Regulatory and Definitional Scan

Status:	Draft
Source file:	02 Secondary Research/Government Sources/regulatory-and-definitional-scan.md
Sensitivity review:	Completed
Purpose:	This scan starts Phase 2 with the regulatory and definitional controls required by the readiness review. It does not assess commercial viability or environmental merit.

Working Definition

Industrial hemp is treated in this project as low-THC Cannabis sativa grown under state licensing systems for lawful industrial, food seed, fibre or related non-medicinal uses.

Product categories must be separated:

• Seed and grain for food.
• Seed oil and seed-derived food products.
• Fibre.
• Hurd and building materials.
• Biomass or other legal industrial uses.
• Research or seed production.

Medicinal cannabis, recreational cannabis, CBD oil from leaves/flowering heads and illegal cannabis markets remain out of scope unless mentioned only to clarify regulatory boundaries.

NSW Regulatory Notes

Source IDs: S001, S002, S050, S051, S052.

NSW DPI states that the Hemp Industry Act 2008 authorises and regulates cultivation and supply of low-THC hemp for commercial production and other legitimate uses. NSW DPI material also states that hemp cannot be grown commercially or for research in NSW without a licence.

The NSW FAQ defines low-THC hemp as cannabis plants with THC concentration in leaves and flowering heads of no more than 1%, including seed and derived products such as oil or fibre.

Project implication:

• For current Tenterfield Shire, NSW licensing is a direct regulatory requirement.
• Any producer economics must include licence, audit, compliance, notification and development-consent considerations where applicable.

NSW Detailed Licence Obligations

Source IDs: S050, S051, S052.

This follow-up reviews the current NSW Hemp Industry Act 2008, Hemp Industry Regulation 2016 and September 2025 NSW licence manual.

The Hemp Industry Act 2008 authorises the Secretary to grant a licence to cultivate or supply low-THC hemp for:

• commercial production;
• use in any manufacturing process;
• scientific research, instruction, analysis or study;
• any prescribed purpose.

The Act defines low-THC hemp as any plant of the genus Cannabis with THC concentration in leaves and flowering heads of no more than 1%, including seed and derived products such as oil, fibre or resin. A licence generally runs for five years unless suspended, cancelled or issued for a shorter period. Renewal applications received at least 28 days before expiry continue the licence until the renewal is determined. The Act also states that licence application and transfer decisions are final and are not subject to review.

The Hemp Industry Regulation 2016 makes the NSW pathway site-specific and documentation-heavy. For commercial cultivation, applications must include property location details, a plan showing cultivation or storage areas and, where the applicant does not own the land, evidence of owner consent. Manufacturing-related applications must also describe the relevant manufacturing processes where known. Scientific-purpose applications require research details and relevant qualifications or experience.

Prescribed licence conditions include:

• activities must remain under the licensee's control;
• activities must occur only in approved areas where the licence specifies an area;
• seed may only be used if supplied on the basis that it will not produce hemp above 0.5% THC in leaves and flowering heads;
• the licensee must take all necessary steps to keep cultivated hemp at or below 1% THC;
• any test result above 1% THC must be provided to the Secretary within 24 hours;
• unauthorised use or supply, or proposed unauthorised use or supply, must be notified;
• low-THC hemp must not be at risk of unlawful use;
• hemp must be substantially stripped of leaves before leaving the cultivation property unless an exemption or permit applies;
• material changes and drug-related convictions must be notified;
• the licence must be produced for inspection and the licensee must cooperate with inspectors.

The Regulation also requires a detailed licence register covering people involved, seed and plant movements, sowing, planting, disposal, destruction, harvest and supply. Register entries must be made within 48 hours of the relevant event and records must be kept securely. If a licence expires or is cancelled, the register must be retained for five years.

The September 2025 NSW licence manual adds operational detail. A new licence application can take up to four months to complete, depending on complexity and time taken to secure documents and checks. If all required documentation is not submitted within 14 days of initial assessment by the Licensing Officer, the application can be rejected and the applicant must re-apply. Each applicant and close associate must complete a National Criminal Record Check.

