[co-author: Jack Crain]
Key Summary
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THCA flower is hemp that looks and functions like marijuana but falls into a legal gray area under the 2018 Farm Bill and an increasingly broad patchwork of state regulation.
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State rules vary widely, creating meaningful challenges to compliance for multi-state hemp companies
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How THCA will be regulated in the future is uncertain, as upcoming federal action, such as the 2025 Farm Bill, could reshape the entire market.
THCA flower has rapidly become one of the more controversial products in the hemp industry. Marketed as federally legal hemp, THCA flower looks, smells, and is consumed just like cannabis. Yet, the specifics of its legal status hinge on technical definitions in the 2018 Farm Bill and the real-world complexities of testing. This FAQ provides clear answers to the most common questions about THCA flower, from how it’s defined and tested to what federal and state policy changes could mean for its future.
Section 1 – Basics
What is THCA Flower?
THCA flower, or THCA hemp flower, is flower sold as federally legal hemp. It is the same species, Cannabis sativa L., as cannabis. There is some debate about whether there is only one cannabis species or three species, but this is beyond the scope of this article, as the authors are not scientists. And hemp flower is used exactly like cannabis flower – it is smoked to obtain a psychoactive effect. The difference between THCA flower and cannabis flower is purely legal.
What is the difference between THC and THCA?
To understand the legal status of THCA flower, you need to understand the difference between tetrahydrocannabinol (THC) and tetrahydrocannabinolic acid (THCA). THC, which is the primary psychoactive molecule in cannabis and is responsible for the plant’s intoxicating effects, does not exist in large amounts in cannabis. Instead, the precursor molecule to THC (THCA) is present. Only upon heating, also known as decarboxylation, does the THCA convert into THC.
For flower, whether cannabis or hemp, the final product that is sold to customers will be high in THCA and low in THC. Only when the customer burns the flower to smoke will THC become present in large quantities. However, some natural decarboxylation will take place over time, especially if the flower is exposed to higher temperatures.
THCA can also be found in concentrates depending on the processing method, but a discussion of concentrates is beyond the scope of this article. For edibles, none of this is relevant as the products will be decarboxylated as part of the manufacturing process.
What does the law say about the difference between THC and THCA?
The key difference between hemp and cannabis (or marihuana as spelled in the Controlled Substances Act – the law which makes the plant illegal under federal law) is legal. It is set forth in the federal definition.
Under federal law, hemp is defined as:
“The term "hemp" means the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis.”
The key point to notice is that this definition does not refer to total tetrahydrocannabinol concentration. This seemingly indicates that all cannabis flower could potentially pass muster as THCA flower, as the flower would likely contain very little THC and only THCA, and is, therefore, federally legal. However, this is only the case if the hemp first passes the test administered prior to harvest.
What is the size of the THCA market?
The actual size of the THCA flower market is difficult to measure. Sales occur primarily through direct-to-consumer channels and smoke shops, which cannabis industry data providers do not track. Nor is there investment banking coverage of the sector. Some state-level data exists, but it is unclear whether these figures capture the true scale of sales. What is certain is that THCA hemp flower is widely available, with many businesses advertising online and offering to ship directly to consumers.
Section 2 – Testing & Compliance
What testing is required for THCA?
Under the 2018 Farm Bill, hemp may be grown pursuant to either the federal plan set out by the United States Department of Agriculture (USDA) or by a plan adopted by the applicable state or tribe and approved by the USDA. The USDA publishes a list of which states and tribes have adopted their own plans, and which default to using the federal plan. All state plans require testing, but certain exemptions do exist.
Per the USDA, “[h]emp grown under a USDA, State, or Tribal Hemp production plan is subject to sampling and compliance testing for THC concentration. Certain producers, along with research institutions and facilities growing immature plants, may be exempt from testing requirements depending on the applicable State, Tribal, or USDA regulations.”
Under the federal plan, hemp must be tested for total THC within 30 days prior to harvest, meaning the THCA is counted according to the following formula: Total THC = (0.877 x THCA) + THC. If the hemp fails this test, it is considered illegal “hot hemp.” Although it has not always been the case, all states with USDA-approved hemp programs also require preharvest testing for total THCA.
