Dear Members of the Department of Cannabis Control,

I write today as a concerned California resident and pet owner to strongly oppose the proposed regulation limiting THC in pet‐specific cannabis products to no more than 1 mg per package. 

I wholeheartedly support the Department’s goal of establishing safe, responsible oversight for cannabis-derived therapies for companion animals, which was the core intent of Assembly Bill 1885. However, I believe the proposed 1 mg THC-per-package limit will create unintended consequences that run counter to this goal. I would like to propose an alternative, ratio-based approach that I believe more effectively ensures both safety and therapeutic access for pets.

Aligning with the Existing Market to Ensure Viability and Safety

The current hemp market provides an important context. Under the 2018 Farm Bill, legally available hemp-derived pet CBD tinctures often contain 1000 mg of CBD and 25-40 mg of THC per package while remaining under the 0.3% THC threshold.

A 1 mg THC limit for dispensary products would present two significant challenges:

• It would necessitate that products are made only from CBD isolate to meet the regulation, removing other beneficial cannabinoids. CBD isolate products are already widely available at a low cost in the unregulated hemp market. This creates a difficult economic position for licensed manufacturers, who would be required to produce a more expensive, highly-regulated product that offers no competitive advantage.
• It would incentivize consumers to remain in the less-regulated hemp market, where products often lack the rigorous testing, veterinary guidance, and clear dosing instructions that AB 1885 aims to provide. A successful regulated market should offer a clear benefit over existing, alternative options.

Adopting Veterinary Best Practices Based on CBD:THC Ratios

From a veterinary standpoint, the safety and efficacy of a cannabis product for pets are best managed by the ratio of CBD to THC, rather than a flat THC cap. A required minimum CBD:THC ratio (e.g., 10:1 or higher) is the clinical standard for ensuring therapeutic benefit without intoxication.

Small, ratio-controlled amounts of THC are critical for the “entourage effect,” which enhances CBD’s ability to relieve pain, reduce anxiety, inflammation, nausea, appetite loss, counteract seizures, and even provide anti-cancer benefits. A 1 mg THC per package limit would make it impossible to provide an effective dose for many conditions, especially in medium to large-sized animals.

Preventing Unintended Risks to Pet Health

If the regulated pet products are not therapeutically effective, loving pet owners may feel forced to turn to cannabis products intended for humans. This introduces significant risks, as human products may:

• Contain ingredients that are toxic to animals (e.g., xylitol or chocolate).
• Lack pet-specific dosing instructions, increasing the risk of accidental overdose.

The purpose of AB 1885 is to create a safe harbor for pet owners. An overly restrictive THC limit would inadvertently guide them toward these riskier alternatives.

Proposed Solution: A Ratio-Based Standard

To create a safe, effective, and viable regulated market, I respectfully propose the DCC revise the proposed regulation to focus on ratios, consistent with current veterinary guidance. I suggest the following language:

“Pet cannabis products shall not exceed a ratio of 10:1 CBD:THC per package (i.e., for every 10 mg of CBD, no more than 1 mg of THC), and the total THC content shall not exceed the per-package limit currently allowed for human cannabis products.”

This approach provides a more effective framework because it:

• Ensures Safety and Efficacy: By capping the CBD:THC ratio, it enables veterinarian-recommended, controlled dosing that is safe and therapeutically meaningful, avoiding both underdosing and intoxication.
• Supports a Viable Regulated Market: This allows for the production of effective full-spectrum formulations that give pet owners a reason to choose safe, tested, dispensary-grade options over cheaper, unregulated hemp or human products.

For over a decade, California pet owners and veterinarians have seen the benefits of third-party tested, ratio-specific cannabis products. By adopting a CBD:THC ratio standard, the DCC can successfully fulfill the goals of AB 1885—ensuring California’s pets have access to the safe, appropriate, and effective therapies they deserve.

Thank you for your time and for your commitment to this important issue.

Sincerely,