Comment Submitted by Rachel Berry, Founder and CEO of the Illinois Hemp Growers Association on 01/27/2025
Subject Matter Hearing – Department of Revenue, City of Chicago 2025-01-27
Distinguished Members of the Committee:
I appreciate the opportunity to comment on matters related to hemp’s role in public safety regulations and revenue generation. As the Founder and CEO of the Illinois Hemp Growers Association (IHGA), I assert that hemp holds tremendous promise as a sustainable and economically beneficial crop. I also agree, as does a majority of our membership, that additional regulations are needed. My goal today is to help the Committee identify regulations that are sensible and strictly avoid stifling the emerging hemp industry. I will address public safety first, followed by revenue.
1. Public Safety Regulations The IHGA’s position is that purity and potency testing should be required for hemp ingredients used in retail products intended for consumption. To be clear, this recommendation focuses solely on testing hemp ingredients—not every individual serving or consumer product batch. Producers of consumer goods already must comply with a wide array of regulations designed to protect public health. However, an additional checkpoint for hemp ingredients would:
● Ensure the absence of contaminants resulting from cultivation or refinement.
● Determine cannabinoid concentrations by weight so that producers can more accurately (within +/-10%) calibrate the total milligram content of hemp-based products.
Such a checkpoint is an unwritten industry standard but is not yet required by law. Given hemp’s increasing use in consumer goods, implementing this reasonable measure will uphold public safety while imposing minimal additional burden on businesses.
Another key aspect of protecting public health is restricting the sale of hemp products containing cannabinoids to individuals aged 21 and older. Ongoing debates about what constitutes “intoxicating,” the legal definition of “intoxication,” and concerns about any negative health outcomes for individuals under 21 are valid points of caution. Until these questions are definitively answered, restricting access to anyone under 21 is a simple, protective step. This age gate is widely acknowledged as a prudent measure, yet it remains another unwritten standard not currently mandated by law.
The IHGA recommends that the City of Chicago support state-level legislation—specifically HB0064, introduced in the 104th General Assembly—which proposes sensible public safety regulations for hemp. This bipartisan, standalone bill would not jeopardize businesses, addresses public safety concerns, and would significantly broaden hemp licensing opportunities for Chicago residents.
2. Revenue Generation and Taxation The IHGA strongly believes no additional taxation on hemp products is necessary. Contrary to some opinions that propose taxing hemp like alcohol or tobacco, hemp possesses a markedly better safety profile. It is even considered less harmful than widely consumed substances like caffeine. Overburdening hemp with sin taxes is both unwarranted and detrimental to an industry still in its nascent stages.
Furthermore, hemp’s potential extends far beyond consumables. Cannabinoids can one day be utilized industrially for biodegradable adhesives, coatings, and lubricants. If hemp cannabinoids are taxed at levels similar to adult-use marijuana, these innovative opportunities could stall before fully emerging.
We understand that the City of Chicago may be evaluating new taxes on retail hemp products to generate revenue. However, increasing taxes typically results in higher consumer prices, which can reduce sales and, paradoxically, diminish potential revenue gains. A lower tax rate on a robust, expanding market is often more beneficial than a higher tax rate on a stagnating or shrinking one. If additional taxation is considered, we urge the City to conduct comprehensive economic impact studies to evaluate whether the benefits truly outweigh the costs.
The IHGA is not aware of any such analyses having been carried out to date. Rather than imposing new taxes, the City can better serve its interests by promoting and supporting the growth of the hemp industry. The potential economic revitalization in Chicago’s most vulnerable areas cannot be overstated and goes far beyond cannabinoid products.
Hemp can offer diverse opportunities in:
● Community gardening and environmental cleanup (soil remediation, urban agriculture).
● Building and remodeling (using hemp-based materials).
● Job creation in processing, manufacturing, and retail sectors. The IHGA stands ready to work with the City to provide education, resources, and industry expertise. We are committed to fostering a hemp industry that is holistic, sustainable, and inclusive.
On behalf of the Illinois Hemp Growers Association, I want to extend my gratitude for your time and consideration. I would like to reiterate that the IHGA strongly supports the following concepts:
1. Purity and potency testing for hemp ingredients is a sensible and minimally invasive step in protecting public health.
2. A 21+ age gate for cannabinoid-containing products aligns with common-sense public safety measures.
3. The best path forward for public health regulation is through state-level legislation such as HB0064.
4. Additional taxation on hemp products is unwarranted, and may hinder growth and innovation within the industry.
5. The City should support and promote hemp as an avenue for economic revitalization and diversification, rather than burden it with restrictive taxes.
Thank you for the opportunity to share these insights. As the longest standing and most authoritative hemp subject matter experts in the state of Illinois, the IHGA remains available to collaborate with city leaders and other stakeholders to ensure hemp’s potential is fully realized while maintaining the highest standards of consumer safety.
Respectfully,
Rachel Berry,
Founder and CEO Illinois Hemp Growers Association (IHGA)
(815) 719-3928
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