However, once it passes this test, the 2018 Farm Bill does not mandate additional testing. The only federal guardrail remains the general requirement to stay under the delta-9 THC concentration of not more than 0.3 percent on a dry weight basis. Note, as explored below, some states have separate post-harvest testing requirements.
Are THCA testing requirements realistic?
Questions have been raised in the industry about how consistently hemp testing is conducted. Critics sometimes point to the fact that popular cannabis strains are sold as THCA flower, arguing that such strains are naturally high in THCA and would be difficult to keep compliant with preharvest total THC testing requirements.
While speculation exists, there is little evidence to suggest widespread misconduct at certified testing labs. State programs, such as Colorado's, require that hemp destined for commerce be tested at approved laboratories that must comply with state health and safety standards in order to retain certification. These laboratories operate under established compliance protocols designed to ensure reliability.
What is clear, however, is that hemp cultivators and THCA flower producers face a lack of uniform oversight and standards across jurisdictions. Testing equations and procedures, particularly beyond the calculation for total THC, can vary from lab to lab and state to state. These variations can create inconsistencies in reported results, which in turn can affect how hemp products are regulated, labeled, and marketed. Operators in this space need to be aware of these inconsistencies and plan accordingly.
What is a Certificate of Analysis (COA)?
Certificates of Analysis, or COAs, are the key documents used to verify the contents of hemp products. These reports, issued by third-party laboratories, outline cannabinoid levels and may also include information on pesticides, heavy metals, and other contaminants. For the hemp industry, COAs are essential tools for demonstrating product compliance and safety.
Because hemp remains largely a self-regulating industry, concerns have arisen about the reliability and uniformity of COAs. In response, industry participants have developed safeguards to strengthen confidence in these documents. One of the most effective tools is the use of QR codes that link directly to a laboratory's information management system, which makes it far more difficult to alter results.
Best practices also include reviewing COAs for irregularities, ensuring that test results are recent, and confirming that the document is the original file issued by the lab rather than a copy or scan. Photos and product descriptions, when included, can help confirm that the sample tested matches the product being sold.
These issues are not unique to hemp. Other agricultural sectors have faced similar challenges with inconsistent testing and verification protocols, which were only resolved through the establishment of more standardized federal oversight. Until comparable reforms are made for hemp, cultivators and sellers must remain vigilant in adopting best practices to ensure the integrity of their testing and labeling.
Enterprising growers and lawyers soon realized the absence of a post-harvest total THC standard created an opportunity. If you could grow the right cultivar of hemp and have it pass the pre-harvest test by testing it at the right time, you would now be in possession of what is arguably federally legal THCA hemp and the COA to prove it.
Section 3 – Federal Oversight
How is the U.S. Food and Drug Administration (FDA) involved in THCA regulation?
The 2018 Farm Bill explicitly states that the legislation does not preclude the FDA from issuing additional regulations. Section 297D of Subtitle G – Hemp Production, “Regulations and Guidelines; Effect on Other Law” states how “[t]he Secretary shall promulgate regulations and guidelines to implement this subtitle as expeditiously as practicable… [and] the Secretary shall have sole authority to promulgate Federal regulations and guidelines that relate to the production of hemp”.
However, the FDA never promulgated rules with respect to hemp. That said, the FDA clearly takes the position that intoxicating hemp is not approved for human consumption. This, however, has to do with the Federal Food and Drug and Cosmetics Act, not the Controlled Substances Act, so the legal consequences are significantly less important.
What are the Arguments that THCA Flower is Illegal?
Opponents of THCA flower advance several arguments for why it should not be considered federally legal hemp. These arguments focus only on the federal level and do not address state law restrictions, many of which independently prohibit or limit the sale of THCA flower. What follows are the primary federal arguments raised by critics.
Congressional Intent and Drafting Error
Critics argue that Congress never intended to legalize intoxicating hemp products. The 2018 Farm Bill defines hemp based only on delta-9 THC content, without reference to THCA or other cannabinoids. Senator Mitch McConnell, one of the bill’s key drafters, has since suggested the definition was too broad and has enabled products that were outside the bill’s original intent. This alleged drafting error is now central to federal efforts to narrow the definition of hemp.
Functional Equivalence to Marijuana
THCA converts into delta-9 THC when exposed to heat, meaning THCA flower can deliver intoxicating effects similar to marijuana. Opponents argue that treating THCA flower as hemp elevates technical lab results over real-world use, and that in practice, it is marijuana by another name.
