Therapy Tonics

From The CEO

By in From The CEO Comments Off on Reading into Coca-Cola’s recently publicized interest in the cannabis market

Reading into Coca-Cola’s recently publicized interest in the cannabis market



*This Op-Ed written by Christopher Coggan was first published by San Diego Daily Transcript on Oct. 22nd


It was recently reported that Coca-Cola was eyeing the cannabis market. As one might expect, cannabis stocks saw a meaningful spike in value with the news of yet another giant international beverage company considering the move into cannabis. Unlike Constellation Brands before them, makers of the popular Corona beer who have recently invested billions in Canopy Growth, Coca-Cola’s inquiries seem more conservative and focused. Coca-Cola’s interest lies in the non-psychoactive Cannabinoid CBD (Cannabidiol), one of the over 100 active cannabinoids naturally occurring in cannabis. Studies show that this phyto-cannabinoid, CBD, is a powerful promoter of the body’s own endocannabinoid system comprised of a network of receptors that regulate an individual’s anti- inflammatory response.
In other words, these recent headlines, although exciting, are not telling the entire story (quite the contrary, they are supplementing the truth with media hype). The type of cannabis strain most commonly associated with CBD is not cannabis (aka marijuana), but rather industrial hemp. Although both hemp and cannabis share the Latin name of Cannabis Sativa, these two plant variations are treated as separate and distinct, that distinction primarily determined by the potency of psychoactive THC. If a cannabis sativa plant contains less than 0.3% THC, the plant is
considered industrial hemp. This is important because industrial hemp faces a varied and somewhat murky regulatory environment compared to the regulated state cannabis markets. The Drug Enforcement Administration (DEA) for example, the CBD that is derived from it a schedule I narcotic, much like THC. The California Department of Public Health has recently come out to
support that position, even though the unregulated hemp CBD market in California might even exceed $1 billion annually. The hemp round table, a consortium of hemp farmers and manufacturers, believes that hemp and it’s bi-products are protected by the 2014 Farm Bill. They also have the opinion that CBD is an unscheduled cannabinoid and should be treated like a nutritional supplement. Then of course, you have a handful of pharmaceutical manufacturers that are in various stages of the patent and trial process on CBD-based drugs. To muddy the waters further, the U.S. government owns a patent on CBD.

Clearly, Coca-Cola courting anything connected with marijuana is an incredibly telling sign of the times. Yet, even though their conversations with Canada-based Aurora Cannabis (ACBFF) seem indicative of the headlines born from these negotiations, their comments suggest that their focus is more on the potential of hemp-derived CBD beverages. And there is good reason for this. As a publicly-traded company on the New York Stock Exchange, Coca-Cola is regulated by the Securities and Exchange Commission (SEC) and is also governed by a host of other expectations dictated by the federal government. Consequently, their ability to engage cannabis directly in the U.S. is severely limited. Coca-Cola’s calculated engagement means a lot more than the headlines suggest, especially as it relates to the hemp CBD marketplace. The fact that one of the largest beverage companies on the planet is considering moving in this direction suggests a base line shift in the

perception of existing federal law and perhaps more importantly, a harbinger of anticipated changes in federal policy. The Senate’s version of the 2018 Farm Bill includes an amendment that would legalize hemp production, resulting in a clear divide between hemp and its psychoactive counterpart, cannabis. Coca-Cola’s interest
currently is no coincidence; new federal policy appears to be a forgone conclusion.


This Op-Ed was first published by San Diego Daily Transcript on Oct. 22nd



Christopher Coggan
Founder/CEO Therapy Tonics & Provisions, Inc
Chairperson, CCIA Manufacturing Committee



By in From The CEO Comments Off on Santa Rosa Public Hearing Testimony

Santa Rosa Public Hearing Testimony

To our esteemed patients and customers,

I recently provided testimony at the final Office of Manufactured Cannabis Safety,  California Department of Health public comment hearing in Santa Rosa, Ca regarding the proposed regulations. I have provided a transcript of that testimony for your consideration. It is so important that we work, united, in efforts to ensure practical regulation in California.

Best regards,

Christopher Coggan – CEO


Good Morning, thank you for having me. My name is Christopher Coggan and I am the founder of Therapy Tonics and Provisions. We specialize in cannabis Infused, ready to drink, specialty coffee and teas, made with organic, non-GMO ingredients. We currently operate out of La Jolla, California.

As a member of the CCIA manufacturing committee, I’d Like to thank the California Department of Health and the Office of Manufactured Cannabis Safety for being mindful of our advice as manufacturers in the drive towards regulations that are practical and effective. We share the common goal of ensuring safe access for patients and providing a fertile environment for evolution and innovation in this growing multi-billion-dollar industry.

That said, I believe there are several proposed regulations that are ill-conceived and threaten to limit access to both medical and adult use consumers, significantly increasing costs and stifling innovation in what will be the largest cannabis market in the world.

I would like to focus on Section 40300 in the proposed regulation text entitled “prohibited products”. Firstly, it is important to note that none of these regulations exist in a vacuum, but rather in the real world.

In the real world, California is a state of great diversity, but many of the defining characteristics are embodied by what California Board of Tourism captures in there marketing efforts, which is best summed up as the California lifestyle. Extrapolating on this, we are a progressive, forward-thinking state defined by active lifestyles and the healthy choices that promote and support these lifestyles.

That said, I find it hypocritical that a state known for cold-press, organic juices, fresh, farm to table choices, and the ‘got milk?’ advertising campaign, would restrict access to the very ingredients that many of our residents have come to depend on in the mainstream marketplace. The proposed elimination of fruit and vegetable extracts or juices, as well as dairy is counterintuitive to this market, a market that has been borne from alternative medicine and a holistic approach to health and wellness.

If I were to guess, over 80% of infused products currently available today would either disappear completely or have to compromise their formulas to accommodate these poorly considered prohibitions. The results for consumers would be catastrophic. Gone would be many of the products that have come to depend on. Gone would be the growing number of healthy choices and organic ingredients. Gone would be the innovative spirit that accompanies the cannabis industries drive for alternative, healthier forms of medicating.

What exactly replaces dairy or a fruit-derived substitute like coconut milk in a chocolate bar?

What replaces a fruit-derived sweetener in a beverage?

What we would be left with is a greatly reduced selection of products, filled with synthetic, processed ingredients and preservatives. In many ways, this completely compromises the values of Californians as well as the progressive choices that accompany the turn to alternative medicines and the holistic approach to health.

Add to this the prohibition of all products that are not shelf stable, and you have severely curtailed patient’s choices and destroyed the innovative spirit of our industry.

To reiterate, this is the real world. Refrigeration has been a common feature of every American household since the 1950’s and as savvy consumers turn more and more towards fresh and organic alternatives in the infused cannabis market, the dependence on temperature controlled options will increase exponentially.

I believe that any product that follows existing food safety standards through the production, distribution, and storage process should be available to cannabis consumers. For example, my company’s drinks are produced and packaged in accordance with current FDA guidelines as well as the health and safety standards as defined by the state of California.

In closing, it is important to note that this industry has self-regulated rather effectively for the last 20 years in California. Long before the state made any effort to monitor our manufacturing or regulate our processes, we stepped up to the plate and took on that responsibility ourselves.

In the real world, you are not regulating a new industry, you are regulating a maturing industry. Guided by existing food safety standards, our own principals, and commitment to safe access for patients, we provide the state a clear roadmap to regulation through example. Please embrace our knowledge and address our concerns to ensure that California leads the nation and the world in this emerging and innovative Cannabis economy.