Urgent Statement to the Investigative Commission on Measures for the Control of Cannabis and OtherDrugs of the Ministry of Health, Labour and Welfare
January 31st, 2021
Hokkaido Industrial Hemp Association

The Hokkaido Industrial Hemp Association (HIHA), which engages in public awareness activities concerningindustrial hemp (see note below) in Hokkaido, is compelled to express its serious concerns in response to the noticeissued on the establishment of the Ministry of Health, Labour and Welfare’s Investigative Commission on Measures
for the Control of Cannabis and Other Drugs. We present our assertions in this urgent statement.
According to the guidelines for the meeting of the investigative commission, the commission’s goals will focus
mainly on discussion of drug-related laws including the Cannabis Control Act and the state of drug control measures;
reporting indicates that consideration will be given to criminalization of usage. Such discussions could spread themistaken impression among Japanese citizens that the cannabis plant is a dangerous drug and foster bias against it,even though it is a valuable crop with traditional and cultural significance that has been used in Japan since the Jomon
period.
The Cannabis Control Act is a profoundly unreasonable law that restricts all cannabis regardless of the quantity oreven presence of THC (Tetrahydrocannabinol, the active ingredient in marijuana, the chemical synthetic substanceof which are designated as an illegal drug in Japan), and even prohibits the cultivation of hemp from overseas (seenote below) containing none of this substance. First, concerning the Cannabis Control Act and problems with its
application, we would like to recommend the development of a more reasonable law formulated based upon
discussion that is made public to the citizens of Japan and upon scientific knowledge.
Cannabis is an immensely varied genus of plants that ranges from varieties cultivated for drug use, which havehigh concentrations of THC, to varieties cultivated for use as a natural fiber, which contain vanishingly small tracesof THC. The European Union defines as industrial hemp (see note below) that which contains less than 0.2% THC,
while Canada, the US, and China specify varieties containing 0.3% THC or less. Under these nations’ regulations,registered varieties may be cultivated by anyone.
In these countries, hemp stems, leaves, flowers, and seeds are used as raw materials for the manufacture and saleof a wide variety of environmentally-friendly and healthy products, including clothing, food, cosmetics, building
materials, automotive interior finishing materials, animal fodder, livestock bedding, Chinese traditional medicine,
CBD oil, and pharmaceuticals. The markets for such goods continue to expand. This hemp industry has drawn interest
worldwide as a new agribusiness suited for a sustainable society (References 3, 5).
In Hokkaido, the Agriculture Administration Division of the prefectural government became an executive officeand established an expert commission on the feasibility of industrial hemp in Hokkaido (chairman: Dr. HirokazuMatsui, a professor emeritus of Hokkaido University) in 2013. Between 2014 and 2019, the commission exploredthe feasibility of hemp as an agricultural product, by means such as launching experimental cultivation in the public1

and private sector. As a result, hemp was recognized as a useful dry-field crop for Hokkaido agriculture; yet it wasobserved that there were many barriers to popularization under the current Cannabis Control Act (Reference 1). Inaddition, in December of 2017, the Hokkaido Prefectural Assembly unanimously approved a “Request for Required
Environmental Improvements for the Industrialization of Hemp” and submitted it to the Cabinet and the Diet
(Reference 2).
As we can see, the Cannabis Control Act is a major obstacle in the popularization of hemp. Enacted in 1948, theCannabis Control Act substantially prohibits the cultivation of cannabis plants; the flowers, leaves, and products
thereof in particular are illegal, and mere possession of them is severely punished. Products manufactured in countries
where use of the leaves and flowers is legal are also prohibited within Japan and cannot be imported. Furthermore,while seeds, plant stems, and the products thereof are legal, it is illegal to import seeds capable of germination withouta clear legal basis, even though seeds are essentially legal, and so not even trial cultivation can be done of outstanding
foreign varieties of hemp. In comparison with the legal systems of other countries such as the US, where thelegalization of medical and even recreational cannabis has gained traction, we cannot help but describe Japan’sCannabis Control Act as considerably outdated (Reference 4).
As we have seen, it is clear that the current Cannabis Control Act is responsible for hampering cultivation,processing, import, and experimental research on industrial hemp in this country. In order to develop a hemp industry
on par with those overseas and protect national interests concerning industrial hemp, this country must revise theCannabis Control Act and other related laws as soon as possible, position the hemp industry appropriately within thelegal system, and strike a balance between the control of drugs and the encouragement of industry.
Below are the opinions and requests of this Association concerning the commission’s review and current
regulations on cannabis. We ask that the chairman and members of the commission conduct an impartial discussionof these points.

1) Proceedings of the Commission① Based on the guidelines for the commission set on January 13th, documents for the first review session, andreporting in the media, we have grave concerns about how the commission is to be held. We wish to indicate andmake requests as follows.
② In this investigation, a discussion should be conducted that is available to the public. In doing so, thecommission’s membership should include not only pharmaceutical and legal experts but also experts in other relevant
fields such as medicine, agriculture, and the social sciences. At the same time, a broad range of opinions should beheard from foreign and domestic operators and others connected to the hemp industry (including cultivation,processing, logistics, and sales) as well as from general consumers and health care patients.
③ Although no members of the commission have been announced apart from the chairman, we hope that thecommission’s membership and records of proceedings will be made fully public so that a scientific and democratic
discussion of the matter may be heard by all citizens.

