The Curious Case of the Flower Dragon


The Curious Case of the Flower Dragon – Med Alert – PGR Peddlers in Lala Land

New Material Added 17 Sep 2011 = Lab Test Results on Flower Dragon, Phosphoload, Top Load, Gravity and Bushmaster.

Author’s note: Flower Dragon, Phosphoload and Top Load were all issued with notices of stop sale in California in May of 2011. All three products were found to contain Daminozide (AKA Alar). ALAR is BANNED FOR USE IN ANY CONSUMABLE CROP. In this article I mention Prohexadione as the suspect PGR. As it turned out Flower Dragon was Superbud rebranded.Other PGR based products also banned in California and Oregon include Bushmaster and Gravity. Bushmaster and Gravity were found to contain Paclobutrazol.

Above: Part of the CDFA Quarantine and Recall Notice. Note, “Threat to public safety”.

CDFA Lab Test Results in Brief

Flower Dragon: 18,400-18,650ppm Daminozide, 30-46.3ppm Paclobutrazol
Phosphoload: 17,800ppm Daminozide, 20.6ppm Paclobutrazol
TopLoad: 3,467ppm Daminozide
Bushmaster: 271ppm Paclobutrazol
Gravity: 516ppm Paclobutrazol

LAB RESULTS (FOIA Data obtained from CDFA)

PDF Downloads

Flower Dragon


Top Load



Full FOIA papers including recalls and other

I will be posting the last chapter in this story shortly, so stay tuned! (She’s a doozey!!)

For now…..


Daminozide is considered a hazardous substance according to OSHA 29 CFR 1910. 1200. The EPA lists Daminozide as a “probable human carcinogen”. Combustion products include: carbon monoxide (CO), carbon dioxide (CO2), nitrogen oxides (NOx), and other pyrolysis products typical of burning organic material. Combustion may emit poisonous fumes. Daminozide is an S5 poison.

Daminozide is produced by reacting succinic acid ahydride with unsymmetrical dimethylhydrazine (UDMH also known as 1,1-Dimethylhydrazine). UDMH is toxic, a carcinogen and can be readily absorbed through the skin.

Although Daminozide is the active ingredient, UDMH is also present as a contaminant in both technical and formulated products. UDMH can also be present in products through hydrolysis of Daminozide and this increases as a function of time and increasing temperature. The formation of UDMH from Daminozide residues is known to occur during cooking of apples and metabolism data has shown that Daminozide hydrolyzes to UDMH in plants and in the mammalian body.
Daminozide was initially registered as a pesticide in the United States in 1963 for use on potted chrysanthemums. The first food use, apples, was registered in 1968.

In July 1984, the EPA initiated a ‘Special Review’ of pesticide products containing Daminozide based on findings that Daminozide and its degradate and metabolite, unsymmetrical dimethylhydrazine (UDMH), were oncogenic (caused the growth of tumors) at multiple organ sites, in multiple species and strains of test animals. The Agency issued a ‘Data Call-In’ in 1986 requiring additional toxicology and worker exposure data. As a result of the Special Review, the registrant, Uniroyal Chemical Company, voluntarily cancelled all food use registrations of Daminozide on November 4, 1989. The EPA revoked the tolerances (maximum residue limits) for food uses in March 1990. There are no longer any registered food or feed uses of Daminozide, and all tolerances have been revoked. The EPA had calculated the hazard of cancer among people exposed to UDMH in Alar for a lifetime is 45 per million, which is 45 times as high as the one-in-a-million hazard EPA considers “negligible.”

In fact, Daminozide is perhaps one of the most controversial agrochemicals ever, eclipsed only by Agent Orange, after the “Alar scare” in 1989 in which a CBS 60 Minutes USA show labeled Alar “a potent human carcinogen”, resulting in the near bankruptcy of the US apple industry. Prior to 1989, five separate, peer-reviewed studies of Alar and its chemical breakdown product, UDMH, had found a correlation between exposure to the chemicals and cancerous tumors in lab animals. In 1984 and again in 1987, the EPA classified Alar as a probable human carcinogen.

The use of Daminozide in any consumable crop is, therefore, illegal. The dangers it poses when used to grow a short-term decidious crop, which is then ingested via inhalation, are unknown (cannabis consumers being the lab rats of shady hydroponic manufacturers and distributors who falsely market Daminozide as “phytominerals”, “citrates”, tartarates”, “arginates” and “rare earth elements”).


Paclobutrazol (CASRN 76738-62-0) is classed as a herbicide/pesticide PGR. Paclobutrazol is an S5 poison. Its use is prohibited in many EU countries. The WHO lists Paclobutrazol as “Moderately Hazardous”, while the US EPA lists it as “not classifiable as to human carcinogenicity” with:

“Substance Name — Paclobutrazol

This substance/agent has not undergone a complete evaluation and determination under US EPA’s IRIS program for evidence of human carcinogenic potential. “


Paclobutrazol is a triazole type plant growth retardant which blocks gibberellin biosynthesis and are involved in reducing abscisic acid, ethylene and indole-3-acetic acid while increasing cytokinin levels. It promotes fruit set in the states of inhibited development. It is also known that it protect plants against abiotic stresses.

In plain English (laymans terms) this means Paclobutrazol is a systemic growth regulator that reduces internode lengths of new shoots and causes earlier formation of terminal buds. It is used primarily as a plant growth regulator for turf grass, grapevines, trees (non fruit variety), and apple, stone fruit and mango trees. Paclobutrazol has reasonably long withholding periods (dependent on application rates and crop type). In some cases, control of growth may persist for more than one year. Typically, however, withholding periods are listed with registered Paclobutrazol products at between 20 and 40 days.

