Imagine a world where, before legislative enactment, Congress considered every possible factual scenario, detailed every possible legal nuance, and left no practical ambiguity to interpretive chance. Unfortunately, this imaginary world is just that—imaginary. And the Agricultural Improvement Act of 2018, or more commonly referred to as the “2018 Farm Bill,” is no exception.

On Dec. 20, 2018, President Trump signed into law the 2018 Farm Bill, which became effective on Jan. 1, 2019. Among other things, the 2018 Farm Bill removed hemp from the Controlled Substances Act, and amended certain federal laws relating to the production and marketing of hemp, as well as derivatives of the plant, including cannabidiol, or CBD. While most of these amendments involve the production of hemp, certain amendments implicate the sale of hemp and hemp-derived products.

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