The licence manual's application checklist includes:

• fully completed application form;
• ASIC extract or certificate of incorporation where relevant;
• photo identification for each applicant and close associate;
• location map and property plan showing cultivation, storage and/or processing areas, associated and surrounding roads, buildings and structures;
• consent to use property where all property owners are not applicants or close associates;
• proof of property ownership;
• research proposal and qualification evidence where the applicant seeks to cultivate for their own scientific research;
• payment details.

The manual also identifies site-suitability expectations. Locations should have restricted visibility and be away from main roads or paths commonly used by the public. Locations must have restricted access and be appropriately distanced from residential areas, places of public gathering, schools and similar sensitive uses. The Secretary may deem some locations unsuitable, including locations in or directly adjacent to residential areas, recreational, sporting or wildlife reserves or airport flight paths; within a 2 km radius of childcare facilities, hospitals, aged-care facilities, disability-care facilities or public function buildings; within a 1 km radius of sporting stadiums, bus and train stations, commercial car parks, commercial retail outlets or correctional facilities; or near main roads or paths used by the community.

Other licence-manual obligations relevant to producer cost and risk include:

• adding locations or activities requires a material-change process; additional locations incur desktop and on-site audits and licence holders should allow at least 30 days' notice;
• planting notifications must be submitted no more than seven days after planting;
• an annual report is due by 1 August each year;
• crop failure must be notified and reflected in the licence register and annual report;
• non-compliant THC test results above 1% must be notified within 24 hours;
• audits assess whether activities match the licence, conditions are followed, security precautions are in place, the register is accurate and personnel details are current;
• acceptable audits generally lead to the next audit in 12 months, while unacceptable audits can trigger follow-up within one month, monthly audits and enforcement action.

Project implication:

• For NSW producers in current Tenterfield Shire, the regulatory burden is material even before local planning, agronomy or market risk is considered.
• Producer budgets should include time and possible advisory cost for application preparation, property maps, owner consent, close-associate checks, site-selection due diligence, renewal, material changes, planting notifications, THC sampling/testing coordination, annual reporting, licence register maintenance and audit readiness.
• The application-timing gap is partly resolved for NSW: the current manual states that a new licence application can take up to four months. The remaining gap is the typical time actually experienced by applicants and whether timing regularly affects planting windows.
• GBLC demonstration or research activity in NSW would need early regulatory planning because research-purpose applications require relevant research detail and qualifications/experience, and site suitability may be a practical constraint.

NSW Cost and Time Burden Notes

Source IDs: S002, S021, S052.

NSW DPIRD's August 2024 FAQ identifies direct licensing costs for low-THC hemp:

Cost item	Amount or treatment	Project relevance
Licence application fee	$572 on lodgement	Direct establishment cost for a new NSW producer.
Renewal fee	$418 on lodgement	Renewal cost where production continues.
Annual administration fee	$200 in each of the following four years	Recurring compliance cost during the usual five-year licence period.
Criminal history checks	Passed on to applicant	Variable direct cost for applicant and close associates.
THC sampling	Conducted by NSW DPIRD officer at licensee's expense	Variable direct cost and timing risk around crop sampling.
THC laboratory analysis	Accredited laboratory analysis at licensee's expense	Variable direct cost and operational compliance cost.

NSW DPIRD also states that an application should be submitted well in advance of proposed planting time, because low-THC hemp planting is generally between March and August and producers need time to source seed and prepare ground. No exact approval-processing timeframe has yet been identified in the reviewed NSW FAQ.

