Response to the Proposal to Include HHC on the UN List of Prohibited Substances

The Institute for Rational Addiction Policies expresses its strong objections to the proposal to classify hexahydrocannabinol (HHC) under Schedule II of the 1971 Convention on Psychotropic Substances. The decision will be made by the United Nations Commission on Narcotic Drugs (CND) at its March 2025 session. We believe this step is not only procedurally flawed but also substantively unjustified and contrary to modern approaches to regulating psychoactive substances.

1. Critical Flaws in the WHO Evaluation Process

According to Article 2 of the 1971 Convention, any decision by the UN Commission on Narcotic Drugs to include a substance in one of the schedules must be based on a WHO assessment, which must include information in three key areas:

• The extent or likelihood of abuse
• The severity of public health and social problems related to use
• The therapeutic usefulness of the substance

However, the WHO’s Critical Review from October 2024 fails to provide this essential information. The report lacks adequate data on the dependence and abuse potential of HHC, relies instead on isolated case reports from a few countries, and entirely omits information on its therapeutic applications. Any decision made in the absence of this required information could be legally challenged and would undermine the credibility of the international drug control system as a whole.

2. Unjustified Criminalization of a Safer Alternative

HHC is structurally, pharmacologically, and in terms of risk profile comparable to THC – a substance that an increasing number of countries are decriminalizing and regulating. Classifying HHC as a prohibited substance would mean international law starts criminalizing a substance that may, in fact, be even safer than THC. This move is not only illogical but also contradicts the modern trend toward regulated control of psychoactive substances, rather than prohibition.

3. The Czech Regulatory Model as an Innovative Alternative

In 2024, the Czech Republic adopted a new regulatory framework for psychoactive substances (Act No. 321/2024 Coll.), which introduced a new legal category of psychomodulatory substances – defined as substances that "do not pose serious risks to public health or significant social harm to individuals or society." This model represents a modern approach that moves away from ineffective prohibition toward controlled regulation. Rather than being suppressed by international restrictions, this model should serve as an inspiration to other countries. Classifying HHC as a psychotropic substance would directly contradict the Czech law, as current evidence clearly supports that HHC fits the definition of a psychomodulatory substance.

4. The Czech Government’s Position on HHC

In December 2024, the Czech government rejected the inclusion of HHC among narcotic and psychotropic substances. Instead, it placed HHC on a newly created list of Controlled Psychoactive Substances—a precautionary list that prohibits trade while allowing further scientific evaluation. A comprehensive assessment of HHC and other natural and synthetic cannabinoids is to be completed by June 2025, after which a decision will be made about their final classification, including the possibility of listing them as psychomodulatory substances. This cautious, science-based approach acknowledges the fact that HHC has not been linked to serious health issues or an addiction epidemic.

5. The International Context and the Need for Drug Policy Reform

The Czech model of regulating psychomodulatory substances is among the first serious efforts to create a modern, evidence-based system for controlling psychoactive substances—one that stands in stark contrast to the outdated prohibitionist model established over 60 years ago. The current system persists largely because states lack viable alternatives to prohibition. The Czech Republic is filling this regulatory gap and is beginning to be recognized internationally as a progressive example.

Rather than expanding prohibitionist measures, the CND should initiate a debate on reforming the international control system—one that enables an evidence-based approach to psychoactive substances, guided by current scientific knowledge rather than outdated ideological visions of a "drug-free world."

Conclusion

In light of the above, we call on UN member states to:

• Request additional information from the WHO on HHC and ensure a thorough risk assessment is conducted.
• Suspend the process of scheduling HHC as a controlled substance due to the deficiencies in the current evaluation.
• Consider new approaches to regulating low-risk psychoactive substances intended for non-medical human use, following the example of the Czech model for psychomodulatory substances.

It is time for the international community to stop repeating the mistakes of the past and begin applying an evidence-based approach to the regulation and control of psychoactive substances—one that genuinely protects public health and reduces societal harm.

Institute for Rational Addiction Policies stands ready to contribute to further expert dialogue on this issue and provide relevant scientific input.