Paclobutrazol has been shown to be an environmental contaminant (Kathrin Reintjes et al 2006). In field situations, paclobutrazol is shown to have a half-life ranging from 3 to12 months (Lever 1986) or 12 to 18 months, although some have reported persistence as long as 3 years (Jacyna and Dodds, 1995). Some commercial greenhouse operations have had issues dealing with chemical residues.1

The persistence of Paclobutrazol in soil may result in contamination of nearby water bodies, thus presenting a possible hazard to human and animal health, and could also influence soil microbial activity with further effects on biodiversity.2

The hazards (if any) of using Paclobutrazol on a short-term deciduous crop that is consumed via combustion (i.e cannabis) are completely unknown.

  2. Sybille Neidhart, Anuwat Jaradrattanapaiboon, Kathrin Reintjes,Berit Jöns, Martin Leitenberger, Joachim Ingwersen, Gunnar Kahl, Pittaya Sruamsiri,  Thilo Streck, and Reinhold Carl (2006) Which risks do result from the application of paclobutrazol in off-season mango production regarding residues in fruit and soil? First results of a long-term field study in northern Thailand

The Question

“Is it acceptable to produce medicine using systemic pesticides that are known to be harmful to human health?”

According to Colorado legislators, who are currently implementing standards/regulations over medical marijuana licenses for growers and distributors, the answer to that would be a very definite no.


“The following chemicals which have been banned by federal and state
agriculture authorities shall not be used in the cultivation of marijuana for
medical purposes by Licensees. Possession of chemicals and/or containers
from these chemicals upon the licensed premises shall be a violation. These


And according to Americans for Safe Access.

“We would certainly not condone medical marijuana produced using banned chemicals…. Given its relatively unregulated production, this is not too surprising if not frustrating. Hopefully current efforts to test cannabis will expand and eventually prevent such contamination in the future.”

The Problem

PGR based products halt the upward (apical) growth of a plant, thus giving cannabis growers control over the height of the plant and keeping nodes close and encouraging dense bud-set.

This is desirable for many indoor growers who wish to grow numbers of shorter plants (e.g. SOG and Coliseum/Vertical growing) or growers who work in areas with limited ceiling height.

Additionally, PGR products can increase yields where cannabis plants are grown in less than ideal conditions. This means that inexperienced growers or growers who fail to optimize their environments (temp, RH, airflow, nutrition) can achieve higher yields. This said, where growers do optimize environments, PGRs such as Daminozide reduce yields (not to mention resin production/quality).

Products such as Flower Dragon are often popular with large commercial cultivators. Large commercial cultivators are responsible for large amounts of commercially available cannabis. As a result, cannabis consumers are unwittingly buying potentially PGR tainted cannabis throughout Australia, North America, the UK, and Europe.

In Australia, where PGR flowering additives first became available through hydroponic stores, large numbers of cultivators now produce cannabis using PGRs. The US and other countries are in danger of mirroring this situation.

The illicit status of cannabis and the high profits associated to the cultivation and sale of cannabis creates a situation which doesn’t lend itself to a strong code of ethics amongst some cultivators and suppliers (this statement extends to elements within the med industry, including growers/suppliers and dispensaries). Due to this, even when cannabis growers are aware that PGR products may contain potentially harmful actives some will choose to use them regardless. In short, only a reprobate would choose to use PGRs without warning their clients/consumers that this is the case (would you like Alar with that?). This said, the cannabis culture, due to the illegal status of the “drug”, attracts more than its fair share of reprobates. Quid pro quo!

Let’s not lose sight of the fact that greed can be a powerful motivator.

Arguments put forward by PGR proponents include cannabis is a carcinogen and, therefore, growing with a “potential” carcinogen and then selling the produce to unsuspecting consumers shouldn’t be an issue (your mother must be very proud of you); or, the product I use that immediately ceases upward growth isn’t proven to be a PGR (you’ve just “proven” it you dickhead); or, PGRs aren’t an issue if you use them 30 days before harvest (and you would know this how?); or, the potential risk of harm to consumers is outweighed by the gains (financially of course – you’re making Monsanto look very good!); or, no one has proven to me that PGRs are dangerous (this is hardly the point – all evidence suggests their use is problematic and it isn’t up to regulators to prove agrochemicals are dangerous, but instead up to the companies who sell/develop these products to prove they are safe before putting them to market).

Sadly, many of these PGR proponents who contaminate medicine with carcinogenic chemicals would also pass themselves off as “care givers” (the author knowing several such people).

Additionally, the hydroponics retail industry is an industry that remains largely unregulated. This has enabled unethical manufacturers, wholesalers and retailers to act unhindered by regulatory codes/consumer protection policies. In fact, the hydroponics industry is guiltier than most. In spite of the evidence, some of the largest wholesalers continue to openly distribute cannabis specific PGR products which they must know contain potentially harmful actives. Further, they distribute these products via highly deceptive marketing with doctored MSDS.

Similarly, the med industry is one that remains unregulated. This situation means that medicinal users – just some of whom are amongst societies most vulnerable – remain largely unprotected by unscrupulous operators. However, it is the med industry that looks to be regulating with moves on in Colorado to implement rules that govern medical marijuana growing practices. Just one product that cannot be used is Daminozide. Perhaps here, they can finally protect the deemed to be federal criminals (med users and growers) from the antics of the seemingly morally bankrupt and only just legal hydroponics industry. Of course, based on the practices of creating doctored MSDS and not listing actives this is perhaps overly optimistic. Just how are regulators supposed to know if any given product contains one of the banned for use substances listed in their regulations?

Furthermore, a legal paradox comes into play (Catch 22). That is, it is illegal to use Daminozide on ANY consumable crop. This said, cannabis is an illegal crop and is, therefore, not legally recognized as a consumable crop (even though it is consumed by millions of people worldwide and is deemed by authorities to be the largest consumable cash crop in many parts of the world where officially the same authorities deem it not officially consumed… wow!). Due to this, cannabis consumers are not consuming a consumable crop… As a result, regulating the sale of long banned Daminozide for use on “any consumable crop”, through the hydroponics industry, becomes an administrative black hole. Take for example our recent case. Daminozide is banned for use in any consumable crop under EPA law. However, while California has acted, based on fertilizer registration laws, the EPA or FDA whose brief it is to police the use of Daminozide on consumable crops are nowhere in sight.  Theoretically, this means that if Flower Dragon and others were registered for use on non-consumable crops, listed actives, perhaps gave instructions for use with Geraniums and provided safety instructions and MSDS they could be made legally available through Californian hydro stores. Of course, we all know that at $120 a pop Geranium growers would be knocking down hydro store doors (call me sardonic – i.e. characterized by irony, mockery, or derision). This aside, officially, no one is using Daminozide to cultivate cannabis, except in Colorado, where someone is finally ‘officially’ regulating medicine (confused yet? ).