Indirect cost categories to include in producer economics:

• Producer time to prepare the application and supporting material.
• Time to demonstrate a lawful and genuine purpose for cultivation and supply.
• Time to identify and document proposed sites, crop area and intended product destination.
• Time and possible external advice to identify close associates and obtain owner consent where land is leased or not owned by the applicant.
• Possible legal, compliance or planning advice where land tenure, processing arrangements, close-associate status, development consent or cross-border supply is unclear.
• Opportunity cost if approval timing, site approval, seed sourcing, THC sampling or laboratory testing delays planting, harvest, sale or delivery.
• Record keeping, annual reporting and audit readiness costs.
• Risk cost from refusal, suspension, cancellation or non-refundable fees after an application is determined.

Project implication:

• Regulatory cost is not limited to the published licence fee. A producer budget should include a separate compliance-cost line for application preparation, annual administration, criminal history checks, sampling, testing, record keeping, reporting, audits, advice and timing risk.
• Approval-processing time is now partly evidenced for NSW: the September 2025 licence manual states that a new application can take up to four months. Typical rather than maximum processing time should still be tested through NSW DPIRD guidance and later grower interviews.

Queensland Regulatory Notes

Source IDs: S003, S004, S057, S058.

Business Queensland states that industrial cannabis/hemp in Queensland is Cannabis sativa bred to have THC levels of no more than 1%, and that a Biosecurity Queensland licence is required to grow industrial cannabis. The page identifies grower, researcher and seed handler licences.

Business Queensland also states that Queensland industrial cannabis production is managed under Part 5B of the Drugs Misuse Act 1986 and Part 4 of the Drugs Misuse Regulation 1987. The page lists current fees and notes that additional requirements include security, mandatory record keeping and notifications.

Queensland material identifies prohibited activities including extracting or producing CBD oil or other products from leaves or flowering heads, supplying leaves or flowering heads for that purpose, and allowing food-producing animals to consume industrial cannabis plants.

Project implication:

• For historic Stanthorpe Shire, Queensland licensing is a direct regulatory requirement.
• Queensland compliance obligations should be included in producer and supply-chain cost/risk analysis.
• Uses involving CBD, leaves or flowering heads are not within the normal industrial hemp pathway and should be treated as out of scope unless a legal pathway is verified.

Queensland Detailed Licence Obligations

Source IDs: S057, S058.

This follow-up reviews Queensland Drugs Misuse Act 1986 Part 5B and Drugs Misuse Regulation 1987 Part 4.

Part 5B of the Drugs Misuse Act 1986 facilitates processing, marketing and trade in industrial cannabis fibre and fibre products, and industrial cannabis seed and seed products. It expressly does not facilitate production of anything intended for administration to or smoking by a person, except the supply of cannabis seed to Commonwealth-licensed cannabis research licence holders, medicinal cannabis licence holders or manufacturing licence holders under specified pathways.

The Act defines an industrial cannabis plant as Cannabis sativa with THC concentration in leaves and flowering heads of not more than 1%. The Act also distinguishes planting seed from industrial cannabis seed and research cannabis categories. For grower licences, planting seed is treated as seed from a cannabis plant with THC in leaves and flowering heads of not more than 0.5%, while the resulting industrial cannabis plants may be not more than 1% THC.

Queensland has three main licence categories:

• Grower licence: authorises possession and production of industrial cannabis plants, planting seed and industrial cannabis seed, and limited supply to authorised persons.
• Researcher licence: authorises research and related activities, including growing industrial cannabis and research cannabis under the licence and research plan.
• Seed handler licence: authorises supply, denaturing, cleaning, drying, grading and storage of industrial cannabis seed.

Applications must show the applicant is eligible and fit and proper, be made in the approved form, identify the licence type, provide close-associate and corporate executive-officer details where relevant, state the Queensland place or places where activities will occur and include the required fee and photographs. Researcher licence applications must include a research plan.

Fit-and-proper assessment can consider the applicant, close associates, corporate executive officers, criminal history, previous licence suspensions or cancellations and, for researchers, relevant qualifications. The chief executive may ask the police commissioner for criminal history checks and may require fingerprint consent. If a person refuses to consent to fingerprints being taken, the chief executive must refuse to consider the application.