FDA and Safety Concerns
The FDA maintains that intoxicating hemp products, including THCA flower, are not approved for human consumption under the Food, Drug, and Cosmetic Act. Opponents cite this position to argue that THCA flower is unsafe and should not be sold in commerce.
Testing Validity Concerns
As noted above, critics have questioned the validity of both CoAs (which are sometimes alleged to be altered) and the underlying testing results.
Has the IRS weighed in on THCA flower?
Incorrect testing of THCA flower could have significant tax consequences within the realm of 280E. If the testing is incorrect, and the THCA flower’s delta-9 THC concentration is above 0.3 percent on a dry weight basis, it would no longer be classified as federally legal hemp and, instead, would be federally illegal marijuana. Thus, what was a federally legal product indistinguishable from cannabis flower and capable of being sold throughout interstate commerce would be a federally illegal controlled substance subject to the challenges of 280E. This is particularly important from the perspective of the IRS, as the agency continues to enforce its stance that marijuana, as a Schedule I controlled substance, falls within the full scope of Section 280E of the Internal Revenue Code.
Suppose the THCA flower in question is alleged to be the result of erroneous testing with an impermissible delta-9 THC concentration level. In that case, it will instead be classified as federally illegal marijuana, and its producers will be subject to the full force of Section 280E. This would mean owing the IRS a fortune in back taxes from what would be construed as impermissible past federal tax deductions, a substantially higher tax rate, and would further eliminate the previously accessible federal tax breaks for these THCA flower vendors. Purveyors of THCA flower and other intoxicating hemp products must be aware of these potential issues. These businesses should pay special attention to entity selection, governance, and taxation during formation, as well as the strong likelihood of an IRS audit.
Section 4 – Litigation & Courts
Have courts weighed in on THCA hemp flower?
The absence of uniform regulatory standards for THCA flower and other intoxicating hemp products has led to uneven results in the courts. In cases such as Anderson v. Diamondback Investment Group, LLC and Fisher v. Airgas USA, LLC & Airgas, Inc., employees who consumed hemp products they believed to be federally legal nonetheless failed workplace drug tests and lost their jobs. In jurisdictions that prohibit intoxicating hemp products outright, as in State v. Goodsell, courts have sometimes treated the possession of THCA flower as equivalent to possession of illegal cannabis, regardless of whether the material in question actually exceeded the 0.3 percent delta-9 THC threshold.
Questions about insurance coverage have also arisen. In Bogard v. County Mutual Insurance Company, a court considered whether the Controlled Substances Exclusion applied to hemp-related damages. The exclusion was found to apply only if the hemp contained more than 0.3 percent delta-9 THC, which was not the case in that matter.
Disputes have likewise emerged over Certificates of Analysis (COAs). In A Distribution Company LLC & Green Family Farm International, LLC v. Mood Product Group LLC, a court examined allegations that COAs had been improperly altered, underscoring the importance of accurate documentation in a self-regulating industry.
Finally, trademark law has also been tested. In AK Futures LLC v. Boyd Street Distro, LLC, the Ninth Circuit upheld a preliminary injunction in a trademark infringement case involving counterfeit delta-8 THC vape products. The decision turned on the 2018 Farm Bill’s definition of hemp, which measures only delta-9 THC concentrations and not delta-8. That interpretation mirrors the legal reasoning often invoked with THCA flower: because the statutory threshold measures delta-9 THC alone, products containing other cannabinoids in higher concentrations, such as delta-8 or THCA, may still be argued to fall within the definition of hemp.
Taken together, these cases illustrate how the lack of consistent standards has produced a patchwork of judicial outcomes. Even with the federal framework established by the 2018 Farm Bill, state-level variations have created uncertainty that hampers efficient business operations. Looking ahead, potential changes to the Farm Bill may introduce additional complexity, further clouding an already unsettled area of law.
Section 5 – Regulation & Policy Developments
Why is THCA flower controversial?
The major source of controversy stems from the disparity in how the cannabis and hemp industries are regulated. State-licensed cannabis operators face high taxes at both the state and federal levels because of Section 280E of the Internal Revenue Code. Direct-to-consumer sales are prohibited, deliveries are tightly regulated, and state agencies actively monitor and enforce compliance through evolving rules and penalties.