Additionally, while Daminozide containing products are now banned in California and Oregon they remain widely available in other US states (et al). This of course means that Daminozide products remain widely available throughout the US because anyone in California and Oregon can purchase interstate, via the internet, and have Flower Dragon, Phosphoload or any of the other numerous PGR products delivered to their door.

Feasibly, many millions of cannabis consumers, on a global basis, are being exposed to cannabis grown with PGRs. Given that 40% (125,000,000) of American’s are estimated to have smoked cannabis in their lifetimes, with a percentage of these being regular marijuana users, the US alone accounts for millions of cannabis consumers who may be exposed to cannabis grown with PGRs. As med users are typically regular users, who often purchase from multiple sources (different strains from the same dispensary coming from multiple sources of origin etc), this places them at high risk.

What do we actually know about the outcomes of using PGRs on a short-term deciduous crop that is ingested via combustion? We know that many PGRs have long withholding periods. We know that no hydro industry PGR product has been registered with the appropriate efficiency data to support its safety (sleight of hand registrations for use on berry crops discarded). In the case of Daminozide, we know that it is banned due to its potential as a human carcinogen. However, the fact is, very little is known about PGRs and how they affect plant biology and the dangers involved . And this is why we need to be concerned. Less is known than is known.

A few callous manufacturers (reprobates thinnly disguised as businessmen) slapped systemic pesticides into bottles, promoted them with the most reprehensible marketing conceivable (poisons thinnly disguised as organic) and began playing Russian roulette with the lives of cannabis consumers. Call it for what it is….

Deceptive Marketing – The Smoke and Mirrors of HydroLand  

PGR products are typically promoted as organic. This creates confusion amongst the cannabis culture as to the implications of using these – stated to be – organic products. While many growers are aware that they are using PGR products many are left in the dark as to just what is in these products with some even believing organic components such as kelp have the ability to cease upward plant growth.

For example, Humboldt Countys Own Bushmaster is sold listing “Active Ingredient: 1.5% Ascophyllum Nodosum (Sea Kelp).

And Gravity is marketed with this:

“Our uniquely prepared kelp extract and phosphorus based additive will harden your flowers from the top to the bottom. A little goes a long way. Use once or twice about 3 weeks before the end of a plant’s cycle. Adds size and weight to flowering plants.”

As for Flower Dragon (Paclobutrazol and Daminozide)

“… This highly specialized mixture of selected rare earth elements and phyto nutrients supports your newly supplied bio available phosphorous by helping focus your plants internal energies into flowering, producing large abundant flowers, without the necessary lag…… a process commonly known as “Speed Shifting”. To do this Flower Dragons harnesses the amazing natural power of Arginates and Rare Earth Elements (REE’s). These unique phyto nutrients synergistically work with our micronutrients to allow your plants their most naturally rapid transition into flowering”

And Dutchmaster Phosphoload (Paclobutrazol and Daminozide)

“Dutch Master PhosphoLoad utilizes a new technology which extracts unique isolates from coal derived humates. These are powerful earth elements that unlock the floodgates for a fast & powerful flowering response. When used, PhosphoLoad produces dramatically larger and heavier yields of flowers with an average yield increase of 25 to 30%. “

While the onetime Superbud (Paclobutrazol and Daminozide) was marketed as

“SUPERBUD is the most innovative & powerful flowering additive to hit the market EVER!

SUPERBUD utilizes a new technology which extracts unique isolates from coal derived humates. These Humatic Isolates are powerful rare earth elements that, when combined with Dutchmasters propriety Phospholipid Technology, unlocks the floodgates for a fast & powerful flowering response.

The unique combination of elements helps your plants finish the growing cycle extremely quickly without the usual lag period that occurs when you turn your light cycle down to initiate flowering.

The Phospholipid Technology (first incorporated in Dutch Master Folitech) then increases or switches the flowering receptor sites on, which then allows these Humatic isolates to exert their powerful flowering effect.

Plants flowered with SUPERBUD stop their upward growth almost immediately & start to form numerous, tight and heavy clusters of flowers that continue for many weeks.

Growers who use SUPERBUD report larger heavier yields of flowers with an average yield increase of 25 to 30%. “


One of the greatest promoters of Superbud, prior to its recall in 2003, was a moderator, Feral, from the now defunct medical marijuana forum Natures High ( Feral, a larger than life character, had been promoting Superbud to Natures High members for some time, mirroring Dutchmasters claims that Superbud was a 100% organic and safe product. In 2003, when it became apparent that Superbud was anything but organic, Feral became the most ardent attacker of Superbud during the internet campaign against it. By this time he had undoubtedly convinced many of the other members of Natures High (and others) to use Superbud, leading med growers to believe (in line with Superbud’s marketing) that Superbud was organic.

His first post in the campaign against Superbud read:

“from the day of it’s release, the makers of superbud, dutchmaster, claim no harmful ingredients are used in its manufacture. today i find out that sb uses a pesticide used in the hydroponic lettuce. industry, untill being banned as it contains

have we been had?????? independent analysis says yes.
the inventor looked tm in the eye and stated that there was definatley no harm full additives. holy shit, they lied by the looks of it.

steven carruthers, owner of the publication “hydroponics aust” found out and stands to loose alot of advertising revenue blowing their cover. he feels it his duty to the public to make info(as my duty to tell yous). dutchmaster spend big dollars with him, not for long by the looks of it. good on him. the hydro industry is well pissed off here as they pride themselves on a pesticide free grows. this WILL smear the industry.
this is hot off the press.

