Phase 2 Control Log¶

Status:	Draft
Source file:	`02 Secondary Research/phase-2-control-log.md`
Sensitivity review:	Completed
Purpose:	This file records how the Phase 1 readiness controls are being applied during Phase 2 Secondary Research.

Phase 2 Commencement¶

Date commenced: 2026-06-09
Authorisation: Phase 2 authorised after GIS/geographic parameters were refined.
Boundary: Current Tenterfield Shire, NSW, plus historic Stanthorpe Shire, Queensland.
Constraint: Phase 2 is secondary research only. No primary interviews, final recommendations or business case conclusions are authorised.

Controls Applied¶

Control from readiness review	Status	Implementation
Start with regulation, product-category definitions and source taxonomy.	Applied	Initial government/regulatory scan created. Source log created from first sources.
Build evidence register from the beginning.	Applied	Evidence register updated with initial source-linked entries.
Apply geographic transferability ratings to every source.	Applied	Source log and evidence register include geography and relevance notes.
Do not allow market forecasts or promotional claims to become findings without corroboration.	Applied	AgriFutures and industry-development sources are treated as evidence of research priorities and industry maturity, not proof of commercial viability.
Separate producer, supply chain, GBLC and environmental implications.	Applied	Evidence register includes perspective fields.
Maintain a live list of claims requiring later primary research.	Applied	Claims requiring verification file created in Source Log.

Current Phase 2 Status¶

Phase 2 has commenced. The current work is an initial source scan and evidence-register setup. It is not a completed literature review, market assessment or business case.

Phase 2 Progress Update - 2026-06-09¶

Researched broader treatment of regulatory costs, clearer international context for AgriFutures' "industry infancy" comparison, and deeper global evidence behind environmental claims.

Additional controls applied:

Regulatory scans now separate direct licence fees from indirect producer costs such as application preparation, producer time, external advice, criminal history checks, site approvals, record keeping, sampling, laboratory testing and approval-delay risk.
International industry context now separates Canada, China and European Union evidence by area, product pathway, statistics quality, processing/trade maturity and transferability.
Environmental evidence now separates crop-production claims from product-substitution and carbon-storage claims.
Global environmental evidence is recorded as useful for mechanisms and product pathways but lower confidence for direct Granite Borders conclusions until regional comparators are applied.
Paywalled or access-limited papers are flagged where they appear useful.
Source log, claims register, data register and evidence register have been updated with new source-linked entries.

Phase 2 Progress Update - Canada Trend Correction - 2026-06-09¶

Reviewed the earlier interpretation that Canada's decline from 2019 to 2023 showed that a larger industry is not necessarily stable or consistently profitable.

Correction applied:

Health Canada notice-based cultivation data are not a clean acreage trend because reporting rates changed materially, from 69% of authorised cultivation licence holders in 2019 to 24.42% in 2023.
Statistics Canada data cited by USDA FAS show a real but smaller recent acreage decline: 55,400 acres planted in 2023, down 28% from 76,900 acres in 2022.
The reviewed evidence does not prove that COVID-19 was the main cause of the decline, even though COVID-19 overlaps with the period.
The stronger finding is that Canadian hemp scale coexists with market, regulatory and value-chain development challenges.
The earlier statement was revised so acreage decline is not used as evidence of profitability or instability without price, margin, processor and market data.

Phase 2 Progress Update - EU and China International Context - 2026-06-09¶

Researched possible reasons for EU hemp decline and whether China is running out of suitable growing land or has demand exceeding local production.

Findings added:

EU sources confirm a 2023 production decline but do not yet establish a single EU-wide cause.
EU trend interpretation now includes data-quality limits, policy incentive effects, processing bottlenecks, country-level variation, niche end markets and farm-economics risks.
China evidence reviewed so far does not show physical exhaustion of suitable hemp-growing land.
China evidence more strongly points to regulatory, variety, seed, mechanisation, retting, processing and market-structure constraints.
China imports hemp fibre despite being a major producer. Quantified indicators include USDA FAS/China Customs data showing HS 5302 imports rising to 837 MT in 2020 and Trade Map/UN Comtrade-derived data showing 9,275 tonnes imported in 2024.
The current evidence does not quantify total Chinese demand exceeding domestic production; imports may reflect quality, specification, timing or price needs.