The chief executive may issue a licence for a term of not more than three years and may impose conditions considered necessary or desirable. It is a condition of every licence that the licensee must not contravene the Act and must notify the chief executive of any change of address or close associates as soon as practicable.

The Act allows licence renewal, amendment, suspension and cancellation. Suspension or cancellation risks include no longer being fit and proper, contravention of the Act or licence conditions, non-payment of fees and materially false or misleading information. The chief executive may immediately suspend a licence for up to 28 days where necessary in the public interest, including because of urgent circumstances or risk that industrial cannabis seed or plants may be diverted for an unlawful purpose. No compensation is payable by the State because of suspension, cancellation or destruction of cannabis plants or seed under the relevant provisions.

Part 4 of the Drugs Misuse Regulation 1987 adds detailed operational requirements. Key requirements include:

• cannabis seed is taken to be from a 0.5% THC plant only where representative-sample analysis supports that threshold and required particulars are labelled;
• interstate or overseas seed requires reasonable steps by the recipient licensee to confirm substantially equivalent analysis and labelling;
• growers and researchers must record strains or varieties, seed and plant sources, deliveries, planting, supplies, disposal and destruction as soon as practicable and no later than seven days after the information becomes available;
• seed handlers must record seed source, quantity, delivery, denaturing, carrier and supply information as soon as practicable and no later than seven days after the information becomes available;
• growers and researchers must notify an inspector about planting within 14 days after planting cannabis seed;
• growers and researchers must notify an inspector that plants are ready for THC testing at least four weeks before intended harvest;
• researcher licence research plans must include details prescribed by the Regulation;
• monitoring fees, inspector travel and sample-analysis costs may apply.

Project implication:

• For historic Stanthorpe Shire producers, Queensland licensing is not a one-off fee. It creates an operating system around seed sourcing, site/activity authorisation, fit-and-proper status, records, notifications, testing, monitoring and renewal.
• Producer budgets should include time and possible advisory cost for licence selection, application preparation, close-associate and executive-officer checks, criminal history/fingerprint processes, site/activity documentation, seed verification, planting notification, harvest-testing notification, record keeping, renewal, amendments, monitoring, inspector travel and sample analysis.
• Queensland licence duration is up to three years, shorter than the usual NSW five-year licence period, so renewal frequency should be reflected in producer economics.
• GBLC demonstration or research activity in the historic Stanthorpe area may require early licence planning, especially if the activity involves research cannabis, a research plan, seed handling, trial plots or activity conducted with partners.
• Approval-processing time is still not quantified from the reviewed Queensland Act, Regulation or Business Queensland page. It remains a separate follow-up item for Biosecurity Queensland guidance and later grower evidence.

Queensland Cost and Time Burden Notes

Source IDs: S003, S022, S057, S058.

Business Queensland's current page, last updated 31 July 2025, identifies the following fees:

Cost item	Amount or treatment	Project relevance
Grower licence application	$1,430.23	Direct establishment cost for a Queensland producer.
Grower licence renewal	$1,161.71	Renewal cost where production continues.
Researcher licence application	$2,129.47	Relevant to trials, breeding and research partnerships.
Researcher licence renewal	$1,723.84	Relevant to ongoing research activity.
Seed handler licence application	$477.47	Relevant where seed is stored, denatured, manufactured or traded.
Seed handler licence renewal	$477.47	Relevant to ongoing seed-handling activity.
Licence amendment or condition change	$323.27	Relevant where sites, conditions or activities change.
Monitoring of an activity	Regulation lists 322.05 fee units per hour	Potential inspection or compliance cost; convert to dollars using current Queensland fee-unit value if applied.
Inspector travel and sample analysis	Regulation notes travel and analysis costs may apply	Variable compliance cost.

Business Queensland states that applicants must contact Biosecurity Queensland to discuss licensing needs and obtain forms. It also states Biosecurity Queensland assesses whether the applicant is fit and proper, and that applicants must provide criminal history and bankruptcy clearance information. The page identifies additional requirements including security, mandatory record keeping and notifications.

