A review of a recent FOI response from the Medicines and Healthcare products Regulatory Agency (MHRA) regarding Skunk, CBD, Cannabis sativa, and their respective Yellow Card lists for adverse reactions to medicines and vaccines.
On 08/02/25 The Hemp Hound Agency submitted a Freedom of Information Request (FOI) to the MHRA with several questions regarding Cannabidiol (CBD) and Cannabis sativa.
This article will go through their response, which was received on 07/03/25.
Before we begin, I want to highlight an article published two years ago by The Hemp Hound Agency, regarding the MHRA’s Yellow Card lists for CBD and Cannabis sativa.
'Killing in the name of' looked at the absurdity of some of the recorded cases, and questioned the legitimacy of including CBD supplemental products in lists that are meant to record adverse reactions to medicines and vaccines. The MHRA’s FOI response states that the names of products causing reactions do not have to be reported—somewhat concerning, especially given their admission that some reactions could be logged on a ‘guilt by association’ basis.
What's more, they have stated that the yellow card list was started due to two fatal reactions to Sativex, and that there were two fatalities from herbal cannabis in 2002 when there were no recognised or authorised medicines or vaccines at the time that fitted that description
The questions asked to the MHRA were:
1. The date when ‘Skunk’ was first listed under the Yellow Card Scheme for Cannabis sativa.
2. The date when CBD supplemental products were first recorded under the Yellow Card
Scheme for Cannabis sativa.
3. The date when CBD products were first listed under the Yellow Card Scheme for CBD specifically.
4. Confirmation that the Yellow Card Scheme is primarily intended for recording adverse reactions to licensed medicines and vaccines.
Additionally requested:
5. Identification of the product(s) attributed to fatalities recorded under Cannabis sativa in 2002.
6. Identification of the product(s) attributed to fatalities recorded under CBD in 2006.
7. If the reports in requests 5 and 6 are not associated with recognised products, can the MHRA confirm whether the fatalities in question were linked to medical trials?
If full disclosure was not possible for requests 5, 6, and 7, a further request was added for:
8. The reason under FOI exemptions for withholding this information.
9. Any general categorisation of the products (e.g., pharmaceutical, consumer, investigational use).
The full response can be found below
Now that you're prepped, let's break down the MHRA’s response—but be warned, it's filled with contradictions and deflections.
Certain questions will be asked, some of which I will answer, whereas others are open to consideration based on available information.
That being said, I encourage discussion on the interpretation and implications of the information provided.
Question 1: The date when 'Skunk' was first listed under the Yellow Card Scheme for Cannabis sativa.
Response: The first UK spontaneous suspected adverse drug reaction (ADR) report we received where the suspect drug was reported using the term “skunk” was received on 15/03/2018.
Analysis:
Suspected... that would be the first indicator of some reports working on a 'guilt by association' basis.
Skunk is a term for illicit high-THC cannabis, not a regulated pharmaceutical product. The only way its presence would make sense is if the medicine in question was actually made from Skunk #1—which, conveniently, happens to be owned by GW Pharmaceuticals.
So it’s completely inappropriate for ‘Skunk’ to be named on a Yellow Card list meant for medicinal cannabis products—unless, of course, the medicine itself was derived from Skunk #1.
But… the date of inclusion? That’s significant.
Thoughts:
There was long-standing suspicion that Skunk was listed on the Cannabis sativa list long before 2018. Now that we know when it was included, it only raises more questions.
The list itself was launched in 1972, just after the Misuse of Drugs Act (MDA) came into force.
We’re talking right after the discovery of several major cannabinoids in the 1960's—which may or may not have led to the need for the MDA, and a scramble to define cannabis as having no medicinal value. To my understanding, this is also when cannabis was redefined—moving from a ‘poison’ to ‘a drug with little to no medicinal value.’
That label came from the 2nd International Opium Convention (1925) and was adopted in the UK through the 1928 amendment to the 1920 Dangerous Drugs Act.
However, the 1925 convention left a window open for pharmaceutical research into ‘pure cannabis,’ and UK law still allowed for the prescription of medical cannabis-based products until 1976.
Then, GW Pharmaceuticals emerges (1998), develops its first product (Sativex) using two isolates (‘pure cannabis’) derived from Skunk #1—which in itself is not a recognised or authorised medicinal product even though the MHRA has entered it on their yellow card list for Cannabis sativa.
