CE esplicita che non esiste alcuna restrizione di commercializzazione per i materiali di moltiplicazione.

Il Ministro, così, utilizza faziosamente l'ormai noto parere del Consiglio Superiore della Sanità che ha ritenuto non si possa valutare l'eventuale pericolosità dei prodotti a base di CBD in quanto contengono anche THC.

La Corte di Cassazione tra l'altro ha già smentito tale parere, giustamente, valutandolo come mere indicazioni prive di forza giuridica, indicazioni peraltro fuori da ogni logica scentifica.

Il Ministro ha poi completamente ignorato (non si sa se volutamente) le decisioni giudiziarie e le interpretazioni della Corte di Cassazione, già commentate nei precedenti articoli.

Invece, dalla più favorevole a quelle più restrittive, al contrario di quanto affermato dalla Circolare, hanno sempre dato atto della legittimità della commercializzazione anche delle infiorescenze.

Il contenuto della Direttiva

Viste le premesse, dunque, il Ministro non ha aggiunto in realtà nulla di nuovo (cosa che, peraltro, neppure avrebbe potuto fare).

Ha semplicemente consigliato alle Forze dell'Ordine ed alle Amministrazioni comunali di disporre "una puntuale ricognizione di tutti gli esercizi e le rivendite presenti sul territorio".

"Nell’esecuzione di siffatto monitoraggio, una cura particolare dovrà riguardare la verifica del possesso delle certificazioni su igiene, agibilità, impiantistica, urbanistica e sicurezza, richieste dalla legge per poter operare.

"Un altro aspetto da prendere in esame è la localizzazione degli esercizi, con riferimento alla presenza nelle vicinanze di luoghi sensibili quanto al rischio di consumo delle sostanze".

Gli esiti di tale attività di mera ricognizione verranno valutati da un Comitato che dovrebbe predisporre un programma di prevenzione dei comportamenti vietati, soprattutto "se diretti verso la categoria più vulnerabile degli adolescenti".

Conclusioni

Dunque, nella sostanza, se la Nuova Direttiva di Salvini sui Cannabis Shop verrà applicata, i negozi dovranno subire:

  • un controllo atto alla verifica delle certificazioni di legge che, però, hanno sicuramente ottenuto, al fine di presentare la SCIA per l'apertura dell'attività;
  • un controllo atto alla verifica dei prodotti venduti ma, se derivano da sementi certificate ed a norma di legge e vengono venduti solo a maggiorenni, i negozi non commettono alcuna violazione.

Quanto invece alla vicinanza a luoghi sensibili, la Direttiva afferma semplicemente che "in relazione alle possibili nuove aperture di simili esercizi commerciali", le Amministrazioni dovrebbero prevedere "una distanza minima di almeno cinquecento metri dai luoghi considerati a maggior rischio".

Dunque, nessun provvedimento di chiusura per le attività già aperte anche se in luoghi definiti sensibili.

Eventuali provvedimenti di chiusura potranno essere impugnati in quanto illegittimi e viziati da eccesso di potere.

Inoltre, sarà possibile agire anche per il relativo risarcimento del danno.

Nulla cambia rispetto alle problematiche già in essere, ossia quelle affrontate dai Giudici di Legittimità.

Il problema resta pertanto la commerciabilità, o meno, delle infiorescenze ed il contenuto massimo di THC ammissibile che, si auspica, verranno risolte dalla Corte di Cassazione a Sezioni Unite il prossimo 30 Maggio.

Come al solito, dunque, il Ministro Salvini fa il forte coi deboli e rimane sempre debole con i forti, mettendo inutilmente alla gogna un intero settore economico senza alcuna ragione se non quella, appunto, propagandistica.

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