By contrast, THCA flower has not historically been subject to the same degree of taxation or oversight. It is often sold through internet shipments, and in many states, until recently, there were few restrictions on packaging, labeling, testing, or age verification. Texas, for example, did not impose an age requirement on intoxicating hemp purchases until very recently.
This uneven regulatory environment has created stark contrasts. The absence of federal reforms addressing cannabis taxation and financing has placed enormous pressure on the licensed cannabis industry, forcing many businesses to close. At the same time, hemp businesses can sell products that are virtually indistinguishable from cannabis flower while facing far lower compliance costs. Given this dynamic, it is not surprising that state-licensed cannabis operators view THCA hemp—and intoxicating hemp products more broadly—as unfair competition.
How will federal regulation of THCA be different in 2026?
Both the 2025 Farm Bill and the FY 2026 appropriations process pose risks for THCA flower. The draft language already in circulation would explicitly count THCA toward total THC and exclude intoxicating hemp products from the definition of hemp. While Senator Paul succeeded in blocking this language from appropriations, it remains very much in play for the upcoming Farm Bill. If enacted, these changes would eliminate federal protections for THCA flower and allow state prohibitions and restrictions to take full effect.
How will FY 2026 appropriations impact THCA flower?
A number of comments have pointed out that the creation of the intoxicating hemp market generally, inclusive of THCA hemp flower, may have been a drafting error on the part of Congress. Many observers argue that the creation of the intoxicating hemp market, including THCA flower, may have been an unintended consequence of the 2018 Farm Bill. This alleged drafting error has drawn sharp criticism and led to a wave of legislative and regulatory activity at both the state and federal levels aimed at “closing the hemp loophole.”
The FY 2026 appropriations process became another battleground over intoxicating hemp. In mid-2025, the House Appropriations Committee advanced its agricultural spending bill with language modeled on the Miller Amendment. This language would have rewritten the hemp definition to include THCA in total THC calculations and exclude intoxicating hemp products, effectively closing the hemp loophole outside the Farm Bill reauthorization and ending any argument for the legality of THCA flower.
When the Senate took up its version of the appropriations bill, however, that language was removed. Reports indicate that Senator Rand Paul (R-KY), a longtime hemp industry ally, pushed strongly to strip the provision. With the Senate version moving forward without the hemp restrictions, the two chambers will need to reconcile their bills in conference.
As of now, the Miller language is not part of the Senate appropriations package, and the status quo remains intact. Still, the fact that the House advanced the measure (and that it only dropped out after Senate negotiations) shows how close Congress came to enacting significant hemp restrictions through the budget process rather than waiting for the Farm Bill. The ultimate outcome will depend on whether the hemp provisions re-emerge in conference or are left out entirely.
How will the 2025 Farm Bill affect THCA?
The 2025 Farm Bill has not yet been formally introduced in the current Congress. However, draft bills circulated in 2024 previewed the fault lines in the debate and illustrated where Congress may land.
The most prominent of these was the so-called Miller Amendment, sponsored by Rep. Mary Miller (R-IL). That provision would have redefined hemp so narrowly that virtually all intoxicating hemp products, including THCA flower, delta-8, and many full-spectrum hemp extracts, would have been excluded from the federal definition of hemp. If enacted, the amendment would have effectively confined hemp to industrial uses like fiber and grain, as well as a small subset of non-intoxicating cannabinoid products that could stay below the 0.3% delta-9 THC threshold. Rep. Andy Harris (R-MD), a leading critic of intoxicating hemp, strongly supported this approach.
The Senate draft, by contrast, did not propose eliminating intoxicating hemp products across the board. Instead, it would have amended the hemp definition to include THCA in the total THC calculation. Because THCA flower is naturally high in THCA and readily converts to delta-9 THC when heated, this change would make compliance with the 0.3% threshold effectively impossible. Even though the Senate draft stopped short of eliminating all intoxicating hemp products, it would still have foreclosed the legal argument for THCA flower.
What THCA regulations are occurring at the State level?
Although there has been no definitive federal action on THCA flower or intoxicating hemp more broadly, states have stepped in aggressively. Many have adopted new laws or reinterpreted existing ones in ways that render certain intoxicating hemp products illegal, including THCA flower.