So, the products on the Cannabis sativa Yellow Card list are CBD consumer-focused. None were designed as medicines, so why are they listed here?
None of those products even existed before 2015. Skunk was only added in 2018—so the only remaining entry is 'CANNABIS SATIVA [not otherwise coded].'
If this was a list for reactions to medicines and vaccines, shouldn’t it only include products licensed as such?
So, if Sativex wasn't added to the Cannabis sativa list, why wasn't Skunk #1, which is almost exclusively used to create Sativex, added to represent reactions to Sativex, before 2006, when it was used to launch the CBD list?
Conclusion:
This response confirms that the Yellow Card list for Cannabis sativa is not fit for purpose. With Skunk’s inclusion, as well as CBD consumer products, the list itself becomes confused—what exactly is it supposed to represent?
Between 1972 and at least 2015, the only recorded product on the Cannabis sativa list was, in fact, Cannabis sativa—but raw cannabis wasn’t legally available for medicinal use until 2020. And I say 2015 loosely, because as you'll see in the response to Question 2, we still don’t know exactly when the MHRA started listing reports for supplemental CBD products. But in essence, this list confuses raw THC-rich cannabis (which the government claims has no medicinal value) with supplemental hemp and CBD products. That isn’t just an oversight—it signals intent.
Because why else would you allow for that confusion?
Let's look beyond the names for a second...
Between GW Pharmaceuticals’ launch in 1998 and the inclusion of Sativex on the CBD Yellow Card list in 2006 (see Question 3 analysis), 21 adverse reactions to Cannabis sativa were recorded—three of them fatal.
None were recorded for inhalation use. So, these must have been through medicinal trials—likely involving a product made with Skunk #1.
That’s further backed up by nine of the reactions falling under ‘General Disorders and Administration Site Conditions.’
Canada was the first country to authorise Sativex in 2005, meaning trials, you would assume, began between 2002/3, right when the MHRA records the very first deaths to Cannabis sativa, specifically floral, as you will see in the analysis for the response to Question 5. So, if Sativex wasn't added to the Cannabis sativa list, why was Skunk not added to it before 2018?
And by that, I mean Skunk #1, because Skunk by itself is slang that the government forced on the public well after Skunk #1 disappeared from the UK.
Point of interest:
Skunk was added to the Yellow Card list on 15/03/2018.
Three days after the EU and FSA started discussing CBD as a novel food. (Novel foods is seemingly a tool to rid unwelcome market participants, and the CBD industry is full of companies with products that are deemed competition to Epidiolex)
At a time when the highly politically coordinated push for medicinal cannabis legalisation emerged.
And, conveniently, that campaign centred around Epidiolex—GW Pharma’s CBD-based medicine.
The Home Office also took to influence the hemp and CBD industry by defining all products as subject to the Misuse of Drugs Regulations (MDR) 2001 (1mg rule, Regulation 2 Limb C), despite them being subject to EU regulations prior, specifically with a cap of up to 0.2% THC
Coincidental, or convenient?
And for all those who are still uncertain about the difference between the 1mg rule vs 0.2% THC, highly refined selective extracts should be subject to the former, whereas whole-plant products should be subject to the latter.
This is somewhat verified in an FOI response from the FSA in 2019 for all conversations between the EU and FSA regarding CBD as a novel food.
'Should' is not 'is', and 'nothing in food law' doesn't then mean that the it becomes subject to drugs law.
Note the wording, though. 'Some hemp products' easily suggests that not all hemp products 'should' be subject to MDA.
That quote is from January 2019, six months after the Home Office had defined CBD products as subject to MDA.
The relevance of that file is that it shows the FSA and EU discussing CBD as a novel food 12/03/2018, three days before Skunk was added to the yellow card list for Cannabis sativa.
Concerns:
The two reports in 2018 are seemingly filed under 'Inhalation use', but there were no authorised medicines or vaccines that functioned in that manner at the time.
What's more, the reports indicate there were gastrointestinal motility and defaecation conditions as well as gastrointestinal signs and symptoms.
Not to be too formal, but in all my years, I’ve never heard of someone crapping themselves after smoking a spliff.
Other reactions included in the report are paranoia, disturbance in thinking and perception, and Pollakiuria.
If I were a sceptic, I would say that someone had a reaction to a brownie, or possibly a cannabinoid rich ingestible preparation, rather than having reactions to cannabis via inhalation use.
