The rise of retail shops and online platforms providing hexahydrocannabinol (HHC) and other semi-synthetic cannabinoid products.
ARUC STATEMENT
8 January

The Authority for the Responsible Use of Cannabis (ARUC) has noticed with great concern that semi-synthetic cannabinoid products, called hexahydrocannabinol (HHC), HXC or THC-Mix, are available in Malta, with various products such as flowers, hashish, high potency extracts, and food items such as gummies sold openly in various shops and via food delivery couriers. The European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) explains that in late 2021, a new semi-synthetic cannabinoid called hexahydrocannabinol (HHC) emerged on the drug market in the United States (US). HHC is synthesised from cannabidiol (CBD), which in turn is extracted from low-THC cannabis (hemp). HHC is sold openly as a replacement for cannabis and THC (Tetrahydrocannabinol) products, and reports indicate that when consumed in high doses, it exhibits psychoactive effects similar to THC.HHC is not specifically controlled under the international drug control system, and it is also mostly not controlled in most EU Member States.

The Authority emphasises that these products are not regulated under ACT No. LXVI of 2021 and are not found naturally in the cannabis plant (Phyto-cannabinoids)1.

The EMCDDA highlights that by 31 March 2023, it had received reports through the EU Early Warning System on new psychoactive substances (EWS) that HHC had been identified in a range of products in 20 European Union (EU) Member States and Norway. Products include low-THC cannabis (hemp) flower and resin onto which HHC has been sprayed or mixed with HHC, vape products and edibles.

Since the production of HHC does not necessarily comply with ‘Good Manufacturing Practices’, contaminations either with extraction residues or synthetic by-products could pose unforeseen risks. In addition, traces of heavy metals originating from the catalyst used for the hydrogenation might also be present2.

In the coming weeks, the ARUC will be setting up an expert multi-disciplinary Consultative Committee, including dialogue with other EU countries experiencing a similar phenomenon, to better discuss challenges and solutions linked with emerging semi-synthetic cannabinoid products.

In view of the unregulated nature of these new psychoactive substances and the absence of studies on the health effects of HHC, the ARUC advises the public to be wary of synthetic and semi-synthetic low THC products and to recognise the unknown and potentially heightened health risks when consuming semi-synthetic products such as HHC.

1 The most abundant naturally occurring Phyto-cannabinoids in the cannabis plant are THC- ∆9-tetrahydrocannabinol and CBD- Cannabidiol. As established by the WHO and the ECJ ruling, Cannabidiol (CBD) based products, in raw or manufactured form, with a lower THC content than 0.2% should not be considered as falling under the provisions of the UN Drug Control Conventions and therefore no longer considered as a narcotic.

2 Data on the metabolism of HHC in animals are scarce and inadequate. The EMCDDA underlines that the human pharmacology of HHC has not been studied, and (immuno)analytical methods for the rapid and unambiguous detection of HHC or its metabolites in urine are lacking.

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