PLEASE DON’T PANIC!!! i have stopped using it today though.
the full report of this product will be available to me next week.
sorry, please don’t shoot the messenger!!!!!!

if this is rite i am going to call for a ban on dutchmaster products for missleading us.”

Posting dated 16/10/2003

The rest is now history in what became the biggest shitfight on cannabis forums ever . Legends were made, myths found their origins, reputations were ruined, and Dutchmasters Superbud juggernaut was given a dose of Kryptonite (well, not quite – Phosphoload was available within weeks).

Author’s note: Feral was wrong on several points. Given the histrionics, the hydro industry does not pride itself on pesticide free grows and while the hydro industry was “pissed off”, this anger was directed towards those who had exposed Superbud. Additionally, Feral and others were only aware of the Paclobutrazol found in Superbud after British industry interests – competitors of Dutchmaster – in collusion with an Australian company set up Steven Carruthers to be the bagman in the Superbud affair. What was unknown to these British industry interests was that Daminozide, which they hadn’t tested for, was present in much larger volumes. This information was privy to only a few (myself included) and was buried to minimise fallout which could harm the reputation of the hydroponics industry. Years on and millions in Superbud/Phosphoload/Flower Dragon sales later, with the benefit of hindsight, this decision was clearly a mistake. Hence, to clear up a few myths.

  • Paclobutrazol is not the key active in Phosphoload or Flower Dragon. Daminozide is the key active in Phosphoload and Flower Dragon. While Paclobutrazol is also present, it is present at low levels.
  • Paclobutrazol is not a known carcinogen. This myth found its origins during the Superbud affair.
  • Daminozide is a “probable human carcinogen” and is banned for use in any consumable crop.

Author’s note 2: Ferals largest yields (an increase of 30 – 40%) would come some time later when he switched from wide channel NFT growing to coco. These yields were achieved without PGRs. Today Feral – albeit under a new tag – remains an ardent campaigner against PGRs. While the author, in this article, has been hard on the growers who choose to use PGRs it has been his honour to have witnessed the culture itself mobilise against these poisons.

The Daminozide Money Trail

Let’s analyze for a moment how much money is made by those promoting PGRs as “rare earth elements”, “citrates”, “arginates”, “quinalone” (a new one to me), “humatic isolates”, “kelp” etc to unsuspecting consumers.

The math…

1 gram of pure substance in 1L equates to 1000ppm. Given Flower Dragon contains 18,400ppm of Daminozide this equates to 18.4 grams per litre of Daminozide at 100% purity in 1L (solute (Daminozide) + solvent (water) = 1L).

Recently, for the purpose of this article, I priced purchasing 100Kg of Daminozide from a Chinese supplier. The product was 850 grams a kilo Daminozide or 85% purity.


To achieve 18,500ppm of Daminozide in solution with the Chinese product it would require 21.76g/L. Based on this, 1Kg of 85% Daminozide would produce 45.95 litres of Flower Dragon. The price of the Chinese product at 100Kg was $97.00 USD per Kg. Add shipping and other costs to this and we could conservatively estimate that Daminozide costs ex China $98.50 USD per kilo landed in BC, Canada where Flower Dragon is produced. Let’s be generous and make that $100 USD per 1Kg of Daminozide. Therefore, 100 Kg of Daminozide costs $10,000 USD ex China to BC. Don’t get hung up on the math. It’s largely irrelevant. The end result is the important thing (for those of you wishing to check my math feel free).

Okay, so we know that 1Kg of 85% Daminozide produces 45.95 litres of Flower Dragon and 1Kg of Daminozide costs $100 USD. Therefore 1L of Flower Dragon requires $2.17 of Daminozide (I.e. 100 ÷ 45.95 = $2.17 USD).

Let’s also add twenty cents in Paclobutrazol (PBZ being cheap and used at low levels), $1.00 per plastic bottle used in production and $1.50 for labels. Total cost to produce 1L of Flower Dragon = $4.87 (round that off to $5.00 for ridiculously low levels of P and K that are also added in production).


100 kilo of 85% purity Daminozide makes 4595.5 litres of Flower Dragon or 4595.5 1L bottles of saleable product. Total cost to produce equals $22, 977 USD based on $5.00 per bottle estimate.


Flower Dragon retails in the US for $120.00. We have 4595.5 1L bottles each retailing for $120.00. 4595.5 x $120.00 = $551,460.00 from an initial investment of  $22, 977. Therefore, the profit made along the way equates to $528,483.00 or roughly 2,300%.


Wholesalers typically mark up products 30% and retailers typically have markups of 100% on consumables. Based on this, Flower Dragon is sold to the wholesalers for about $45.00 (a $40.00 profit for Envy Plant Products or a 900% profit and $40 x 4595.5 = $183,820.00 on 100Kg of Daminozide = $165,4380.00 in profits); wholesalers then sell to retailers at $60.00 (4595.5 x $20 = $91,910) and finally retailers Flower Dragon to consumers for $120.00 (4595.5 x $60 = $275, 730).


Of course, I’ve oversimplified this somewhat because people have rents to pay etc. The aim, however, is to demonstrate the incredible sums of money that are made through the sales of these products.

What is most important to note here is the vast amount of profits generated all flow to the top of the Daminozide pyramid. That is, wholesalers make 30%, retailers make 100% and Steve Berlow et al make 900% on 100% of all Flower Dragon sales across the US et al. Technically speaking, this amounts to millions of dollars earned very quickly from lies, more lies, more lies, and banned for use in any consumable crop, Daminozide (aka Alar).


Let’s look at some industry products and the jargon that is used to promote them. I.e. a reality check.

First off the block: A product named Flower Dragon. I originally found this product on Ikon Internationals website – the largest hydro wholesaler/distributor in the UK. In the US it is being distributed via National Garden Wholesale (the largest wholesaler stateside – a division of Sunlight Supply Inc).

What sparked my interest was the awe-inspiring name and Ikons listing; “Flower Dragon MANUFACTURED BY (Not Specified)”.

