Powered by a $6.1 billion annual budget and prosecutorial alliance with the Federal Trade Commission (FTC), last month the U.S. Food and Drug Administration (FDA) simultaneously charged three cannabidiol (CBD) companies with violating the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. 301, et seq. (FDA Act) and Federal Trade Commission Act, 15 U.S.C. Sections 41-58 (FTC Act) by placing unapproved and misbranded human drugs and adulterants and unapproved and unsafe animal drugs into interstate commerce; and making false or unsubstantiated health claims.

A wildly popular nutritional supplement and food additive, oil-based hemp derived products like CBD racked up $1.1 billion in 2018 domestic sales and, after the Agriculture Improvement Act of 2018 (Farm Bill) removed them from the Controlled Substance Act, 21 U.S.C. Sections 801, (1970) and Drug Enforcement Administration’s (DEA) clutches, 2019 hemp production and sales exploded.