Indirect cost categories to include in producer economics:

• Producer time to contact Biosecurity Queensland, obtain forms and prepare the licence application.
• Time and possible advice to determine whether a grower, researcher or seed handler licence is required.
• Time and possible external expertise to prepare a research plan, where relevant.
• Time and possible legal or compliance advice to address criminal history, bankruptcy clearance, fit-and-proper status, security, licence conditions and cross-border supply.
• Costs of security measures, mandatory record keeping, notifications and compliance monitoring.
• Possible analyst or NATA-accredited laboratory costs for THC analysis.
• Opportunity cost if approval timing, monitoring, sample analysis or licence amendment delays planting, harvest, sale or supply.

Project implication:

• Queensland producer budgets should include the grower licence application fee, renewal fees where applicable, amendment fees, monitoring/sample costs and compliance administration time.
• Approval-processing times have not yet been quantified from the reviewed Queensland material. This remains a follow-up item for Biosecurity Queensland guidance and later grower interviews.

Local Planning and Development-Consent Notes

Source IDs: S046, S047, S048, S049.

This follow-up was completed as an initial desktop planning scan. It does not replace property-specific planning advice, because approval requirements depend on the exact lot, zone, overlays, proposed buildings, earthworks, access, water infrastructure, vegetation impacts and whether any processing or industrial activity is proposed.

Tenterfield Shire, NSW

The Tenterfield Local Environmental Plan 2013 (Tenterfield LEP) identifies Zone RU1 Primary Production as a rural production zone. In the RU1 land-use table, Extensive agriculture and Intensive plant agriculture are permitted without consent. The NSW planning definition of extensive agriculture includes commercial crop or fodder production, while intensive plant agriculture includes irrigated crops, horticulture, turf farming and viticulture.

Planning implication for industrial hemp:

• Field production of low-THC hemp on appropriately zoned RU1 land is likely to fall within Extensive agriculture or, where irrigated, Intensive plant agriculture. On that basis, ordinary crop production itself is unlikely to require local development consent in RU1 land.
• This does not remove the separate NSW DPIRD low-THC hemp licence requirement.
• Development consent or other approvals may still be required if the proposal includes buildings, structures, storage facilities, processing, change of use of an existing building, subdivision, demolition, earthworks, works near waterways, road/access changes or other development not covered by the agricultural use permission.
• Tenterfield Shire Council states that building, renovating, changing the use of a building, demolishing, subdividing or placing a structure/building/temporary structure on land generally requires a development application unless an exempt or complying pathway applies.

Project implication:

• For producer budgets, ordinary field cultivation should not automatically carry a local DA cost in Tenterfield RU1 land.
• A planning due-diligence line should still be included for any proposal involving sheds, drying, storage, packing, processing, farm-gate sales, signage, new access, water infrastructure, earthworks or non-RU1 land.
• Phase 3 grower questions should ask whether council planning advice was sought and whether any development consent, construction certificate or other approval was required.

Historic Stanthorpe Shire / Southern Downs, Queensland

The historic Stanthorpe Shire area is now administered under Southern Downs Regional Council. The Southern Downs Planning Scheme (Version 5) is the current local planning instrument for the region and is regulated under the Planning Act 2016.

The Southern Downs Planning Scheme defines Cropping as premises used for growing plants or plant material for commercial purposes where dependent on soil cultivation. The definition includes harvesting, storage and packing of produce and plants grown on the site and ancillary repair and servicing of machinery used on the site. Examples include grain production, fodder and pasture production and plant fibre production. In the Rural zone table, Cropping is accepted development. The Rural zone table also identifies Intensive horticulture as accepted development if it is not a mushroom farm.