 “Not Specified”? I wonder why?

The promo for the product:

“Flower Dragon is a new kind of flower booster. The easiest most powerful flower booster you have ever used. Simply use Flower Dragon at 3ml per litre during week 3 of flower. It’s that easy!!! …Developed by leading plant physiologists, bio-chemists and plant performance researchers from around the world – Flower Dragon will leave you absolutely gob smacked!”

It did – I reasoned that “leading plant physiologists, bio-chemists and plant performance researchers from around the world” would have better things to do for humanity than develop marijuana-growing products (call me a cynic).

Author’s note for the US: “Gob smacked” is a British term. Its’ definition first appeared in writing in the mid 1980’s. ‘Gob’ is of Scottish Gaelic origin meaning beak or bill. Gob has long been used in Northern regions of Britain as a word for mouth. E.g. “Shut your gob”. So to be gobsmacked is to be struck dumb as if by a smack in the mouth. MacMillan Dictionary defines “gobsmacked” as: adjective, British informal… surprised, shocked, amazed, speechless, astonished.

Linguistics aside, let’s dig deeper.

On the (name withheld) Hydroponics website they advertise Flower Dragon with.

“Flower Dragon mineral base flowering supplement.”

Not really. Its minerals are listed as 0- 0.15- 0.30.. Based on its NPK listing it’s little more than water, at least at first glance.

It is important to note that under US standards, P is listed as P2O5 and K is listed as K20. Given this, Flower Dragon’s elemental NPK ratio is 0- 0.0645- 0.249 or, 645ppm of P and 2,490ppm of K. This would deliver approx 7.47ppm of K and 1.9ppm of P when diluted at 3ml/L in solution. When you consider that tap water typically contains approx 1.6 – 2.0 ppm of P and 7- 40ppm of K, tap water contains more NPK than this $120.00 product.

They then go onto state:

A similar product to Rox or Superbud.”

Intrigued, I fired off an email to (name withheld) Hydroponics to inquire further.

Their response;

“Flower dragon is a great product and the feed back we are getting bnack (sic) is nothing but good. Flower dragon however is a legal product.”

Ok. I responded with:

“Thanks for the response, so what actives are listed??? What is the approval number??? Who is the manufacturer? Because on Ikon’s site they specify “Not Specified” … Please explain!”

Their response… actually, it all went a bit quiet. Nothing! No response. Dead silence! Hmmm?

Not to be deterred, I then went to Flower Dragons homesite @

The site looked fantastic!! A fully animated/interactive Flash site with slick design but nothing there to indicate a manufacturers name, other than “Copyright Flower Dragon”. They did, however note:

“We are a select group of industry leading experts and professionals who felt that there was a better way. A better way to research, a better way to develop and provide, “real” yield changing technologies that you can see, touch and feel…“Together we have over 100 cumulative years of industry specific expertise behind us.”

I for one was impressed: 100 years of experience (wow!) but who is the mysterious Flower Dragon?

On the site they also provide usage instructions for Flower Dragon; actually, several options. Among them:

Hydroponics: Use Flower Dragon for 1 week between weeks 2 and week 5 of flowering. Add Flower Dragon at the rate of 3ml to 5ml per litre of made up nutrient solution. Dump and replace your nutrients as you normally would at the end of that week.

The Power Sprint
Spend longer in Veg than most for a bigger, better structured plant (4 weeks minimum) Need to pick up some time and some size. Try this Power Flower Method!
How it works: Add Flower Dragon to system after you have introduced your plants to flower at a rate of 6ml/gallon of nutrient/water for the first two weeks – then continue with regular nutrient feeding program.

The Double-Hitter
Size counts, but quality matters too. A combination of the two can be even more satisfying. Use this combo routine for maximal size and quality!
How it Works: Add Flower Dragon to system at week 4 for 1 week return to your regular feeding program and then reapply for 1 week when you are 2 weeks out from harvest. Finish as you normally do.

Wow – “the double hitter” and “The Power Sprint”…. Sounds like a sports supplement.

Hmmmm …. To the experienced eye Flower Dragon is looking more and more like a PGR. Prohexadione (3,5-dioxo-4- propionylcyclohexanecarboxylate) perhaps? Without active ingredient listing, registration, and MSDS, which would be standard practice in the legitimate agricultural sector, it remains largely guesswork. Let’s take a punt though – there’s no harm in guessing. After all, they fail to list actives – guesswork is all we have.

Prohexadione acts in a similar way to Alar (Daminozide) and like Alar, before it was banned in 1989 for use on any consumable crop, Prohexadione, a new GA biosynthesis inhibitor (gibberellin inhibitor), is now being used as a PGR in the apple industry to reduce vertical growth (apical dominance) and regulate budset. Further, Prohexadione is being used in the grape industry and other areas of agriculture as an insecticide and/or PGR. The APVMA (Australia) list an approved and trialed Prohexadione product as having a 56-day (8 week) withholding period while the EPA list another Prohexadione product as having a 45-day (6.5 week) withholding period. Acylcyclohexanedione (the base to Prohexadione) is synthesized from 1,4 Cyclohaxandione (or Tetrahydraquinnone). 1,4 Cyclohaxandione is an organic intermediate used in the making of various actives in pharmaceuatical, herbicides and various organic products. 1,4 Cyclohaxandione is a diketone and has two carbonyl groups. Chemical jargon aside…

Bottom line – Prohexadione isn’t suitable for use in a short-term deciduous crop (e.g. cannabis) and where PGRs are concerned this is about as good as it gets (re withholding periods).

FLower Dragon displays two products on their website. One, ‘Bio Sorb PK’ and the other, ‘Phyto Mineral Mix’, the latter being the impressive –albeit curious- Flower Dragon of which we speak.  Their promo:

Bio Sorb PK utilizes 3 cutting edge compounds – citrates, tartarates and phosphates – that when paired with soluable phosphorous – radically and immediately Bio Activates the plants supply of phosphorous…. This immediate increase in available energy results in a dramatic increase in your plants flowering potential and yields by unlocking the floodgates to the plants energy pool…. (The also note) “Citrates and Tartarates: Increases phosphorous uptake potential by over 300%”” (Wow!!! 300% – is that even biochemically possible?)