22) Definitions of cannabis④ There is no reference to industrial hemp with a low concentration of THC or indication that any review willtake place of the definition of cannabis under Article 1 of the Cannabis Control Act in the guidelines for thecommission.
⑤ The current Act essentially prohibits the cultivation of cannabis plants belonging to the variety Cannabis sativa
L., regardless of their concentration of THC. This law should be changed so that instead of prohibiting all cannabis
plants in the same way, it classifies varieties according to the purpose for their cultivation and their THC content andgives appropriate regulations for each classification of plant.
⑥ The current Act differentiates between parts of the plant, with flowers and leaves prohibited while stems andseeds are legal. However, it is unreasonable to prohibit the use of flowers or leaves not containing THC, and thiselement of the law should be abolished.

3) Industrial hemp
⑦ Cannabis plants containing less than a 0.3% concentration of THC should be defined as “industrial hemp”
under Article 1 of the Cannabis Control Act and differentiated from other cannabis plants containing a 0.3%
concentration or greater of THC. Industrial hemp should be treated by the law as an ordinary agricultural product.
⑧ We agree with the existing licensing system by which prefectural governors permit cultivation. However, theexamination standards for licensing should be clarified and licenses should be obtainable by anyone who can fulfill
a defined set of requirements. The national government should refrain from interference in the licensing proceduresof prefectural governors.
⑨ Legal regulations concerning industrial hemp should be the jurisdiction of the Ministry of Agriculture, Forestryand Fisheries, and the Ministry should implement measures promoting industrial hemp as a national responsibility as
well as engage in research on the development of hemp varieties, cultivation methods, and usages for hemp.
⑩ Trade Control Orders and other regulations should be revised to permit the import of seeds for superior hemp
varieties from overseas. Hemp seeds for cultivation should be added to official notices on importation and should beexempted from heat treatment.

4) Medical cannabis and recreational cannabis⑪ This Association recognizes that this commission will hold discussions related to medical cannabis and thestate of drug countermeasures. The preparation of laws concerning medical cannabis, which is of particularly urgency,
should be accelerated.
⑫ This Association desires the commission to be an opportunity for holding a democratic debate concerning
medical and recreational cannabis that touches on humanitarian considerations, scientific expertise, and international
shifts in attitude as well as a chance to foster understanding.
⑬ This Association opposes excessive regulatory measures and revisions to laws concerning medical andrecreational cannabis that would hinder the promotion of industrial hemp.
3Note) In this document, the term “industrial hemp” refers to cannabis plants with a low concentration of THC, including Japanese
hemp. We may refer to it as “hemp for industrial purposes” or simply “hemp.”

References
1. “Report on the Feasibility of Industrial Hemp as a Crop in Hokkaido” Hokkaido Industrial Hemp Feasibility
Commission, March 2019
2. “Request for Required Environmental Improvements for the Industrialization of Hemp” Request of the Hokkaido
Prefectural Assembly, December 2017
3. Issues 1 - 38 of “Facts about Industrial Hemp Around the World” Agricultural Operator Yoshiyuki Akahoshi, January
2018 - February 2021
4. Request for Regulatory Reform for Expansion of Domestic Hemp Production, Agricultural Operator Harumi Kikuchi,
December 2020
5. Report on Overseas Observations of the Hokkaido Industrial Hemp Association (Hokkaido Hempnet)
Report on the 10th International Conference of the European Industrial Hemp Association (EIHA), June 2013
Report on the 12th International Conference of the European Industrial Hemp Association (EIHA), June 2015
Report on 2015 Observational Tour of the Hemp Industry in France, September 2015
Report on 2016 Observational Tour of the Hemp Industry in Holland and Germany, June 2016
Report on the Japan and France International Exchange Symposium on Hemp 2017, October 2017
Report on the 15th International Conference of the European Industrial Hemp Association (EIHA), July 2018
Report on ASACON2019 - International Conference on Eco-Friendly and Healthy Industrial Hemp, June 2020
Report on the 17th International Conference of the European Industrial Hemp Association (EIHA), July 2020

Contact Us
17-chome-3-23 Nagayama 7-Jo Asahikawa, Hokkaido, JAPAN 079-8417
Hokkaido Industrial Hemp Association, Representative Director Dr. Harumi Kikuchi
E-mail: info@hiha.jp
Official Name: General Incorporated Association Hokkaido Industrial Hemp Association (Abbreviation:Hokkaido Industrial Hemp Association)
English Name: Hokkaido Industrial Hemp Association (Abbreviation: HIHA)
Homepage: https://hokkaido-hemp.net/index.html
Established: February 29th, 2012
Incorporated: August 18th, 2014
Purpose: To widely promote and deepen understanding of the usefulness of industrial hemp among theJapanese public as well as found a national hemp industry based on the cultivation and utilization as araw material of 20,000 hectares of hemp as a primary crop in Hokkaido.

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