Late last year after the release of the Interim Final Rule (IFR) from the USDA, it became clear that all states would not embrace the plan for the 2020 season.  On top of that, State’s Departments of Agriculture voiced serious concern over some of the requirements outlined in

the IFR, namely the requirements around THC testing for producers.  State ag departments have pushed back against impractical sampling requirements, that compel states to test 100% of the crop.  Many states tested less than 50% of the 2019 hemp crop, some much less.  This only adds to the unfunded mandate for states to conform to federal hemp policy.  The 15-day harvest window is also contentious.  State personnel felt the burden of sampling crops in past years, compressing the timeline only exacerbates the stress on their agencies.

One of the most pressing issues for…