But, regardless of the concerns with the report itself, there were no authorised medicinal cannabis-based products in the UK that functioned through inhalation use in 2018, so why is there a report for two here, and why are they labelled as reactions to Skunk? It can't be a medicinal product, because it's Skunk, not to be confused with Skunk #1, which shows that the yellow card list, supposedly for reactions to medicines and vaccines, contains reports either for adverse reactions to recreational cannabis use, or, for strategically placed reports that are designed to misrepresent a dynamic of cannabis for the benefit of GW Pharmaceuticals' products.
There are other indicators to suggest that the reports are not what they seem
Both were submitted by healthcare professionals, which again calls into question why Skunk being named, as you would expect any healthcare professional in 2018 with an interest in cannabis to know that Skunk, as in raw cannabis, was not an authorised medicine or vaccine. So why did the MHRA accept the reports, and list Skunk on the Cannabis Sativa yellow card list?
Well, it might be all about timing, which I've touched on already, and will do so further as we carry on.
Question 2: The date when CBD supplemental products were first recorded under the Yellow Card Scheme for Cannabis sativa
Response: Please be advised that food supplements are outside the remit of the MHRA; adverse reports for food supplements are to be reported to the Food Standards Agency, who can be contacted at foodinxxxxxxx@xxxx.xxv.uk.
Analysis:
That doesn't answer the question, which is frustrating, but also convenient due to the response given.
Thoughts:
Interestingly, this implies that the FSA has access to an MHRA-owned list. But if that’s the case, it means the FSA has knowingly misrepresented supplemental products as medicines.
Nowhere does it say the Yellow Card lists includes food products, nor does it suggest that the FSA has any control over them.
This feels like a deflection. They know what was asked: the date CBD supplements were added to the Cannabis sativa Yellow Card list.
There’s no reason why they can’t provide an answer—unless that date is significant.
If it aligns closely with the inclusion of Skunk, it would reinforce suspicions that the reports themselves were politically managed.
Points of interest:
The MHRA claims it’s the FSA’s job to monitor food supplement reactions—but they themselves have named CBD supplements in the Yellow Card lists for CBD and Cannabis sativa.
To my knowledge, the FSA has no such list. In fact, the FSA launched allergy and intolerance reporting tool in 2021, but according to their website the page has been archived.
I personally know a former company owner who made one of the CBD products named on the Cannabis sativa list.
The complaint against them was malicious, but here’s the real question: How did the complainant even submit a complaint to the MHRA—about a food supplement?
The MHRA’s response suggests that if they received such a complaint, they would redirect it to the FSA.
But that clearly didn’t happen.
Unless… The FSA has direct access to the Yellow Card lists and has been adding CBD products to them—despite the MHRA never publicly acknowledging that the FSA has that level of control.
I know for a fact that the anonymous complaint I’m referring to was submitted directly to the MHRA—back when they had as much control over the CBD industry as the FSA does now.
Conclusion:
There’s justifiable confusion here, caused by a response that dodges the actual question.
I’ve followed up on the FOI request asking for a clear answer.
Furthermore, upon publication, this article will be sent to both the FSA and MHRA to request confirmation on who owns and controls the Yellow Card lists for Cannabis sativa and CBD.
Question 3: The date when CBD products were first listed under the Yellow Card Scheme for CBD specifically
Response: The first UK spontaneous suspected ADR report we received where the substance of the reported suspect drug was cannabidiol, was received on 26/01/2006.
Thoughts:
I made a mistake here—I was actually looking for the date CBD supplements were added to the list.
That said, this response connects directly to Question 6, which identifies Sativex as the product that started the CBD Yellow Card list after two fatalities in 2006
I believe the MHRA understood the intent of this question. They could have asked for clarification, especially given the wording of Question 2—but instead, they’ve handed over an unexpected gem of a response.
Just like in Question 2, they’ve avoided giving the date when supplemental products were added to the list.
That alone is worth questioning.
Conclusion:
This response is best analysed in the section for Question 6 which discusses the implications of Sativex being the first product on the yellow card list for CBD.
Question 4: Confirmation that the Yellow Card Scheme is primarily intended for recording adverse reactions to licensed medicines and vaccines.