Phase 2 Progress Update - Previously Access-Limited Environmental Papers - 2026-06-09¶

Full-text PDFs were reviewed for two environmental papers previously flagged as access-limited:

O'Brien and Arathi (2019), "Bee diversity and abundance on flowers of industrial hemp (Cannabis sativa L.)".
Arrigoni et al. (2017), "Life cycle assessment of natural building materials: the role of carbonation, mixture components and transport in the environmental impacts of hempcrete blocks".

Findings added:

O'Brien and Arathi (2019) strengthens the narrow claim that flowering hemp can provide a pollen resource for bees in some contexts. The study collected 1,937 bee individuals from 23 genera in northern Colorado, but it does not prove broad biodiversity improvement or Granite Borders-specific outcomes.
Arrigoni et al. (2017) strengthens the hempcrete product-pathway evidence. The LCA found a negative GHG balance for a non-load-bearing hempcrete block wall under defined assumptions, but also showed carbonation was concentrated in outer block layers after 240 days.
Hempcrete carbon-storage evidence is now recorded as product-pathway evidence only. It must not be treated as evidence that hemp cropping itself improves soil carbon.
The environmental evidence scan, source log, evidence register, claims register, data register and claims requiring verification have been updated.

Phase 2 Progress Update - Local Planning Follow-up - 2026-06-09¶

Completed the regulatory follow-up on whether local planning or development-consent requirements may apply in Tenterfield or historic Stanthorpe contexts.

Initial desktop planning scan completed:

Tenterfield LEP 2013 RU1 Primary Production permits extensive agriculture and intensive plant agriculture without consent. Ordinary field hemp production on appropriately zoned RU1 land is therefore unlikely to require local development consent if classified as those agricultural uses.
Tenterfield Shire Council material confirms development applications may still be required for building, renovating, changing building use, demolition, subdivision or placing structures unless an exempt or complying pathway applies.
Southern Downs Planning Scheme Version 5 defines cropping to include plant fibre production and identifies cropping as accepted development in the Rural zone. Ordinary field hemp production in the historic Stanthorpe area is therefore likely to be accepted development where treated as cropping on appropriate rural land.
Southern Downs development assessment material confirms proposal-specific tools, mapping, codes, forms and pre-lodgement pathways remain relevant.
The residual risk is proposal-specific: buildings, drying/storage sheds, processing, off-site intake, manufacturing, water infrastructure, earthworks, access, overlays, clearing, sales, signage, worker accommodation or demonstration sites may trigger approvals.

Registers updated with source IDs S046 to S049 and new evidence entries. The original follow-up is now reframed as property-specific due diligence rather than an unresolved general desktop scan.

Phase 2 Progress Update - NSW Regulatory Follow-up - 2026-06-10¶

Applied a staged review process for regulatory and definitional scan follow-up items.

Completed the first immediate follow-up item: review of the NSW Hemp Industry Act 2008, Hemp Industry Regulation 2016 and current NSW licence manual.

Findings added:

The NSW Act authorises licences for cultivation or supply of low-THC hemp for commercial production, manufacturing use, scientific purposes and prescribed purposes.
Low-THC hemp is defined as Cannabis with THC concentration in leaves and flowering heads of no more than 1%, including seed and derived products.
Licences generally run for five years, but refusal, renewal, transfer, suspension and cancellation provisions create producer risk.
The NSW Regulation requires site-specific application details, property plans, owner consent where relevant, seed and crop THC controls, notification duties, leaf-stripping before plant material leaves the property unless an exemption or permit applies, and detailed registers.
The September 2025 NSW licence manual states that a new application can take up to four months depending on complexity and document/check timing.
The manual also records site-suitability expectations, planting notifications, annual reporting, crop-failure notification, audit process and audit-frequency consequences.