Phyto Mineral Mix
“Giving Flower Dragon it’s unique “Blood Red” colour This highly specialized mixture of selected rare earth elements and phyto nutrients supports your newly supplied bio available phosphorous by helping focus your plants internal energies into flowering, producing large abundant flowers, without the necessary lag…… a process commonly known as “Speed Shifting”. To do this Flower Dragons harnesses the amazing natural power of Arginates and Rare Earth Elements (REE’s). These unique phyto nutrients synergistically work with our micronutrients to allow your plants their most naturally rapid transition into flowering”… (Wow!)

 OK , let’s briefly touch on the jargon… Citrates – they sound incredible but our mystery company is probably talking about citric acid that can act as a mild chelating agent, as a buffer, and as an acid to reduce pH (C Integral Hydroponics, Edition 4). Or they could be talking about sodium citrate. Or, they could be talking about potassium citrate as a source of K or ammonium citrate used as a buffer. One big question mark and some extravagant claims about a cheap to purchase and commonly used component when it all comes down to it.

Citric Acid is a sequestering (chelator) and stabilizing agent.

Citric Acid is a colourless crystalline organic compound and belongs to carboxylic acid family. It exists in all plants (especially in lemons and limes) and in many animal tissues and fluids. In biochemistry, it is involved in important metabolism of almost all living things; the Krebs cycle (also called citric acid cycle or tricarboxylic acid cycle), a part of the process by which living organisms (e.g. plants) convert food to energy. Citric acid works as a preservative (or as an antioxidant) and cleaning agent in nature. It is commercially obtained by fermentation process of glucose with the aid of the mold Aspergillus niger and can be obtained synthetically from acetone or glycerol.

The three carboxy groups lose protons in solution; resulting in the excellent pH control as a buffer in acidic solutions. Citric Acid also chelates metals (citrates chelate metal ions) and, for this reason, is an ideal organic chelator in nutrient formulations. C Integral Hydroponics, Ed 4 to see how it is used as a organic pH down agent.

Let’s move on….

Tartarates – presumably they’re talking about tartaric acid or potassium tartrate. Tartaric acid is a white crystalline diprotic organic acid – it occurs naturally in many plants.  Other than this, it is one of the most common acids found in wine. Tartaric acid adds to the tart flavor of some wines, hence the term “tart”. Tartaric acid (tartrate) also acts as a mild organic chelator and like citric acid is used in the biochemical process by the plant to chelate nutrients so they can move freely throughout the plant. I.e. Upon entering the plant the metal will immediately become chelated by organic acids such as citric acids, malonic acid, tartaric acid (tartrate), and some amino acids (e.g. glycine), which occur naturally within the plant. This biochemical chelation process will then enable the nutrients to move freely inside the plants to areas where they are needed. The addition of both tartaric acid and citric acid (“Krebs cycle metabolites” as one company would have you believe) may prove beneficial in some formulations where organic acid chelation is required (note: I’ve oversimplified the chemistry more than a lot because both acids may also prove pointless in situations where adequate chelation, via EDTA and DTPA, EDDHA, fulvic acid and an array of other chelators, is concerned).

Phosphates: This is where things go from the sublime to the ‘are you kidding?’ A phosphate is an inorganic chemical. Inorganic phosphates are mined to produce phosphorous. Phosphorous is used in nutrient and additive formulation. Along with potassium, phosphorous is highly beneficial to flowering plants (e.g. cannabis). Innumerous flowering stimulants (e.g. PK 13-14 etc) contain phosphorous and potassium. Flower Dragon state,  “…phosphates – that when paired with soluable phosphorous – radically and immediately Bio Activates the plants supply of phosphorous….”

What? Is this alien technology? Typos aside, this simply makes no sense at all.


ARGINATES: This mineral form is bound to the amino acid arginine. It is able to penetrate the cell and deliver the mineral specifically to the plasma and inner layer of the outer cell membrane (at least at a human physiological level).  It’s typically a term used in bioscience and/or medicine but isn’t used with regards to plant physiology and mineral nutrition. Arganine is an amino acid found in plant and animal protein involved in the conversion of ammonia to urea. Unless there is a spelling error and they mean ‘alginates’ or ‘aliginic acid’ which is a polysacharide and is found in kelp and brown algae. ‘Aliginic acid’ is used as a thickener, usually as sodium alginate much like gums and agar. Again though we are left wondering.

Bottom Line: Impressive jargon that ultimately is little more than perplexing dribble when deconstructed at a chemical level.

OK – now for rare earth elements (REE). I’ve left the best to last.

REE first appeared in hydro stores via a South Australian company named Dutchmaster. Dutchnmaster have somewhat of a reputation for misleading consumers. They released a product named Superbud in about 2000 with:

“SUPERBUD is the most innovative & powerful flowering additive to hit the market EVER!
SUPERBUD utilizes a new technology which extracts unique isolates from coal derived humates. These Humatic Isolates are powerful rare earth elements that, when combined with Dutchmasters propriety Phospholipid Technology, unlocks the floodgates for a fast & powerful flowering response.
The unique combination of elements helps your plants finish the growing cycle extremely quickly without the usual lag that occurs when you turn your light cycle down to initiate flowering.
The Phospholipid Technology (first incorporated in Dutch Master Folitech) then increases or switches the flowering receptor sites on, which then allows these Humatic isolates to exert their powerful flowering effect.

Indeed! However, what Dutchmaster failed to mention was Superbud’s real secret lay in two chemical PGRs; one of which was paclobutrazol and the other of which was Alar – the latter of which was banned for use in any consumable crop in 1989 after a massive controversy in the US (The Alar Scare). We’ll talk more about Superbud shortly (stay tuned).

For now…back to “Rare Earth Elements (REE)”.