Response: Yellow Cards can be used for reporting suspected adverse drug reactions to medicines, vaccines, herbal, or complementary products, whether self-medicated or prescribed. This includes suspected adverse drug reactions associated with misuse, overdose, medication errors, or from use of unlicensed and off-label medicines: https://www.gov.uk/drug-safety-update/suspect-an-adverse-reaction-yellow-card-i
Thoughts:
Whatever you read above, it always comes back to drugs and medicines, but this question was about consumer CBD products.
The closest match in their response is "herbal, or complementary products"—but even that is still in the context of drugs and medicines.
So, where exactly do CBD food supplements fit into this?
The MHRA's Borderline Medicines Department owns Guidance Note 8, which defines what qualifies as a medicinal product.
It was drafted with the help of the CTA and strictly limits what claims can be made on food supplements before they cross into medicinal territory.
Now, combine that with their response to Question 2, where they claim that CBD food supplements are the FSA’s responsibility, and you'd assume that they would be confident in recognising a food product. Furthermore, you'd like to think they knew the difference between a medicinal product, licensed or otherwise, versus a food where someone has implied it to be 'more' than just a food. The latter shouldn't be on the list because implying doesn't mean that a reaction will manifest that will ultimately be reported. Equally, if any person contacting the MHRA or FSA stated that they had a reaction through using a food as a medicinal product, it shouldn't be recorded, because someone is using the food beyond its intended function.
So why are CBD supplements even on the Yellow Card list at all?
And more importantly—when were they added? Three months after Skunk was added to the Yellow Card list, the CTA held its 2018 AGM.
One of the key speakers? Dr. Chris Jones, former head of the Borderline Medicines Department.
He stated very clearly to those in attendance:
"We’re just waiting for the consumer to see your products as medicinal—that’s when we’ll be back to say hello!"
I was there. I managed the sound setup for that event.
At the time, I thought he was just being bitter. It had been only two years from when the MHRA attempted to classify CBD as a medicine—just two months after Epidiolex completed Phase III trials.
I assumed he was just taking shots across the bow to unsettle the industry, but what if it was a warning?
What if the groundwork was already in place to manipulate consumer perception—to shift the CBD market into the pharmaceutical sector, and he was indicating that a move had already been made?
We've already seen it, certainly from 2019 when the recreational vs medicinal debate emerged. People were being told that recreational users were consuming for medicinal purposes, they just didn't realise it. That move was to redefine cannabis to the public: Skunk is bad, but medical cannabis products made from Skunk are good... As for food, that didn't get a look in, deliberately, because CBD consumer products threaten the dominance of GW Pharmaceuticals through Epidiolex, which when all said and done, is just an over priced pharmaceutical version of a CBD supplemental product.
If I’m right, this would mean that the entire regulation of CBD has been a coordinated effort to control market access.
And if that's the case, the MHRA Yellow Card lists for Cannabis sativa and CBD were never about public safety. It was about paving the way for pharmaceutical dominance over cannabinoids.
Conclusion:
The MHRA’s response sidesteps the real issue: why are CBD supplements even on the list?
They claimed it’s the FSA’s jurisdiction, yet they continue to include CBD supplements in their adverse reaction monitoring.
This reinforces the suspicion that the Yellow Card list is being used as a regulatory weapon.
And if that’s the case, we need to ask—who benefits? Because it’s certainly not the consumer, nor the hemp and CBD industry.
Question 5: Identification of the product(s) attributed to fatalities recorded under Cannabis sativa in 2002.
Response: In 2002 we received two UK spontaneous ADR reports associated with the suspect substance “cannabis sativa” which reported a fatal outcome. In both of these reports the reported suspect product was “cannabis sativa flower”. As mentioned previously, further information on the suspect product such as brand is not mandatory on the Yellow Card form therefore is not always reported.
Thoughts:
First and foremost—no brand of cannabis flower was authorised for medicinal use in 2002.
One major reason?
The Misuse of Drugs Regulations (MDR) 2001 had just come into force—designed to allow trials of cannabis-based medicines while keeping raw flower off the table through the Misuse of Drugs Act (MDA) 1971.
This means that in 2002, no legally available cannabis flower existed in the UK, so what exactly were these two fatal reports referring to?
The MDR 2001 allowed for the transport, testing, and destruction of controlled substances—meaning only a licensed entity would have had access to cannabis for medical trials.
And we know one company had that license.