Planning implication for industrial hemp:

• Field production of industrial hemp in Southern Downs rural land is likely to be treated as Cropping, with plant fibre production expressly included as an example. On that basis, ordinary hemp crop production is likely to be accepted development in the Rural zone.
• This does not remove the separate Biosecurity Queensland industrial cannabis licence requirement.
• Planning risk increases where the proposal moves beyond field production and on-site storage/packing of crop grown on the site. Processing, off-site product intake, manufacturing, industrial uses, significant buildings, worker accommodation, new access, major earthworks, water infrastructure or overlay-affected work may trigger code assessment, building approval, operational works approval or another approval pathway.
• Southern Downs Regional Council states that development assessment is undertaken under the Southern Downs Planning Scheme and identifies online mapping, planning scheme codes, development assessment forms and pre-lodgement meetings as tools for applicants.

Project implication:

• For producer budgets, ordinary field cultivation should not automatically carry a local planning-approval cost in Southern Downs Rural zone land.
• Budgeting should include a planning due-diligence allowance where production includes infrastructure, processing, drying, storage beyond ordinary on-site crop handling, road access, water works or activity on constrained/overlay land.
• The project should treat historic Stanthorpe evidence as current Southern Downs planning evidence unless a proposal depends on historical approvals or site-specific legacy conditions.

Overall planning conclusion

Local planning does not appear to be a major barrier to ordinary field cultivation on appropriately zoned rural/agricultural land in either Tenterfield or historic Stanthorpe/Southern Downs contexts.

However, development-consent and planning-cost risk remains material for:

• non-rural zones or constrained/overlay land;
• farm buildings, drying sheds, storage sheds, packing facilities or structures;
• processing or manufacturing beyond ordinary on-site crop handling;
• road access, parking/loading or traffic-generating activity;
• subdivision or boundary changes;
• earthworks, dams, irrigation infrastructure or waterway works;
• clearing or biodiversity impacts;
• farm-gate sales, signage, tourism or education activities;
• worker accommodation or demonstration sites.

Therefore, local planning should be treated as a proposal-specific due-diligence item rather than a blanket approval barrier.

Food Standards and Seed Foods

Source IDs: S004, S005, S006, S007, S069.

FSANZ states that the Australia New Zealand Food Standards Code was amended in 2017 to permit sale of low-THC hemp seed foods. Queensland Health guidance and FSANZ material indicate that lawful food products are seed-derived, and that foods made from leaves, flowers, buds, stems or other plant parts are prohibited for food.

Standard 1.4.4 provides the exact legal exception for Cannabis sativa seeds and seed products. The permission is narrow and does not legalise all hemp or cannabis-derived foods.

Cannabis sativa seeds may be sold as food or used as a food ingredient only if:

• the seeds are seeds of low-THC Cannabis sativa;
• the seeds contain not more than 5 mg/kg of total THC;
• if the food is for retail sale, the seeds are non-viable and hulled;
• the only cannabinoids in or on the seeds are naturally present.

Seed products may be sold as food or used as food ingredients only where they are extracted or derived from seeds of low-THC Cannabis sativa, the only cannabinoids in the product are those naturally present in or on the seeds, and the relevant THC limit is met:

Product category	Total THC limit
Oil extracted from seeds of low-THC Cannabis sativa	Not more than 10 mg/kg
Beverage derived from seeds of low-THC Cannabis sativa	Not more than 0.2 mg/kg
Any other product extracted or derived from seeds of low-THC Cannabis sativa	Not more than 5 mg/kg

For this section of the Code:

• low-THC Cannabis sativa means the leaves and flowering heads do not contain more than 1% delta-9-tetrahydrocannabinol;
• total THC means the total amount of delta-9-tetrahydrocannabinol and delta-9-tetrahydrocannabinolic acid;
• hulled seeds means seeds from which the outer coat or hull has been removed;
• non-viable seeds means seeds that are not able to germinate;
• seeds includes part of a seed;
• for seed-product permissions, seeds of low-THC Cannabis sativa includes viable and unhulled seeds.