Wikipedia defines “rare earth elements” as:

“…rare earth elements or rare earth metals are a collection of seventeen chemical elements in the periodic table, namely scandium, yittrium, and the fifteen lanthanides. Scandium and yttrium are considered rare earths since they tend to occur in the same ore deposits as the lanthanides and exhibit similar chemical properties.

The following abbreviations are often used:

  • RE = rare earth
  • REM = rare earth metals
  • REE = rare earth elements (Hey there we go!)
  • REO = rare earth oxides
  • LREE = light rare earth elements (La-Sm)
  • HREE = heavy rare earth elements (Eu-Lu)”

Impressive stuff but technically, at least from an agricultural perspective – pointless.

On the other hand, U.S. military technologies such as guided bombs and night vision rely heavily upon “Rare Earth Elements (REE)”. Unfortunately the US military is having a hard time getting hold of “rare earth elements” (hence “rare”) probably as a result of “leading plant physiologists, bio-chemists and plant performance researchers from around the world” sucking them all up for use in cannabis growing products (Call me ‘sardonic’ I,e, characterized by irony, mockery, or derision)

Let’s move on…

Many rare earth elements are toxic and/or are heavy metals.

Their chemical symbols:

La, Ce, Pr, Nd, Pm, Sm, Eu, Gd, Tb, Dy, Ho, Er, Tm, Yb, Lu

However, I suspect (pray) what Flower Dragon are discussing is fulvic acid (a very common component that is used in many additives). Fulvic acid typically carries 70 or more minerals and trace elements as part of its molecular make up. Plants readily absorb high amounts of fulvic acid, and maintain it in their structure. Fulvic acid is an excellent chelator. , It forms four-point bonds with the elements it chelates, but unlike the synthetic agents it can be absorbed into the plant. This adds to the mobility of the nutrients. The nutrients chelated by fulvic acid can move more freely which prevents a number conditions like localized calcium deficiency that can happen due to low mobility of nutrients.

Fulvic acid is very impressive stuff and I know that I incorporate fulvic acid in many of my formulations (as do many nutrient formulators). But let’s not be deceived —– “select rare earth elements”? (C’mon!)

Just some elements/minerals that are found in fulvic acid:

Calcium, Ruthenium, Thallium, Cobalt, Indium, Nickel, Samarium, Thorium, Barium, Copper, Iodine, Niobium, Scandium, Thulium, Beryllium, Dysprosium, Osmium, Selenium, Erbium, Iron, Palladium, Silicon, Titanium, Boron, Phosphorus, Silver Lead, Platinum, Vanadium, Gadolinium, Lithium, Potassium, Strontium, Ytterbium, Calcium, Gallium, Lutetium, Praseodymium, Sulfur, Yttrium, Cerium, Germanium, Manganese, Rhenium, Tantalum, Zinc, Cesium, Gold, Magnesium, Rhodium, Tellurium, Zirconium ……

But consider this. To hit optimum fulvic acid target ppm in solution you would use approximately 40ml of 8% fulvic acid concentrate added to 960ml of water. This would give you a 1L concentrate product (similar to something you buy in hydro stores) that would then be used at approximately 2ml/L in the nutrient tank/reservoir.

Next…consider this: many of these so called rare earth elements are at such low ppm levels in fulvic acid that their presence in a nutrient (given dilution) is negligible. E.g. Yittrium is a rare earth element that is found in fulvic acid… Yttrium exists at approx 0.1ppm (in concentrated fulvic acid). Hence, given our 1L concentrate + dilution rate = 0.0002pmm. I’ve oversimplified this for reasons of conjecture – this number is likely to be far lower, which is probably a very good thing. That is, Yittrium is likely to be a threat to the environment and public health. I.e. Yittrium has not been demonstrated to be an essential element for plants. It is, however, a contaminant/effluent around nuclear reactor sites, and research has demonstrated that some plants will uptake yittrium when it is present at approx 1ppm in solution/soils.

Other than yittrium, rare earth elements, namely lanthanum and cerium, have been studied for their benefits on plant growth. The findings:


“Conclusions: La and Ce did not enhance the growth of corn or mungbean, but decreased the growth, root function and consequently the nutritional status of mungbean at concentrations >0·2 µM in solution…. While La and Ce had similar effects on plant growth, Ce was more detrimental than La to the uptake of Ca and Na by corn.” 1

Bottom line: What we’re left with, at best, is pure jargon; no substantial NPK ratio’s or other substantial ingredient listings, no contact details for the manufacturer on their site, no MSDS, and no idea who these “leading plant physiologists, bio-chemists and plant performance researchers from around the world” are. Impressive… I for one am left “gob smacked!” (At least on this front Flower Dragon aren’t kidding)

Not to be deterred, I scoured the web for more information, this time looking for US suppliers. One store in Dayton, Ohio listed it as Atami Flower Dragon. Uh huh, I thought, so maybe Netherlands based Atami –fronted by Erwin Rossario- is behind the mysterious Flower Dragon.

I sent the store an email to confirm the new information:

“Hi, I’m just wanting to know more about Flower Dragon. I saw on a UK site that it’s similar to Superbud.  But the problem is that no one else seems to be saying this and I want to get hold of something that acts in a similar way to superbud (reduces height) but isn\’t so aggressive. Have you had any feedback on Flower Dragon yet? It says on your site that Atami makes it. Is this correct? I used to use their biostimulants years ago and they were great! There doesn’t seem to be much on the internet about it but the Flower Dragon website looks fantastic…

Best regards

Their response:

Hello ..,

Yes Atami does make it.  You may check out National Garden Wholesale (NGW) for more info.  We have not sold a lot yet but the few that have got it have came back for more.  Thats always a good sign.

(name withheld)

OK – so Atami makes it. Puzzle solved (or, at least I thought). I then went to NGW’s website to confirm the information. Nothing about Atami and the promotional material contained the same information that I had read on the UK site. Confused, I shot back another email.