Final Form Product Requirements
A key area of divergence concerns how states regulate final-form hemp products. While every state uses the “total THC” metric to test hemp in the field, not all apply the same standard to finished products. This inconsistency has become central to the availability of THCA flower.
Most THCA flower originates in states that only test hemp in the field, such as Kentucky and Indiana. In these jurisdictions, final products are not required to meet a total THC standard beyond what the 2018 Farm Bill mandates. Kentucky, for example, requires labs to report THCA levels in finished products but does not impose a binding standard beyond the federal “total THC” metric. Indiana similarly limits compliance to the federal definition without additional state-level requirements.
By contrast, some states have taken a stricter approach. Tennessee enacted new rules in late 2024 that apply the total THC standard to final form products, effectively prohibiting the cultivation and manufacture of most THCA flower and other intoxicating hemp products.
These differing approaches highlight the patchwork nature of hemp regulation. In states with limited oversight of final products, THCA flower has flourished. In states imposing more stringent testing requirements, the product has effectively been regulated out of the market.
State-Level Actions in 2025
While the industry waits for potential federal change, there has been no shortage of changes at the state level. 2025 has been an incredibly active legislative season. In addition to legislative changes, we’ve also seen attorney generals act against the unregulated hemp industry.
Arizona Attorney General Kris Mayes, for example, issued a 2024 legal opinion questioning the legality of intoxicating hemp products, followed by a 2025 directive detailing how any business selling THC products must be licensed with the state pursuant to Arizona state law. While Attorney General Mayes was sympathetic towards retailers who may have been selling these intoxicating hemp products pursuant to the hemp loophole included in the 2018 Farm Bill, she was also extraordinarily clear that “federal law does not preempt Arizona’s more stringent state laws”.
According to Attorney General Mayes, Proposition 207—which legalized Arizona’s adult-use marijuana market in 2020 and established the state’s licensing program for marijuana retailers—also applies to businesses selling intoxicating hemp products. These retailers must subsequently be licensed with the state to sell these products and were given an April 24, 2025 deadline to do so. Currently, Attorney General Mayes’ directive is in legal limbo following the Hemp Industry Trade Association of Arizona’s (HITA) successful acquisition of a "Petition for Special Action" from the Arizona Court of Appeals after the denial of its request for a temporary restraining order against the directive in the lower court.
Missouri Attorney General Andrew Bailey has taken a similar approach to Attorney General Mayes by cracking down on the unregulated hemp industry, and specifically within the context of THCA flower. Attorney General Bailey recently sent 18 cease-and-desist letters to several Missouri-based retailers threatening legal action if these retailers failed to stop the sale of THCA flower products. Attorney General Bailey cited health and public well-being concerns for sending the cease-and-desist letters, which explicitly direct retailers to halt the sales of hemp products that contain more than 0.3% THCA on a dry weight basis. Attorney General Bailey, however, neglected first to send the requisite notice of intent as required by Missouri state law, and, like Attorney General Mayes, now has his directive in a similar state of legal limbo. It will be illuminating to see how these and similar cases regarding attorneys general acting against the unregulated intoxicating hemp industry continue to play out in the future.
What impact will state litigation have on THCA?
When the 2018 Farm Bill legalized hemp and its derivatives at the federal level, its language noted that the legislation did not preempt or limit any state law regulating hemp production. However, the 2018 Farm Bill does prohibit states from stopping the transportation of federally legal hemp across state lines. This ambiguity, alongside dormant commerce clause arguments, has fueled ongoing litigation and regulatory uncertainty.
Courts across the country are assessing state efforts to regulate the sale of intoxicating hemp products. Early on, in some states, legal challenges secured preliminary injunctions that temporarily blocked the enforcement of new restrictions. This trend has shifted, and in more recent cases, courts have allowed these regulations to remain in effect during ongoing litigation. See the Appendix below for a list of current cases by state.
For instance, the Fourth Circuit Court of Appeals in Virginia upheld a state law restricting the sale of hemp products with high THC levels, reinforcing the state's right to regulate intoxicating substances for public health reasons. Meanwhile, a Maryland Circuit Court judge granted a preliminary injunction against a state ban on intoxicating hemp products, allowing sales to continue while the case moves through the courts. This ruling is in contrast to California, where industry stakeholders challenged new regulations prohibiting hemp products containing detectable levels of intoxicating cannabinoids, seeking a temporary restraining order to halt enforcement, though no preliminary injunction was issued. These cases underscore the ongoing conflict between state governments, the hemp industry, and the judiciary as lawmakers attempt to regulate an industry evolving faster than existing legislation.
