I take no pleasure in telling you that the primary sponsor of this bill doesn’t think highly of cannabis or its users. At all. But I suppose that’s a 2-way street.
They’ve introduced this same bill multiple times over the last 4 years, and it never leaves committee [probably because of how asinine it is]. Each year, they make miniscule changes such as raising the potency cap by 5% and try again, and we need to stay vigilant to ensure this bill never moves past the committee hearings.
This year the cannabis potency cap changed from 30% THC to 35% THC, and any concentrates or cartridges that test higher than that can only be sold by medically-compliant cannabis retailers to registered cannabis patients.
This bill essentially bans dabs and cartridges for all non-medical users. But before we drive to Oregon or DM the🔌for rosin, we need to all take 3 minutes and register as being opposed to this bill.
How to Take Action
Go to https://app.leg.wa.gov/csi/House. Select "Regulated Substances & Gaming" from the Committee dropdown menu, then "02/02/2023 8:00am" from the Meetings dropdown menu.
Click on "HB 1642 Cannabis concentrates," then click the link that says, "I would like my position noted for the legislative record."
On the next page, make sure you select "CON" as your position. Complete the form with your information, and feel free to put "Patients and Users for Reasonable Policy" as your Organization.
Official Testimony
PURP will be giving the following remote testimony, provided here in writing for any regulators who wish to review it:
I've testified in staunch opposition to HB 1641 earlier today, which would create a tiered sin tax system for concentrates containing more than 35% THC... which is essentially all concentrates*. HB 1642 is an even more restrictive, out of touch, and preposterous attempt to ban the sale of concentrates which will only harm Washington's cannabis tax revenue, devastate the regulated cannabis economy created by I-502, and help the black market thrive.
Please look into the fiscal impact of eliminating the entire product category from our state's cannabis economy. According to the LCB's 2022 annual report (page 22), the amount of tax revenue generated through cannabis sales was more than double what the state made from taxes on beer, wine, and spirits combined. According to Headset data, concentrates accounted for 11.8% of cannabis sales in the last 90 days, with concentrate cartridges accounting for another 17.3%. Given this data, my layman stoner projection is a 29.1% decrease in annual cannabis tax revenue if this bill passes, roughly $148.7 million that would go up in smoke.
Per usual, I speak for the daily cannabis users who financially support Washington's regulated cannabis economy, and we voted for this system because we didn't want our government to treat us as criminals anymore. HB 1642 would once again make us criminals. Not only would this eliminate safe access to cannabis concentrates, but it would eliminate safe access to cannabis vapor products as well. The archetypal soccer mom who sips her vape pen when her kids are asleep would also become a criminal, and that same black market entrepreneur who supplies her untaxed and unregulated vape cartridges won't ask for her children's IDs when selling concentrate products to them as well.
I believe this is the 3rd time in the last 4 years that we've heard an iteration of this same bill, and I think it speaks volumes that it never moves forward. Please do not advance HB 1642, then we can all do this again next year when the primary sponsor amends and re-re-introduces this asinine bill with a 40% limit. Thank you all for your time and consideration.
*Per my testimony in opposition to HB 1641:
It should be noted that the premise of limiting the THC potency of concentrates makes no sense from a physical standpoint. If the average potency of cannabis flower is around 20% THC, and we concentrate that by removing most of the plant matter and leaving just cannabinoids and residual lipids, we can expect the resulting product to be at least 40 to 60% THC.
Hashish— an ancient cannabis concentrate that predates Abrahamic religions— typically clocks in at 40% THC, and today's solventless extractions made by applying heat and pressure to hashish typically yield concentrates with 60 to 70% THC. The 35% threshold in this bill is inherently unreasonable.