What to expect when submitting a cannabis stem sample to Medicinal Genomics and addressing concerns about shipping stem samples across State and Federal borders.
Medicinal Genomics’ StrainSEEK Stem Sample Collection Kit provides instructions for taking a sample of your plant and preparing it for shipping to MGC’s services laboratory so that it meets all federal and state guidelines for shipping cannabis plant material across US State and Federal borders. We provide an overview of our collection kit below and explain our findings in preparing our kit instructions.
Stem Sample Collection kits are supplied at no charge with any StrainSEEK® or Whole Genome Sequencing service purchase. Once you checkout on our webstore and we receive the order, we'll send the appropriate number of kits with pre-paid return labels for UPS or FedEx (for all US orders).
Each Stem Collection Kit includes the following:
- 1 Sample Submission Form
- 1 Stem Collection Instructions Sheet
- 2 barcoded sample tubes
- 1 plastic pipette
Important: Each Sample Collection kit contains 2 barcoded sample tubes. The second tube is a backup, just in case we are not able to collect enough DNA from the first tube. Fill both sample tubes with stem from the same plant, and return them in the same bag they arrived in.
Additional equipment you will need to collect your sample(s) that is not included in the kit:
- Razor blade
- Rubbing alcohol
Once we have received your sample(s), we will send an email to the address provided on the Sample Submission Form. We will use this email to communicate the status of your order with you and to deliver the results.
Shipping Cannabis Stem Samples Across State and Federal Borders
There is a classification in the Controlled Substances Act (CSA) that specifically exempts “mature stalks” of the plant. This means that even if the cotyledon, or the first leaf, is a stalk, it is not a mature stalk because it occurs early in the growth cycle. The MGC stem (or stalk) kit instructions require a mature stalk be cut from the plant. We also go a step further and require the stalk be soaked or “washed” in isopropyl ethanol to remove any cannabinoids present in the plant material.
The classification under the CSA of “Exempt Cannabis Plant Material” includes the following four categories.
- Mature stalks (as described above)
- Fiber produced from mature stalks
- Oil or cake made from seeds
- Seeds incapable of germination
The CSA does not actually define “mature stalks”. We have consulted legal counsel and conclude that pressing leaves into paper or accepting cotyledons is not legal under the CSA. Those companies doing so are taking a legal risk. We do not believe that using the cannabis leaf, at any stage of the growth cycle, is allowed.
In May of 2018 the DEA issued an internal directive acknowledging that Exempt Plant Material is not “marijuana”. This clears up the question of whether mature stalks (or stems) can be safely shipped to Medicinal Genomics from abroad. The directive touched on how the distinction impacted internationally traded cannabis.
“[A]ny product that the U.S. Customs and Border Protection determines to be made from the cannabis plant but which falls outside the CSA definition of marijuana may be imported into the United States without restriction under the Controlled Substances Import and Export Act. The same considerations apply to exports of such products from the United States, provided further that it is lawful to import such products under the laws of the country of destination.”
There you have it straight from the horse’s mouth: Importing or exporting Exempt Cannabis Plant Material is lawful under the Controlled Substance Import Export Act.