UN Ban on HHC: What It Means for Spain

Statement following the recent international ban on hexahydrocannabinol (HHC)

Madrid, 13 March 2025.

From 10 to 14 March, the 68th session of the United Nations Commission on Narcotic Drugs is taking place in Vienna, Austria.

One of the items scheduled for a vote was the inclusion of new substances in the schedules of the international conventions, both the 1961 Single Convention and the 1971 Convention on Psychotropic Substances.

Specifically, it was proposed to include the molecule hexahydrocannabinol (HHC) in Schedule II of the latter treaty. According to the UNODC (United Nations Office on Drugs and Crime) itself on its notice board, this inclusion has been approved.

See the UNODC announcement

Once the Commission on Narcotic Drugs has concluded, the official resolution will need to be reviewed to determine the details of the control and its specific regulatory implications.

Before control of hexahydrocannabinol (HHC) becomes effective nationally, an internal process must be completed. This involves the Ministry of Health receiving the official notification, assessment by the competent authorities and the subsequent amendment of Royal Decree 2829/1977 by ministerial order. Only after its publication in the BOE will the control have legal effect in Spain.

As we reported in previous weeks, even before this measure was adopted by the Commission on Narcotic Drugs, Spain already had a project under way to amend Royal Decree 2829/1977. This amendment includes hexahydrocannabinol (HHC) and its derivatives, as well as other substances unrelated to HHC, which means that Spain had already planned to classify them as controlled substances in its domestic law.

Specifically, the substances to be included are:

• Hexahydrocannabinol (HHC)
• Hexahydrocannabinol acetate (HHC-O; HHC acetate)
• Hexahydrocannabiphorol (HHCP)
• Hexahydrocannabiphorol acetate (HHCP-O; HHCP-O acetate)
• Delta-8-tetrahydrocannabiphorol (delta-8-THCP; JWH 091)
• Tetrahydrocannabiphorol (delta-9-THCP; THCP)
• Tetrahydrocannabiphorol acetate (THCP-O; delta-9-THCP-O acetate)
• Tetrahydrocannabinol acetate (THC-O; delta-8-THC-O acetate)
• Delta-8-tetrahydrocannabinol-C8 (delta-8-THC-C8)
• Delta-9-tetrahydrocannabinol-C8 (delta-9-THC-C8)
• Hydrocannabidiol (H4-CBD; tetrahydrocannabidiol)
• Other substances included in the amendment of the Royal Decree that are unrelated to cannabinoids

We will keep you informed about how this process develops and its impact on Spanish regulation.

S&F Abogados.