Hello! Welcome to our first blog post. Before we get into the interesting details of all things CBG and hemp, we thought we’d take the opportunity in this first post to give our customers and followers a general overview of the process we went through to become licensed hemp growers and manufacturers of hemp products in Iowa. We’ll also explain some of the limitations we have when it comes to growing, manufacturing, marketing, and selling our products.
Riveting stuff – we know!
First, you might be wondering, ‘Why Iowa?’. I (Megan) grew up in Oxford, Iowa. Scott and I met in California while working in the cannabis industry, and in 2018, we moved back to be closer to family. We knew we wanted to continue using the knowledge we gained growing in California, and when hemp was legalized in Iowa, we knew we found our next venture.
Getting Our Industrial Hemp Growing License
Many people have asked us if it was difficult to become a licensed hemp growers in Iowa and if there was a lot of red tape involved. The answer: yes and no. For us, there were a few more hoops we had to jump through compared to someone who simply wants to sell hemp products because we are growing, manufacturing, and selling our own line of organic hemp products, but that’s alright by us – we think that’s what makes us unique!
To obtain an Industrial Hemp Growing License from the Iowa Department of Agriculture and Land Stewardship (IDALS), first, we had to apply. Some of the things we were asked to provide on the application included: name, date of birth, address, fingerprints, the exact GPS location of our hemp plot, what we planned to do with our hemp (e.g., fiber, seed, cannabinoids, etc.), and what cultivars, or plant variety, we’d be growing. We had to file our acreage size with the Farm Service Agency (FSA), apply for an FSA Farm ID number, and of course, pay the state. Each year we pay $1500 to IDALS to grow up to 80 acres of hemp.
Regular Reporting
Throughout the growing season, there is documentation we must submit to keep IDALS informed. All hemp farmers in Iowa need to file a “planting report” no later than 30 days after planting. Then in the fall, a “harvest report” is required to be submitted no later than 2 weeks after harvest.
Before we can harvest, we must notify IDALS one week in advance, so they can send state officials to sample the tops from ten different plants – randomly selected throughout our hemp field. They do this to test the average THC (the psychoactive cannabinoid found in cannabis) reading and ensure it is under 0.3%, which is the legal amount.
If we pass, the state gives us two weeks to complete our harvest. If we do not finish harvesting within that timeframe, then we can request an extension. The state returns and runs the same test on the remaining hemp plants to confirm that the crop is still below 0.3% THC, and we get another two weeks to continue harvest. But if at any point our crop ever comes back above 0.3% THC, then we are required to destroy it.
Consumable Hemp Manufacturing License
To manufacture consumable hemp products, we needed a separate license from the Iowa Department of Inspections & Appeals (DIA), called a Consumable Hemp Manufacturing License. It costs $475 each year. The state allows us to manufacture our topical body care product line from the kitchen in our home, but we are required to manufacture our edible product line in a compliant commercial kitchen.
We have been renting a great kitchen run by wonderful people at the CommUnity Free Lunch Program kitchen that regularly serves free lunch to people. The state completed a successful inspection of the commercial kitchen three months after they granted us our license.
In addition to the license associated with the commercial kitchen, we needed one for our storage facility at the farm. So, we have another (two total) consumable hemp manufacturing licenses.
Testing and COAs
Our consumable hemp products must be submitted for a microbiology test, a mycotoxin test, and a moisture and water activity test. For each batch we produce, we are also required to get a full panel COA, or Certificate of Analysis, for each product. COAs are issued by labs with assurance that confirms the regulated product meets its product specification. In other words, it verifies that the product matches the label. It is a requirement for cannabis-derived products.
There is no rule on how big each of our batches can be, but if a batch gets recalled, every product from that batch must be pulled off the shelves. To help ensure this doesn’t happen, we use a lab in Florida called ACS because Florida has the strictest guidelines in the country when it comes to cannabis testing.
Food Processing Plant License
In addition to the Consumable Hemp Manufacturing License, we also needed to obtain a Food Processing Plant License from the DIA to manufacture hemp products in the state of Iowa. This license costs $475 the first year, as well, but the price can decrease significantly in subsequent years, based on profits from the previous year.
This license is also required for our storage facility location, so just like the Consumable Hemp Manufacturing License, we have two Food Processing Plant Licenses.
This means that we have a total of five licenses needed to operate: 1 Industrial Hemp Growing License, 2 Consumable Hemp Manufacturing Licenses, and 2 Food Processing Plan Licenses. If, in the future, we get our own commercial kitchen installed inside our building, then we could knock our licenses down to just three per year!
Additional Classes & Certifications
Our state inspector suggested some other classes and certifications that would help us ensure that we were doing our best to protect consumers. The first class we (Megan) took, was the Basic Food Handler’s Certificate course through Always Food Safe, which taught sanitization guidelines, safe food temperatures, and cooking times needed to kill pathogens, ensuring food served is deemed safe.
Following this course, Megan took the Food Safety Preventative Controls Alliance (FSPCA) course, which taught food manufacturing safety and how to create a hazard analysis for our manufacturing facility. This course is required by the FDA for manufacturers. Technically, we didn’t have to take it because we are considered a small farm, but we wanted to do the best we could to get off on the right foot.
Megan has also completed an online course through the Iowa State Extension office on Food Safety Sanitation and Preparation and several other online courses related to good manufacturing practices.
It has been no small task, but everyone that we’ve worked with through IDALS and the Iowa Department of Inspections & Appeals has been very helpful and patient with us as we got on our feet.
Things We Can’t Do as Hemp Farmers in Iowa
The hemp plant is a bioaccumulator, which means it pulls heavy metals, toxins, and chemicals from the ground as it is growing and holds on to them within the plant. For this reason, hemp farmers are discouraged from using chemicals in their growing practice. There is a list on the DIA website of toxicant limits that our products cannot exceed to be considered safe for commerce. Fortunately, we grow organically so we don't worry about these tests coming back too high.
Things We Can’t Do as Hemp Manufacturers and Retailers in Iowa
The most difficult restriction that we experience as hemp farmers and manufacturers in the state of Iowa, is that we are unable to market our products in a way that directly tells our customers what our products may be helpful for. Despite the science supporting the benefits of using hemp products and CBG, until the FDA officially recognizes it as having medicinal value, we are unable to make any claims on our website or marketing materials that states that our products might help someone in some way. Because of this, we are hoping that blogging isn’t extremely difficult because we will have to dance around what we really want to convey. But we will do our best!
There is no legal age restriction on selling hemp products to humans in the state of Iowa, but we are not able to market our products to pets just yet. We were told by IDALS last fall that the state was about 1 year into a 2-year study on hemp for livestock animals and when they completed that, they would study its effects on house pets for another 2 years before making it legal to sell hemp products to pets in Iowa.
We also are restricted from selling Delta 8 THC products. We are totally fine with that. Although we believe that every cannabinoid counts, Delta 8 THC products on the market are synthetically derived. That’s not anything that our farm would dabble with anyway. The cannabis plant can produce Delta 8 THC naturally, but not in the amounts that you are seeing illegally on the shelves around the state.
More to Come
Deciding to become hemp farmers in the state of Iowa has been an exciting adventure. Although it seems like there is a never-ending list of things to do to get the business up and running and to keep it there, we are enjoying the experience of producing and manufacturing hemp products in the state of Iowa. Interacting with everyone at markets and letting people sample our products has been a fun and truly rewarding experience.
We hope that you have enjoyed our first blog and that you will come back to visit us again soon!
Until next time, may the four winds blow you safely home.