We know GW Pharmaceuticals received seized cannabis samples in 2004 (See 2014), 2008, 2014, and 2018, but what if they also received earlier batches?
If so, could these fatalities linked to a medical trial?
Because if they were, there’s only one company that could have been running it at the time.
Breaking Down those two Fatal Reports:
One fatality was filed under "Injury, Poisoning, and Procedural Complications"—with "Overdose" listed as the cause of death.
One reaction was listed under "Investigations" with "Drug level increased."
The second fatality was recorded as "Asphyxia," alongside acute psychosis.
And here’s where it gets even stranger.
One report states the route of administration is ‘unknown.’ The other says there are only ‘a few reports’, yet both were submitted by healthcare professionals.
If these were genuine clinical reports, shouldn’t the method of administration be clear?
And if they were part of a clinical trial, wouldn’t there be more structured documentation?
So what are we looking at?
There are two possible scenarios:
The reports were false.
These were medical trial deaths that were vaguely reported, deliberately, to protect something that was, or should have been, on the yellow card lists.
And that second possibility isn’t far-fetched—because this isn’t the first time we’ve seen vague, unexplained fatalities tied to Cannabis sativa on the Yellow Card list.
Just look at what happened in 2018 when Skunk was added—conveniently aligning with the push for novel food regulations for CBD products, at the time a politically managed public campaign to legalise CBD, sorry, medicinal cannabis.
Equally, we have the two Sativex fatalities being used to launch the yellow card list for CBD in 2006, with the one death being recorded as route to administration unknown.
Sativex wasn't authorised in the UK in 2006, so it's arguable that the only way the fatality could have come about was through clinical trials, so how is the route to administration unknown?
Concerns:
The Yellow Card list is looking less like a safety tool and increasingly like a political weapon—used to control cannabis policy. One can only wonder if it has been used with intent against other foods in such a manner.
If this kind of reporting was happening as early as 2002, it means the UK government has been shaping cannabis policy through strategically placed, or strategically vague reporting for decades.
Conclusion:
The lack of clarity around these 2002 fatalities is massively concerning, and given what we now know about how the Yellow Card list has been used, it’s clear that these fatalities, and other, deserve a much deeper investigation.
Question 6: Identification of the product(s) attributed to fatalities recorded under CBD in 2006.
Response: In 2006 we received two UK spontaneous ADR reports with a fatal outcome, where the suspect substance was “cannabidiol”, and the reported suspect product was “Sativex”.
Thoughts:
Come on… be honest—you’ve been waiting for this section.
How on earth can Sativex, a 50:50 THC:CBD product made from Skunk #1, be classified as a CBD product?
You’d expect Sativex to appear on the Cannabis sativa Yellow Card list—but instead, it not only ended up on the CBD list, it effectively launched that list.
And on paper, there are several reasons why that makes no sense.
But then again—are either of these lists appropriate?
Sativex is far from whole-plant cannabis and doesn’t neatly fit into the category of a "cannabis-based medicine” (even though it is).
More accurately, it is a cannabinoid-based medicinal product.
But here’s the real issue: Sativex being placed on the CBD Yellow Card list in the same year GW Pharmaceuticals patented supplemental CBD use reeks of something else entirely—a protection mechanism.
More Uncertainty in the Reporting
Both fatalities were recorded by healthcare professionals.
One report lists “age unknown”.
One death was classified as a cardiac disorder, while the other was cardiac failure.
Routes of administration? “Unknown” for one, “buccal” for the other (suggesting clinical trials).
And let’s not forget—unclear reporting isn’t new.
Of the 33 deaths recorded on the Cannabis sativa Yellow Card list, 32 have “unknown” as the route of administration, or are flagged as having only “a few reports”.
That’s not normal.
Concerns:
Who Benefited from This Classification?
Why did the MHRA classify Sativex-related deaths under CBD instead of Cannabis sativa?
Who benefited from that decision?
Or more importantly—who influenced it?
A book released in 2021, A Worthwhile Medicine, sheds some light on this.
In it, Professor Geoffrey Guy, co-founder of GW Pharmaceuticals, openly admits that he was controlling the cannabis narrative while simultaneously providing the Home Office with responses to parliamentary questions about cannabis.
Considering we’ve already seen GW’s influence extend far beyond the pharmaceutical industry, it’s not a stretch to assume this influence also shaped the MHRA’s handling of adverse event reporting.