Registers updated with source IDs S050 to S052 and new evidence entries. The immediate follow-up item is now complete at desktop-review level, with typical processing time and actual producer time burden retained as later verification needs.

Phase 2 Progress Update - Queensland Regulatory Follow-up - 2026-06-10¶

Continued to the next regulatory and definitional scan follow-up item.

Completed the second immediate follow-up item: review of Queensland Drugs Misuse Act 1986 Part 5B and Drugs Misuse Regulation 1987 Part 4.

Findings added:

Queensland Part 5B creates a controlled lawful pathway for industrial cannabis fibre and seed products, not medicinal cannabinoid or smoking-product pathways.
Queensland industrial cannabis plants use a not-more-than-1% THC threshold in leaves and flowering heads, with planting-seed controls tied to a not-more-than-0.5% THC basis.
Queensland licence categories are grower, researcher and seed handler, with materially different authorised activities.
Licence applications require fit-and-proper assessment, close-associate and executive-officer information where relevant, Queensland activity locations, fees and prescribed photographs; researcher applications require a research plan.
The chief executive may seek criminal history reports and may require fingerprint consent.
Licences may be issued for a term of not more than three years and may be subject to conditions.
Suspension and cancellation risks include public-interest immediate suspension, contravention, non-payment and materially false or misleading information; no compensation is payable for suspension, cancellation or destruction under the relevant provisions.
The Regulation adds seed verification/labelling controls, record keeping within seven days, planting notification within 14 days, harvest-testing readiness notice at least four weeks before intended harvest, and potential monitoring, travel and sample-analysis costs.

Registers updated with source IDs S057 and S058 and new evidence entries. The immediate follow-up item is now complete at desktop-review level, with typical approval-processing time, producer time burden and practical monitoring/testing experience retained as later verification needs.

Phase 2 Progress Update - Food Standards Follow-up - 2026-06-10¶

Continued to the next regulatory and definitional scan follow-up item.

Completed the third immediate follow-up item: review of Food Standards Code Standard 1.4.4 for exact hemp seed food requirements.

Findings added:

The Food Standards Code permits a narrow low-THC Cannabis sativa seed and seed-product food pathway.
Seeds may be sold as food or used as food ingredients only if they are from low-THC Cannabis sativa, contain not more than 5 mg/kg total THC, are non-viable and hulled if sold at retail, and contain only naturally present cannabinoids.
Seed oil, beverages and other seed-derived products have different total THC limits: 10 mg/kg for oil, 0.2 mg/kg for beverages and 5 mg/kg for other seed-derived products.
Low-THC Cannabis sativa means leaves and flowering heads do not contain more than 1% delta-9-THC.
Total THC includes delta-9-THC and delta-9-THCA.
Cannabidiol must not be present in any food for sale above 75 mg/kg.
Hemp food labels and presentation must not suggest a psychoactive effect, make CBD nutrition or health claims, use images of plant parts other than seed, or use the words cannabis, marijuana or similar wording; the word hemp is allowed.

Registers updated with source ID S069 and new evidence entries. The immediate follow-up item is now complete at desktop-review level, with processor/buyer specifications, testing practices, labelling controls and import/export requirements retained as later verification needs.

Phase 2 Progress Update - International Context Australian Baseline Follow-up - 2026-06-10¶

Applied a staged review process for international industry context follow-up items.

Completed the first follow-up item: obtain Australian planted area, production value and licence data by state if available.

Findings added:

Available public data provide a partial Australian baseline, not a complete current state-by-state dataset.
AgriFutures reported about 2,000 hectares of Australian hemp crops in 2020, producing about 2,000 tonnes of grain and 100 tonnes of fibre, with seed production accounting for about 95% of crops.
AgriFutures reported estimated Australian industrial hemp GVP of $6 million in 2019-20.
The AgriFutures best management practice manual reported just under 2,500 hectares planted by more than 500 licence holders across Australia in 2022-23.
NSW draft industry-plan material reports 170 hemp industry licences and 254 licensed facilities at 31 March 2025.
Agriculture Victoria reported 42 valid Victorian licences at 15 August 2023, many inactive, with six outdoor commercial growers and 169 hectares planted in 2022-23.
Older public figures identify about 1,600 hectares planted in Tasmania in 2019-20, with farm-gate seed value of $4.5 million, and 280 hectares planted in Western Australia in 2019-20.
Current comparable Queensland, South Australian, Northern Territory and Australian Capital Territory figures remain unresolved.

