Page 110 - Daggabay Magazine Issue 9

Fields of Green for ALL • Collectively Reforming South African Cannabis Laws
Similar to co-operatives, Cannabis Hubs are the
core of the commercial pillar of the regulation
model. Hubs are local, decentralised and
democratic/horizontal enforcement platforms
that take care of quality control, pricing, crop
certification, tax collection, anonymous auctions,
warehousing, and management of by-products.
Hubs implement policies on the ground by
offering services required by the regulations.
Hubs are overseen by the Office of the Cannabis
OmBUDsman with inputs from the relevant
7
government departments / regulatory authorities.
At this stage it is unclear which government
departments would oversee what, but a good
example would be Industrial Cannabis Hubs
overseen by the Department of Agriculture.
The Cannabis OmBUDsman would need to
work closely with the relevant government
departments in order to look after the interests
of consumers, cultivators and traders.
Hubs are organised in order to provide services
to Cannabis operations of the “Commercial Pillar”
(standard operations and Kasinomics), but must
implement specific and simplified processes
for Kasinomics in order to attract the current
non-regulated market. Provision for ongoing
knowledge sharing within the Hub should also be
a significant attraction for industry participants to
strive for optimum performance.
All Hubs can service both growers and seed-
to-sale operations, either buying the crop and
paying the growers (with tax/VAT deduction when
applicable) for the former, or analysing, certifying
the crop, and collecting tax/VAT when applicable,
and giving back the products, for the latter.
The current pricing structure within the
unregulated market is an adequate starting point
for a legal market (See Section 2.3.2.2 on Trade).
It is what Cannabis consumers are used to and
no attempt should be made to regulate pricing
beyond what the market dictates. It goes without
question that prices will come down due to a glut
in the market and consumers being permitted
to cultivate for personal use; however this could
be compensated for by the application of VAT.
There will always be a wide range of Cannabis
consumers in South Africa, as the current price
range demonstrates.
66 CANNABIS IN SOUTH AFRICA • THE PEOPLE’S PLANT • A Full-Spectrum Manifesto For Policy Reform
Two types of Hubs should be regulated:
Type a: Open Hubs.
Open Hubs are the generic and likely the most
common type of Hubs. They are accessible to any
operation located in the area covered by the Hub.
Type B: legacy Hubs.
Legacy Hubs provide for specific admission
rules based on geographical and/or traditional
knowledge-related standard-compliance criteria.
This allows Legacy Hubs to provide services
for citizens representing very specific types of
cultivation, processing, or other activities related
to Cannabis. Legacy Hubs can also apply for
specific legal protections.
All Hubs provide 6 mandatory services:
1. Registering affiliates;
2. Quality control and basic product analysis;
3. Establishing product-labelling protocols,
traceability and basic required indications of
source/ origin in labels;
4. Basic training and education;
5. Tax/VAT collection;
6. Transaction of trade between Hubs;
All Hubs can choose to provide optional services,
according to their needs:
7. Advanced product analysis;
8. Advanced training;
9. Standard packaging;
10. Anonymous auctions;
11. Warehousing;
12. Non-psychoactive wastes and by-products
recycling;
13. Register of Collective marks and related IP
protections (anti-misleading source);
14. Collective and equitable share benefits from
natural and genetic resources (anti-biopiracy
& abusive bioprospecting);
15. Collective organisation of cultivation (Farmers
Cooperative);
16. Community-based restrictions to access.
Legacy Hubs may decide to become enforcement
platforms for collective rights linked to local
traditional knowledge, traditional cultural