We’ve Seen This Before—And It’s Always Convenient
In 2020, the head of Novel Foods admitted the Home Office was “holding the FSA’s hand” regarding controlled cannabinoids.
GW Pharmaceuticals defined 9 out of 12 controlled cannabinoids—despite no evidence of abuse potential or psychoactivity for most of them.
In January 2020, two unnamed observers attended a Centre on Toxicity (CoT) meeting to discuss CBD regulation—using 16 Epidiolex lab reports as the basis for setting regulatory standards for CBD Novel Foods.
The FSA even confirmed that while Epidiolex is a medicine, not a food, its safety data was exceptional—yet that same data was then applied to food supplements.
This is a pattern.
The Home Office doesn’t just manage GW’s interests—it actively enforces them.
How Hard Would It Be to Influence the MHRA?
We already know that government agencies have misrepresented cannabinoids in other areas, from novel foods to borderline medicines classifications.
So how much effort would it really take to shape the Yellow Card data in a way that protects Sativex and Epidiolex—while damaging their competition?
Were these reports based on questionably vague trial data?
Were they the result of casual, unchecked reporting?
Or was there a more deliberate effort to shape how cannabis-derived products were perceived?
The MHRA has either allowed inconsistent, vague reporting… or facilitated it.
Either way—it raises serious questions.
At the very least, anyone logging fatalities in 2002 or 2006 should have asked the right questions.
Any competent healthcare professional or MHRA worker should have been suspicious of a report where the age, sex, or even the route of administration was unknown—especially when it involved a fatality.
So, how did these reports make it through?
That is not an isolated issue—it is systemic.
The Scale of the Problem: Trial Data Disguised as Consumer Reports?
Out of 193 reports on the Cannabis sativa list:
14 reports are sex unknown
9 reports are age unknown
6 reactions of which fall under General Disorders & Administration Site Conditions
5 of them were filed by healthcare professionals
2 of them record unknown routes of administration
When examined more closely, 139 reports covering 335 reactions, out of 193 and 549 respectively, indicate a strong possibility that these are associated with clinical trials.
That accounts for 72% of all reports, with over 50% of total recorded reactions—yet most categories do not even apply to supplemental products.
The same pattern emerges with the CBD list:
Out of 549 reports:
64 are sex unknown
51 are age unknown
34 of them do not specify administration routes
2 are fatal reactions
21 fall under General Disorders & Administration Site Conditions
17 were filed by healthcare professionals
When looking at the same reactions that were highlighted with the Cannabis Sativa list, a similar picture emerges.
Both lists combined record 45 fatal reactions, 75 are for reactions through inhalation use (71 for CBD...), 416 reports out of 742 are recorded as route to administration being unknown, and of them, 294 (70.7%) were reported by healthcare professionals.
For some reason, someone though it appropriate to add reactions to consumer products that should all be labelled with "This product is not intended to treat, diagnose or cure any ailment, condition or disease", and diminish the authenticity of a food by portraying it as a medicine.
And here's something to consider. Those lists are effectively redacted, in that you cannot see what product is associated with what report.
That means that from the outside looking in, you could be forgive in thinking that food supplemental products were potentially responsible for the fatal reactions recorded on the list for Cannabis sativa.
And, if they didn't question the inclusion of Skunk on the list, it's most likely that the idea of fatalities to herbal cannabis would be dismissed as science deems it impossible to overdose from herbal cannabis, and it's accepted that the plant in its raw sense has never killed anyone.
We only know that Sativex started the CBD list because the MHRA were asked, as with when Skunk was added, but we don't see what everything else is attributed to, reaction-wise, and that's where another misrepresentation lies.
A lot of listed CBD products could be described as whole-plant in nature, and as such, if there was a provision where reactions to supplemental products could be legitimately recorded on the yellow card scheme, they would be better suited to being on the cannabis sativa list.
Equally, the MHRA has added reactions to unlicensed cannabis for medicinal use on the CBD list. Some of those products have little to no CBD in whatsoever, which means their inclusion on the CBD list makes less sense that the inclusion of supplemental products.
The Sativex / Buccal Connection It is already confirmed that Sativex was the product used to justify the launch of the CBD Yellow Card list in 2006—the same year GW Pharmaceuticals filed a patent for CBD, including for supplemental use.
One of the 2006 fatalities was recorded under "buccal" administration.