Standard 1.4.4 also sets a cannabidiol limit and labelling/representation controls:

• cannabidiol must not be present in any food for sale at a level greater than 75 mg/kg;
• a hemp food product must not be labelled or otherwise presented in a way that suggests a psychoactive effect;
• labels must not include a nutrition content claim or health claim about cannabidiol;
• labels must not include an image or representation of any part of the Cannabis sativa plant other than the seed;
• labels must not include the words cannabis, marijuana or words of similar meaning;
• labels may include the word hemp.

FSANZ's survey of low-THC hemp seed foods reports that testing was conducted across six Australian jurisdictions and New Zealand in 2019 and 2021. FSANZ reports 96% of products tested complied with total THC limits.

Project implication:

• Hemp seed food is a legally recognised product category, but market demand, price and producer viability still require separate evidence.
• The lawful food pathway is seed and seed-product specific. It should not be conflated with leaves, flowering heads, CBD oil, medicinal cannabis, recreational cannabis or foods fortified with cannabinoids.
• Product labelling, THC/CBD limits, seed viability, hulling, product testing and import testing should be treated as supply-chain compliance issues.
• Producer demand evidence should distinguish between grain/seed buyers, oil processors, beverage manufacturers and other seed-derived product processors because the Code applies different THC limits to each product category.

APVMA and Chemical-Use Regulatory Note

Source IDs: S034, S075, S076.

APVMA maintains PubCRIS for registered agricultural and veterinary chemical products and a permits database for off-label, emergency, minor-use or research uses. APVMA states that permits can allow use of chemicals contrary to label instructions or use of an unregistered product in certain circumstances.

This follow-up reviewed the current PubCRIS data extract and APVMA permits database on 10 June 2026. The PubCRIS dataset was used to identify registered product-label uses for host code IH1 (INDUSTRIAL HEMP). APVMA permit searches and direct APVMA permit PDFs were then checked for current industrial hemp or hemp permits.

Registered product-label uses identified in PubCRIS

The PubCRIS host table includes false hemp-text matches: HEMP and HEMP1 refer to peppermint, not industrial hemp. The relevant host code identified in the dataset is IH1, described as INDUSTRIAL HEMP.

The IH1 host-use table contained 316 use rows and 26 product codes. Of these, 23 product codes joined to current registered product records in the PubCRIS product table. The joined current product records are dominated by herbicides, plus one fungicide seed treatment.

Product or active group identified	Product type	Industrial hemp use indicated in PubCRIS	Evidence note
Pendimethalin products, including 330 g/L, 440 g/L and 455 g/L products	Herbicide	Multiple weed uses, including annual grasses and broadleaf weeds, depending on product	Multiple registered product records identified against IH1; product labels and state control-of-use rules still need to be checked before budgeting or grower advice.
Trifluralin 480 g/L products	Herbicide	Multiple annual grass and broadleaf weed uses, depending on product	Several registered product records identified against IH1; some product codes in the host-use table did not join to current product records and should not be treated as current without label confirmation.
Fluazifop-P products	Herbicide	Annual and perennial grass weed uses	Two registered product records identified against IH1.
Fludioxonil + metalaxyl-M seed treatment	Fungicide seed treatment	Fusarium/root rot/wilt or damping-off uses	One registered seed-treatment product record identified against IH1.

This result means industrial hemp is not a crop with no registered chemical pathways in Australia. It does not mean that all products are suitable for all hemp varieties, production systems, states, markets or end uses. Product labels, withholding periods, maximum residue limits, buyer specifications, state control-of-use rules, organic status and crop-safety cautions still need to be checked before any economic or agronomic conclusion is drawn.