Registers updated with source IDs S055, S056, S059 and S060 and new evidence entries. The corresponding published draft page and source register were updated because the material is public-source evidence and safe to publish.

Phase 2 Progress Update - International Context Common Category Comparison - 2026-06-10¶

Continued to the next international-industry-context follow-up item.

Completed the second follow-up item: compare Australian industry size against Canada, the European Union and China using common product categories.

Findings added:

The comparison is strongest when separated into seed/grain/food, fibre/stem biomass, hurd/construction, flower/cannabinoid and trade-visibility pathways.
Australia appears materially smaller than Canada, the EU and China on available area and fibre-production indicators.
Australia appears seed-dominant in 2020, with about 2,000 tonnes of grain and 100 tonnes of fibre reported by AgriFutures.
Canada is more relevant for seed/grain and food/nutrition comparison, with USDA FAS reporting that Canadian hemp remains driven by food and nutrition markets.
The EU comparison is strongest for fibre, with European Commission and USDA FAS sources reporting much larger fibre-hemp area and production than Australia.
China is mainly relevant as a fibre/textile-processing and competitive-context comparison, but official production data remain incomplete.
The comparison does not establish demand accessible to Granite Borders producers; it only supports the industry-maturity comparison.

The working note and corresponding published draft page were updated. Evidence and claims registers were updated with a new product-category comparison finding.

Phase 2 Progress Update - International Context Import-Replacement Follow-up - 2026-06-10¶

Continued to the next international-industry-context follow-up item.

Completed the third follow-up item: identify whether Australia imports hemp products that could plausibly be replaced by domestic production.

Findings added:

Australia has lawful import pathways for compliant hemp seed foods, hemp seed oil and hemp fibre under ODC and DAFF guidance.
Import replacement is plausible in principle for hemp seed foods, hemp seed oil and some hemp fibre/tow categories, but this is not yet proof of commercial viability.
HS 5302 provides the clearest hemp-specific trade-code evidence. ABF identifies true hemp tariff lines and WITS/UN Comtrade shows small or irregular Australian trade signals for raw/retted and processed true hemp categories.
HS 120799 is too broad to quantify hemp seed imports. It captures "other oil seeds and oleaginous fruits, nes" and should not be used as a clean hemp seed import figure without finer tariff-line, shipment or buyer data.
Hemp yarn, textiles, hurd/hempcrete and cannabinoid/flower pathways remain unresolved for import-replacement economics because trade-code, processing, legality or buyer evidence is insufficient.

Registers updated with source IDs S070 to S074 and new evidence and claims entries. The working note and corresponding published draft page were updated, and the source register now includes the new import-replacement sources. The follow-up is complete at desktop-review level, with actual hemp-specific import quantities, buyer specifications, local processing requirements and farm-gate economics retained as later verification needs.

Phase 2 Progress Update - International Context Overseas Processing Follow-up - 2026-06-10¶

Continued to the next international-industry-context follow-up item.

Completed the fourth follow-up item: identify whether overseas processing advantages make domestic processing difficult to compete with.

Findings added:

Overseas processing advantages are a material competitive risk for Australian fibre and textile pathways, especially high-specification bast fibre, yarn and textile pathways.
The processing issue should be separated by product pathway. Grain, seed oil, cake and protein processing have lower technology barriers than fibre and textile processing.
Established fibre and textile regions such as China and parts of Europe have larger production bases, processing experience, export pathways and buyer ecosystems than Australia.
Local or regional Australian processing may still be plausible for grain, seed oil, hurd, bedding, construction materials or lower-specification fibre where freight savings, co-product use and buyer offtake offset scale disadvantages.
The decisive evidence for Granite Borders is processor-level economics: capital cost, minimum viable throughput, intake specifications, straw price, freight, product prices and committed buyers.