This is important because:
There is a fine line between buccal, oral, and sublingual administration.
CBD supplements are marketed as oral or sublingual—which means Sativex reports would most likely be reported as buccal, although as we know with the other fatality reported in 2006, some might be reported as the route to administration being unknown.
When breaking this down further:
31 reports on the CBD list are associated with buccal administration.
Those reports account for 114 reactions—which is approximately 10% of all reactions recorded on the CBD list.
Seven of the twelve fatalities recorded on the list are categorised as buccal, with the other five being for oral use (1), sublingual use (1), and unknown (3).
And this brings us back to the key question: Why are supplemental products listed in a system meant for medicines and vaccines—especially when the data seems to include medicinal trial reports? There is also something else to consider here: If one of the 2 initial fatalities attributed to Sativex was recorded as having an unknown route to administration, there is a high possibility that the other two that are recorded as such are also due to Sativex. And as stated before, there's a fine line between buccal, oral, and sublingual use. This basically means that all of those fatalities could have been caused by the same product.
The MHRA’s Own Words Undermine Their Entire System
The MHRA’s didn't need to respond to questions 7, 8, and 9, but their additional statements warrant closer scrutiny.
Causality Has Not Been Established
The MHRA states:
“Please be aware that when interpreting ADR data, it is particularly important to note that causality has not been established.”
If causality has not been established, how can any Yellow Card list be considered credible?
Particularly when it contains reports where sex, age, and administration route are unknown, and fatalities are attributed to non-medicines?
This is not just incompetence—it appears to be regulatory manipulation.
The Blurred Line Between Food and Medicine
The MHRA admits that it should not be logging adverse reactions for food supplements, as that falls under the FSA’s remit, yet, CBD supplements remain listed under a system meant for medicines and vaccines.
If they knew all along that food supplements fall under the FSA’s jurisdiction, why have these reports not been removed?
This is not an oversight—it is misrepresentation by design.
The MHRA further states:
“Many suspected ADRs reported on a Yellow Card do not have any relation to the medicine or vaccine and it is often coincidental that symptoms occurred around the same time.”
If this is true, why is the Yellow Card Scheme used to justify policy and regulation?
If reports may have nothing to do with the product they are attributed to, what is the purpose of the list?
The MHRA’s Own Contradictions
The MHRA also claims:
“Many factors have to be taken into account in assessing causal relationships, including the time between taking the suspect drug and experiencing the ADR, contribution of other medication, and any underlying disease.”
This directly contradicts their previous statement that causality is not established.
And finally, the MHRA states:
“A spontaneous report is an unsolicited communication by a healthcare professional or consumer to a competent authority, marketing authorisation holder or other organisation… that describes one or more suspected adverse reactions in a patient who was given one or more medicinal products.”
This raises another fundamental issue: If the Yellow Card system is for medicinal products, why are non-medicinal CBD food supplements included?
What This Breakdown Proves
Skunk was added to the Yellow Card list for Cannabis sativa on 15/03/2018.
This coincided with:
The move to restrict whole-plant CBD.
A politically managed campaign to legalise medicinal cannabis (Epidiolex).
The FSA’s shift to define CBD as a novel food.
The MHRA refuses to disclose when CBD supplements were added to the Cannabis sativa Yellow Card list—
Likely because it aligns with Skunk’s addition and the medicinal cannabis campaign.
Sativex was used to justify the launch of the CBD Yellow Card list in 2006—
Despite being 50:50 THC:CBD, it was classified as a CBD product, rather than being placed in the Cannabis sativa list.
The MHRA admits they should not be cataloguing food supplements, yet they continue to do so, while the FSA has no equivalent list.
The Yellow Card list is not credible.
The MHRA admits reports are based on suspicion, not verified evidence.
Many reports list unknown age, sex, or administration routes, undermining their validity.
Medical trial data is mixed with consumer product reports, making the list functionally meaningless.
Final Question: Who Is This System Really Designed to Serve?
The level of government effort to control cannabis for the benefit of one company is staggering.
This FOI response proves the system is broken. At its core, cannabis is a food—but the moment it shows potential as a medicine, it is regulated out of food markets and into pharmaceutical control, which is an ongoing event.
Hippocrates said, “Let food be thy medicine and medicine thy food.”
A regulatory body that claims to protect public health should follow the principle of ‘Do No Harm.’