Current APVMA permit pathways identified

APVMA permit records identify additional permitted pathways for particular hemp uses. The following direct APVMA permit PDFs were current by their stated in-force dates on 10 June 2026:

Permit	In force to	Persons who can use	Product or active pathway	Key limits and cautions
PER95564	31 May 2027	Persons generally	Clethodim for selected grasses; alpha-cypermethrin for selected insect pests in industrial hemp	All states and territories except Victoria. Clethodim must be applied before flowering and no more than once per crop. Alpha-cypermethrin is limited to no more than two applications per crop, has a 21-day harvest withholding period, and must not be sprayed on flowering plants while bees are foraging. Crop safety has not been fully evaluated for all conditions.
PER86924	30 June 2027	Persons generally	Bromoxynil, haloxyfop, diquat, nucleopolyhedrovirus of Helicoverpa armigera, indoxacarb and chlorantraniliprole for hemp	All states and territories except Victoria. Covers selected weeds, Helicoverpa and related uses. Includes crop-safety cautions, a specific warning not to apply bromoxynil to Finola, withholding periods and grazing restrictions that vary by active.
PER94780	31 October 2026	Persons generally	Azoxystrobin and bifenazate for industrial hemp grown for fibre only	Allows control of selected fungal diseases and mites. Treated produce must not be used for human consumption, treated crops must not be grazed or fed to livestock, aerial application is prohibited, bifenazate cannot be applied with backpack equipment, and no more than one application per crop is allowed.
PER94808	31 December 2028	Persons engaged in industry-funded research in industrial hemp	Tau-fluvalinate + myclobutanil product and bifenazate for protected industrial hemp grown for fibre	Research/protected-crop pathway only. Treated produce must not be used for human consumption, treated crops must not be grazed or fed to livestock, and no more than one application per crop is allowed.

The live APVMA permit portal search for current agricultural permits returned PER94780 and PER94808 for industrial hemp on 10 June 2026. Direct APVMA permit PDFs for PER95564 and PER86924 also state that those permits are in force. PER13792 was checked because it had previously appeared relevant, but the current APVMA PDF reviewed on 10 June 2026 is for green tea and does not mention hemp; it has not been included as an industrial hemp production permit.

Project implication:

• Industrial hemp chemical-use claims cannot be assessed only from general statements that hemp needs few chemicals.
• Registered and permitted chemical pathways exist for industrial hemp, including herbicide, insecticide, fungicide/miticide and seed-treatment pathways.
• Several permit pathways are narrow: some are fibre-only, protected-crop-only, research-only, non-human-consumption, non-grazing, state-limited or subject to crop-safety cautions.
• The claim that industrial hemp requires fewer chemicals than realistic alternatives remains unresolved. Legal availability of chemical options does not prove high or low chemical use; later agronomic and grower evidence must compare actual weed, pest and disease pressure, crop density, cultivation, herbicide tolerance, buyer residue requirements and local alternatives.
• Producer budgets should include both possible chemical costs and possible non-chemical weed-control costs until local production systems are better evidenced.

Immediate Follow-up

1. Completed initial review of the NSW Hemp Industry Act 2008, Hemp Industry Regulation 2016 and September 2025 licence manual. Remaining NSW checks: confirm typical approval-processing times and actual producer time burden through official advice or Phase 3 grower evidence.
2. Completed initial review of Queensland Drugs Misuse Act 1986 Part 5B and Drugs Misuse Regulation 1987 Part 4. Remaining Queensland checks: confirm typical approval-processing times, actual producer time burden and practical application of monitoring/testing requirements through Biosecurity Queensland guidance or Phase 3 grower evidence.
3. Completed initial review of Food Standards Code Standard 1.4.4 for exact hemp seed food requirements. Remaining food-standard checks: assess processor/buyer specifications, testing practices, labelling controls and import/export compliance requirements.
4. Completed APVMA PubCRIS and permits database scan for currently registered or permitted agricultural chemicals for industrial hemp. Remaining chemical-use checks: confirm current labels before any budget or advice, test product suitability with agronomist evidence, check residue and buyer requirements, and compare actual input use against realistic local alternatives.
5. Complete property-specific local planning checks for any proposed grower site, processing site, demonstration site or GBLC activity. The initial Tenterfield and Southern Downs desktop planning scan is complete.
6. Seek official or practitioner evidence on typical NSW and Queensland approval-processing times.
7. During Phase 3, ask growers how much time, external advice and approval delay they experienced.