Registers updated with source IDs S077 and S078 and new evidence and claims entries. The working note and corresponding published draft page were updated, and the follow-up table was re-ranked after removing the completed item.

Phase 2 Progress Update - APVMA Chemical-Use Follow-up - 2026-06-10¶

Continued to the next regulatory and definitional scan follow-up item.

Completed the fourth immediate follow-up item: use APVMA PubCRIS and permits database to identify currently registered or permitted agricultural chemicals for industrial hemp.

Findings added:

PubCRIS host-code checking found that HEMP and HEMP1 are false matches for industrial hemp because they refer to peppermint.
The relevant PubCRIS host code is IH1, described as INDUSTRIAL HEMP.
The IH1 host-use table contained 316 use rows and 26 product codes, with 23 product codes joining to current registered product records.
Registered product-label pathways identified in the joined current product records are dominated by herbicides, especially pendimethalin, trifluralin and fluazifop products, plus one fludioxonil and metalaxyl-M fungicide seed treatment.
Direct APVMA permit PDFs reviewed on 10 June 2026 identify current permitted hemp pathways for PER95564, PER86924, PER94780 and PER94808.
The permit pathways include important restrictions: fibre-only, protected-crop-only, research-only, non-human-consumption, non-grazing, application-method limits, withholding periods, state exclusions and crop-safety cautions.
PER13792 was checked but the current APVMA PDF is for green tea and does not mention hemp, so it has not been included as an industrial hemp production permit.
The chemical-use claim is now reframed: legal chemical pathways exist, but this does not prove industrial hemp requires fewer chemicals than realistic alternatives.

Registers updated with source IDs S075 and S076 and new evidence entries. The claims register now keeps the broad lower-chemical-use claim as unverified pending local agronomic, grower and comparator evidence. The corresponding published draft page and source register were updated because the material is public regulatory evidence and safe to publish.

Phase 2 Progress Update - Synthesis And Gap Review - 2026-06-10¶

Prepared a Phase 2 synthesis and gap review after broad secondary research reached diminishing returns for the moment.

Completed:

Created 02 Secondary Research/phase-2-summary-report.md.
Created the corresponding publishable page at docs/02-secondary-research/phase-2-summary-report.md.
Updated the MkDocs navigation so the Phase 2 Summary Report appears under Secondary Research.
Updated project status and change logs.

Synthesis conclusion:

Broad secondary research has produced enough evidence to define product categories, regulatory pathways, environmental evidence limits, international context and major unresolved gaps.
Phase 2 has not established commercial viability, environmental benefit or GBLC strategic role.
The remaining decision-critical gaps are mainly practical, commercial and local.
The project should move from broad secondary scanning to targeted gap closure and Phase 3 primary research planning, subject to approval.

Phase 2 Progress Update - Producer Economics, Supply Chain And Regional Suitability Gap Closure - 2026-06-10¶

Closed identified secondary research gaps for producer economics, supply chain and regional suitability, including domestic producer, supply-chain and wholesale-buyer pathway information suitable for later mapping with direct contact details redacted from the site.

Completed:

Created detailed working notes for producer economics, supply chain and regional suitability.
Replaced the matching published placeholder pages with detailed draft pages.
Added source IDs S115 to S132.
Added evidence and claims-register entries for producer-economics uncertainty, Stanthorpe trial relevance, Granite Borders climate, domestic food-processing pathways, fibre/hurd processing constraints, seed/genetics constraints and map-ready actor data.

Findings added:

Current secondary evidence provides producer-economics frameworks and yield leads but does not prove profitability for Granite Borders producers.
Stanthorpe trial evidence is the strongest direct regional agronomic lead, while Tenterfield-specific hemp trial evidence remains unresolved.
BoM station data for Tenterfield, Stanthorpe and Applethorpe show a high-elevation, summer-rainfall climate with material frost risk.
Domestic hemp food processors and wholesale ingredient pathways are identifiable, but public sources rarely disclose purchasing capacity, intake windows, prices or contract terms.
Fibre and hurd pathways exist nationally but remain highly dependent on processing proximity, freight economics and co-product markets.
Supply-chain actor data can be published at locality/state/postcode level for later mapping while direct phone, email, street and personal contact details remain redacted.

