Nathalie Bougenies

Nathalie chairs the hemp CBD practice group and focuses her practice on health and wellness, in addition to corporate transactions and regulatory compliance. She enjoys building a deep understanding of our clients’ businesses, industries, and long-term visions, and leverages her broad expertise and international background to help our overseas companies with their foreign direct investment into the United States and to help American companies with their overseas legal needs.

rules oregon cannabis hemp delta-8 cbn

Oregon Hemp: New Rules (Part 3)

The end of 2021 was marked by significant regulatory changes adopted by the Oregon Liquor and Cannabis Commission (the OLCC), including new rules for hemp and cannabinoids. Today I will cover a few of the big changes affecting artificially derived cannabinoids, including CBN and Delta-8 THC. In the big picture, Oregon stakeholders knew new regulations would

oregon hemp new rules

Oregon Hemp: New Rules (Part 2)

On December 28, 2021, the Oregon Liquor and Cannabis Commission (the OLCC) adopted new hemp rules that greatly impact hemp products sold in the state. The changes were not unexpected, but the new regulations do include revisions from the version that went into effect in July 2021 (through the temporary rulemaking process). Two of the most

irs cannabis tax reporting guidelines

Cannabis Taxpayers, the IRS is Here to Help

For the past year, the Internal Revenue Service (IRS) has directed its attention to the cannabis industry– in a helpful way! This includes promulgation of cannabis tax guidelines as well as webinars and public forums dedicated to tax compliance for marijuana businesses (together, the “Guidelines”). The stated IRS goal here is “to positively impact filing

hemp cbd fda congress

Feds Might Regulate CBD as a Food Ingredient

The CBD Product Safety and Standardization Act (the Act) indicates that the Feds might regulate CBD as a food ingredient, and that it may lead to regulation of other cannabinoids. If the Feds regulate CBD as a food ingredient, it could seriously change the game (in a good way) for hemp CBD companies. On December

Mailing Hemp Cannabinoid Products in the U.S.

Now that the holiday season is upon us, hemp-derived cannabinoid (Hemp Cannabinoid) companies are getting busy selling and shipping their products to consumers throughout the country. In addition to limiting the sale and distribution of their products to jurisdictions where these products are expressly allowed and regulated, Hemp Cannabinoid companies should also familiarize themselves with

new york cannabis marijuana hemp

OCM Takes Over New York’s Hemp Cannabinoid Program. Now What?

Last week, New York’s Cannabis Control Board (“CCB”) held its first meeting since the enactment of the Marijuana Regulation and Taxation Act (the “MRTA”) and announced the transition of the State’s Cannabinoid Hemp Program (the “Program”) from the Department of Health (“DOH”) to the Office of Cannabis Management (“OCM”) – OCM is tasked with administering

hemp cbd gmp label fda

Hemp-Derived Products: The Law Does Not Stop at Labeling Requirements

I work with many manufacturers and distributors of hemp-derived products and am often surprised by the fact that few understand their general obligations beyond labeling requirements. Every state that authorizes and formally regulates the manufacture, distribution, and sale of these products – Colorado is a good example – imposes stringent manufacturing requirements that squarely align

fda delta 8 hemp

The FDA Warns Consumers of the Risks Associated with Delta-8 THC Products

On Tuesday, the Food and Drug Administration (the “FDA”) released its first statement via a consumer update regarding Delta-8 tetrahydrocannabinol (“Delta-8 THC”). The agency decided to provide consumers with key information surrounding the popular cannabinoid following a sharp increase in adverse event reports involving the substance and unauthorized marketing practices directed at minors. If you

oda oregon hemp 2021

Oregon’s New Proposed Hemp Production Regulations

On Monday, August 30, the Oregon Department of Agriculture (ODA) released proposed updates to its hemp regulations. If you follow this blog, you may recall that in July Oregon enacted HB 3000, an omnibus bill covering a wide range of hemp-related issues. One of the new law’s provisions authorizes ODA to update its existing rules

fda cbd ndi hemp

The FDA Continues to Show It Is Not Interested in Regulating Hemp-Derived Products

Last week, the Food and Drug Administration (the “FDA”) maintained its strict and narrow position on the legality of cannabidiol (“CBD”) by rejecting two new dietary ingredient (“NDI”) notifications submitted by Charlotte’s Web and Irwin Naturals. Both companies sought agency clearance to market their full-spectrum hemp extract as “dietary supplements.” In its letters to these