Instead, they have:
Blurred the line between food and medicine
Misrepresented data
Weaponised a safety reporting system to shape policy in favour of pharmaceuticals
Now, consider this:
What if the MHRA provided the missing FOI response, revealing when CBD supplements were first added to the Cannabis sativa Yellow Card list, and if that date happened to be within days of Skunk’s addition.
That would place it right at the start of the medicinal cannabis campaign and the push to redefine CBD as a novel food.
The timing alone would validate concerns of regulatory capture.
Before you go...
I have a personal victory to report.
One of the key goals of this FOI request was to find trackable use of the Skunk Narrative—and this has now been achieved through the timing of its inclusion in the Cannabis sativa Yellow Card list.
Before receiving this FOI response, my working theory was that Skunk was added to the list in 2006, around the same time Sativex launched the CBD Yellow Card list, and GW Pharmaceuticals filed their patent covering supplemental CBD use.
The reasoning?
The Skunk Narrative officially launched in 2005, when Tony Blair pushed to reverse the downgrading of cannabis to Class C.
If Sativex wasn't listed separately, it would have been classified as Skunk—because Sativex is made from Skunk #1.
But this FOI response has changed the timeline—and with it, the implications.
Why I Pursued This FOI
I remember the introduction of the Skunk Narrative—because I was there.
Between 1996 and 1998, I regularly visited coffeeshops in Holland, where I saw first-hand how half the menus featured Super Skunk, Special Skunk, and other variants, while the other half did not.
By 2001, I was living in Brixton during the Lambeth decriminalisation trial—Skunk was rarely named.
From 2002 to 2005, I was growing my own cannabis and knew many hobbyist growers. We weren’t growing Skunk #1—we had options.
I remember specifically in 2005 someone giving me some Skunk seeds, and I grew them knowing that I was growing something rare, but at the same time, I was also growing 7 other different strains including: Holland's Hope, Ice Cream, Strawberry Cough and Northern lights.
The latter is another strain associated with Hortapharm and GW Pharmaceuticals.
So when Blair suddenly declared a crisis, claiming Skunk was an issue, I immediately questioned it.
When I realised that ‘Skunk’ had been redefined to mean any cannabis over 14% THC, my suspicions deepened.
But it wasn’t until 2018—the year Skunk was added to the Cannabis sativa Yellow Card list—that I discovered GW Pharmaceuticals effectively owns Skunk #1.
By then, Skunk and its variants were largely obsolete, but that decline started in 1998, and accelerated when the government signalled a softening stance on cannabis in 2001.
The point of that decline is notable in that it was the point GW Pharmaceuticals claimed ownership of Skunk #1, as well as Hindu Kush, Gloria (???) and Northern Lights.
I've been fascinated with the way that the government has used the Skunk Narrative, whilst living through it.
This article isn't just about me reporting on some bit of information, I've been following this for years, and now I have direct evidence of the narrative and it's employment
The Smoking Gun?
Seeing the MHRA use the Skunk Narrative in its official data is priceless. It shows that it's an inter-departmental tool for a wider agenda, that being to facilitate GW Pharmaceuticals ownership of Skunk.
It's one thing if you have the home Office quoting figures for cannabis use with a percentage give for that believed to be Skunk, or for the Department for Health and Social Care to give a warning to the potential of cannabis psychosis through Skunk use.
But for a government department to add Skunk to a list for reactions to medicines and vaccines when it's a government managed slang word for recreational cannabis, regardless of when, it shows either incompetence or intent.
Incompetence is ruled out when considering that supplemental products are included in that misrepresentation.
That's where the Skunk Narrative breaks down
We need to see cannabis beyond that which the government manages. It's more than Skunk, it's more than a medicine, and yet the government would have you believe otherwise.
But one key piece is still missing: If it’s confirmed that CBD consumer products were added to the Yellow Card lists at the same time as Skunk, then the connection becomes undeniable.
It would prove, without a shadow of a doubt, that:
The Skunk Narrative and CBD policy are deeply intertwined.
The MHRA and government agencies have weaponised language and data to justify pharmaceutical control over cannabis-derived products.
The entire regulatory approach to cannabinoids has been designed to protect pharmaceutical interests, which includes using non-pharmaceuticals regulations to do so (Novel Foods).
That’s the final piece of the puzzle, and if the MHRA refuses to release the date for when CBD products were added—that tells us everything we need to know.
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