Residual gaps:

Farm-gate prices and buyer specifications by product pathway.
Processor capacity, utilisation, fees and intake requirements.
Freight-adjusted returns from Tenterfield, Stanthorpe and Applethorpe.
Current purchasing and sales capacity for named domestic actors.
Property-level suitability, including soil, water, frost exposure and harvest logistics.

Phase 2 Progress Update - Australian BMP Agronomy Profile - 2026-06-10¶

Reviewed the AgriFutures Australia best management practice manual for growing, harvesting and storing industrial hemp in Australia and incorporated it into the secondary-research agronomy profiles.

Findings added:

The manual was already recorded as source S059; the source record has been expanded from national baseline evidence to national BMP/agronomy guidance.
The regional suitability note now uses S059 as the main Australian national agronomy checklist, while clearly noting that it is not local Granite Borders trial evidence.
The agronomy profile now covers variety and product pathway fit, sowing and establishment, soil and drainage, nutrition, water and irrigation, pests and diseases, weeds and volunteers, pesticide application, harvest and post-harvest requirements and farmgate cost categories.
The suitability screen now treats drying, cleaning, storage, retting, baling, machinery, contractors and harvest/weather risk as part of producer suitability rather than only downstream supply-chain issues.
The evidence register now separates BMP-supported agronomy guidance from unresolved local suitability, profitability and environmental-benefit claims.

The working regional suitability note, published regional suitability page, source log, evidence register, claims register and published source register were updated. The material is public-source evidence and safe to publish, provided the source is not treated as proof of local commercial viability.

Phase 2 Progress Update - Product Pathway Economic Rough Guide - 2026-06-10¶

Prepared an interim economic rough guide for product pathways to help populate financial figures and build economic understanding of a possible industrial hemp industry in the Granite Borders region.

Completed:

Created a working rough guide and corresponding published page.
Linked the rough guide from the Producer Economics page and Secondary Research navigation.
Added pathway-level rough economic screens for grain/seed food, oil/protein/hearts, planting seed, fibre/bast, hurd/building materials, dual-purpose crops, biomass/composites, lower-specification hurd uses and excluded cannabinoid pathways.
Added minimum financial figures to populate, suggested conservative/base/upside scenario structure and draft Granite Borders budget fields.

Interpretation:

The rough guide is an economic scaffold, not a profitability conclusion.
AgriFutures gross-margin figures are used as national benchmark assumptions requiring local validation.
Grain/seed food is identified as the first pathway to model because it has the clearest legal basis and identifiable Australian processing leads.
Fibre, hurd, building-material and biomass pathways remain processor-, freight- and buyer-dependent.

Phase 2 Progress Update - Economic Confidence Review - 2026-06-11¶

Extended secondary-only economic evidence to test whether GBLC should still spend time on later primary validation, given primary research had not yet commenced.

Completed:

Created a working economic-confidence review and corresponding published page.
Added source IDs S134 to S137 for Australian Hemp Council cost-structure guidance, WITS 2024 Australia-to-US true-hemp export data, USDA/NASS 2024 hemp benchmark data and UTAS Tasmanian forage/seed return caution.
Updated producer economics, product-pathway economics and supply-chain pages to reflect the new confidence judgement.
Added evidence-register entries classifying the process findings by Producer, Supply Chain, GBLC and Environment perspectives.

Interpretation:

Secondary evidence is now strong enough to justify targeted primary research, especially for grain / seed food.
The evidence is not strong enough to justify grower recommendation, promotion or investment.
Fibre, hurd, dual-purpose and biomass pathways should only be prioritised where named processor or buyer access can be tested.
The highest-value primary research questions remain buyer prices, specifications, intake terms, freight-adjusted returns, local grower budgets and agronomist validation.