What additional THCA reforms can we expect in the 2025 Legislative Session?
The intoxicating hemp market is larger than just THCA flower and consists of edibles, tinctures, and vapes. State legislatures, in response to this wide-ranging and rapidly expanding market, have and are continuing to implement regulatory reforms to address what has been a predominantly unregulated space. While a few of these state-level reforms are rooted in common-sense regulatory logic, with the goal of bolstering the safety of the manufacturing processes and preventing minors from accessing intoxicating hemp products, many others are overly broad and sweeping.
Texas SB3 is one of these overly broad and sweeping state-level reforms. Spearheaded by Texas Lieutenant Governor Dan Patrick, the bill targets Texas’ hemp industry and specifically any product containing intoxicating cannabinoids. SB3, which would have eliminated the state’s $8 billion+ hemp industry, was subsequently vetoed by Governor Greg Abbott. SB3, and the Texas Senate’s counterpart in SB6, were considered over the course of two Texas state legislative Special Sessions. The second of these Special Sessions adjourned sine die late on the evening of September 3 without any broad ban on intoxicating hemp products. The caveat to this was the passage and September 1 effectuation of Senate Bill 2024, which banned the sale and marketing of all vape products containing cannabinoids.
Tennessee has taken a similar approach to Texas with HB 1376, which bans all products containing THCA and/or synthetic cannabinoids and prohibits direct-to-consumer sales. The bill, which Governor Bill Lee signed on May 21st, transfers Tennessee’s state regulatory control of hemp-derived cannabinoid products from the state’s Agriculture Department to the state’s Alcoholic Beverage Commission (ABC) and will become effective in 2026. The legislation, in addition to curbing access to intoxicating hemp products, delivers a particularly devastating blow to a state that lacks a medicinal cannabis program.
A similar situation arose in California last September when Governor Gavin Newsom proposed emergency regulations to ban the sale of intoxicating hemp products, which the California Office of Administrative Law swiftly approved. Governor Newsom announced in May that there had been a 99.7% compliance rate with these emergency regulations, with California’s robustly developed medicinal and adult-use cannabis markets likely playing a significant role with this exceptional rate of compliance. Just like the above discussion on attorneys general acting against the unregulated intoxicating hemp industry, it will be interesting to see how these and other state-level reforms play out in the future and whether the presence of a state medicinal and/or adult-use cannabis market plays any role in the success or failure of these reforms.
Conclusion
While it may not have been the intent of Congress in 2018, there is a strong argument that THCA hemp flower—so long as it passes the required pre-harvest test—is federally legal under the definition of hemp set forth in the Farm Bill. Whether one views this outcome as a “loophole” or not is beside the point. The law, as written, measures delta-9 THC only, and that remains the governing definition until Congress enacts a new one. Because hemp flower is indistinguishable from cannabis flower, it has become the most visible and controversial symbol of the intoxicating hemp industry, which also encompasses products such as delta-8, delta-10, THC-P, gummies, vapes, and beverages.
The controversy is unlikely to abate soon. The state-regulated cannabis industry, burdened by high taxes and compliance costs, views intoxicating hemp as a direct competitor—substitute goods sold with far fewer restrictions. Hemp beverages are something of an exception, as they compete less directly with state cannabis operators, given the limited role beverages play in dispensary sales.
For THCA flower, however, the boom may already be waning. In the absence of federal reform, states have moved quickly to assert authority, either by passing new laws or by reinterpreting existing ones to restrict or ban sales outright. This state-level momentum suggests the market for THCA flower will remain uncertain and fragmented.
At the same time, many companies are hedging their bets by selling both intoxicating hemp and cannabis products where possible, exploiting the continued federal–state divide. Within that dual strategy, THCA flower is often treated with greater caution, given its visibility and the risk of enforcement.
Until Congress addresses the definition of hemp, expect the controversy to persist. Intoxicating hemp and cannabis will remain in direct competition, and financial pressures on the cannabis industry will only intensify the debate.
Appendix - Status of State Hemp Regulation Litigation
