Similar to co-operatives, Cannabis Hubs are the core of the commercial pillar of the Full Spectrum Model for the Legal Regulation of Cannabis in South Africa. Hubs are local, decentralized and democratic/horizontal enforcement platforms that take care of quality control, pricing, crop certification, tax collection, anonymous auctions, warehousing, and management of by-products. Hubs implement policies on the ground by offering services required by the regulations.
Hubs are overseen by the Office of the Cannabis OmBUDsman with inputs from the relevant government departments / regulatory authorities. At this stage it is unclear which government departments would oversee what but a good example would be Industrial Cannabis Hubs overseen by the Dept of Agriculture. The Cannabis OmBUDsman would need to work closely with the relevant government departments in order to look after the interests of consumers, cultivators and traders. This creates a triple tier of regulatory oversight that can serve to guard against corruption and the monopolies by large commercial interests.
Hubs are organized in order to provide services to Cannabis operations of the “Commercial Pillar” (standard operations and Kasinomics), but must implement specific and simplified processes for Kasinomics in order to attract the current non-regulated market. Provision for ongoing knowledge sharing within the Hub should also be a significant attraction for industry participants to strive for optimum performance.
All Hubs can service both cultivators and seed-to-sale operations, either buying the crop and paying the growers (with tax/VAT deduction when applicable) for the former, or analyzing and certifying the crop, collecting tax/VAT when applicable, and returning the crop ready for sale, for the latter.
Two types of Hubs should be regulated:
All Hubs provide six mandatory services:
Quality control & basic product analysis,
Establishing product labeling protocols, traceability and basic, required indications of source/ origin on labels,
Basic training & education,
Facilitation of trade between Hubs.
All Hubs can choose to provide optional services, according to their needs:
Advanced product analysis
Access to special fund if relevant (e.g.: Dagga Autonomous Banking Solution – a concept to consider),
Non-psychoactive waste & by-product recycling
Legacy Hubs may decide to become enforcement platforms for collective rights linked to local traditional knowledge, traditional cultural expressions, and/or specific genetic resources. The potential for Legacy Hubs to add value and protect rights is dependent on various factors within Indigenous Knowledge Systems (IKS) legislation already in place and subject to scrutiny by various sectors within our IKS community.
We suggest the following responsibilities for Legacy Hubs:
Services provided by Legacy Hubs
Register of Collective marks and related IP protections (anti-misleading source)
Collective and equitable share benefits from natural and genetic resources (anti-biopiracy & abusive bioprospecting)
Collective organization of cultivation (Farmers Cooperative)
Community-based restrictions to access
Legacy Hubs are organized according to democratic and inclusive participation at the decision-making level. Their Board is representative of all the activities affiliated to the Hub, plus 1 person of authority (to safeguard the ethics of the hub, e.g: legal professional) and 1 administrator.
Registration of new Hubs
A minimum of 5 persons (individual entrepreneurs or companies) would be required to register a new Hub. Individuals or companies that wish to set-up a Hub must register it as a non-profit company, draft up a Hubs business plan, and obtain registration from the Office of the Cannabis OmBUDsman, after which they can start to operate. The only reason for the Office to refuse registration is the failure of the applicant to present a Hub Business Plan that complies with the 6 mandatory services, or the non-registration as a non-profit entity. The OmBUDsman keeps lists and records of all Hubs. It is desirable to the authors of this document that Hubs report to the OmBUDsman but it might be that they report directly to a yet to be established / determined government body.
More detail around the intricacies of the operations of Hubs can be found in the full document of Fields of Green for ALL’s manifesto: Cannabis in South Africa, The People’s Plant. A Full Spectrum Manifesto for Policy Reform.
All comments and suggestions are welcome on our dedicated Manifesto page.