 “Hello…, thank you for getting back to me. So I’m a bit confused – is Flower Dragon similar to Superbud in that it stops upward growth and promotes dense flowers? I looked at the NGW site but it didn’t say much about what it actually does. I’ve also looked at the Flower Dragon site, which BTW is impressive. Nothing about Atami though on either NGW or the FD site. .

It too doesn’t actually say that it stops upward growth and induces heavy flowerset which is what I’m really looking for. It’s quite pricey and I want to be sure it’s similar to Superbud in the effect it has on plants.

Best regards”

Their response:

“HI ….
I am not sure if it is similar to that product.  I may have been misinformed about Atami.  The bottle says manufactrued by Envy Plant Products Inc.   in BC Canada.  The bottle dosen’t say much about the product either.

(name withheld)”

OK this is getting confusing but at least I now have a company name – Envy Plant Products Inc, BC. The problem is I’ve never heard of them. I get 4 hits on google – all of them linked to Flower Dragon being sold online via hydroponic stores. A Canadian company search on the BC government company listing website does, however, tell me that Envy Plant Products Inc is a registered company in BC.

I then sent off an email to (name withheld hydroponics) in California to see if I could learn more.

Their response:

Hello  (pseudonym)

Yes, Flower Dragon is similar to Superbud however when all is said and done it is more effective and user friendly.  Unlike Superbud/Phosphoload, Flower Dragon does not contain paclobuzatrol (plant growth regulator in superbud/phosphoload known to cause cancer).  This product is truly unique and I suspect you will be hearing alot about it over the next few years.  You can order this product on our website if you want to give it a shot.  If not feel free to stop by one of our three retail stores located in California.

(name withheld)

OK, so we now have two stores – one in the UK and one in the US- who are comparing Flower Dragon to Superbud (also known as Phosphoload in North America). I won’t go into the implications of the paclobutrazol and cancer comments (other than to right a wrong and say that paclobutrazol is not known to be a human carcinogen – on the other hand, Alar is and it is Alar that makes up the bulk of Superbud as active).

I responded with:

“Thanks  (name withheld). Is it organic? The only info they seem to provide is it is a mineral based product but it lists 0- 0.15- 0.30 which is really not a lot of minerals. Sorry to bother you but it is very expensive
and I just want to be sure I’m getting my moneys worth.

Best regards”

Their response:

“Unfortunately flower dragon is not organic.  If a product does not have a OMRI (organic materials reviews institute) label it is not certified organic according to international standards.  These labels are difficult to find but can be found in the Organicare and Bio-Bizz nutrient lines as well as a few others.

As far as mineral content goes Flower Dragon is unique in that it contains a lot of micronutrients and heavy metals such as iron, molybdenum, copper, selenium, and zinc.  Feel free to take a look at the following link for public information available on Flower Dragon.  Don’t be discouraged by the heavy metal content (eg. lead, nickel).  If you take a closer look you will find that a lot of your favorite organic fertilizers contain more of these heavy metals than most products.  Please take a look at your states nutrient regulations to find out more about mineral content.”

I took his advice and went to the link he had provided to look at the “mineral content”.

What? “…it contains a lot of micronutrients and heavy metals such as iron, molybdenum, copper, selenium, and zinc. “ he said. Let’s analyze this for a moment.

Micro Nutrient (%)
Boron (B) Nil
Chlorine (Cl) Nil
Cobalt (Co) Nil
Copper (Cu) 0.001 (10ppm)
Iron (Fe) 0.001 (10ppm)
Manganese (Mn) Nil
Molybdenum (Mo) Nil
Sodium (Na) Nil
Zinc (Zn) 0.001 (10ppm)
Total Micros = 30ppm  

Heavy Metals (ppm)
Arsenic (As) 7.7
Cadmium (Cd) 7.39
Cobalt (Co) 7.42
Copper (Cu) 32.7
Lead (Pb) 7.03
Mercury (Hg) 0.388
Total Heavy Metals = 62.628ppm

You must be kidding… right?  There’s technically nothing in it. 30ppm of micros (0.003%w/v) and 60.628ppm of heavy metals (0.0060628%w/v). At this point the author is left dumbfounded!

Bottom line: Flower Dragon is clearly not a “mineral base flowering supplement”. We have a product that seemingly contains nothing (a bit of P and K, minute levels of three micros, and worryingly high levels of heavy metals – C note 1); it is also in breach of Californian labeling standards. I.e. the label states Flower Dragon is a “mineral base flowering supplement” which clearly it isn’t. The label also states “Phytominerals” at its’ base, which is a term typically associated to alternative therapies, skincare and pharmaceuticals. (C note 2)

We also have a retailer who clearly knows nothing about the products he’s selling, and just as little about the chemistry of such products (to equate ppm from %w/v simply multiply by 10,000 – e.g. 0.001 x 10,000 = 10ppm) and another retailer that seems confused by who manufactures the product… “I may have been misinformed about Atami” – (I.e. two retailers who seem clueless).

Author’s Notes:

#1. Flower Dragon has a total of 30ppm of microelements (nothing really) with a total of 62.6ppm of heavy metals (HM). I.e. double the heavy metals to micros. When one considers that a standard horticultural grade solid phosphate fertilizer contains on average 10ppm/Kg of heavy metals, Flower Dragon’s HM numbers are extremely high (over 6 times more than you would expect to find in a component fertilizer used in manufacturing nutrients and additives)

#2. Phyto or Phytohormones are terms typically associated to botany/plants.

Phyto is used before a noun when indicating a plant or vegetation (e.g. phytogenesis, phytotoxicity) so the use of phytomineral is acceptable (linguistics again). Of course, on this basis, phytomineral means the same thing as saying plant mineral, which is the same thing as saying “mineral base flowering supplement”, which is the same thing -in this case- as saying nothing, if you take my point.

At this point, something about this was starting to sound all too familiar.

I.e. Pharmaceutical jargon attached to a, in all probability, PGR based product, advertising material that is truly nonsensical, a product which fails to list actives and, where actives are listed, are patently bogus; an, in all probability, PGR product that is being distributed by Ikon International (UK) and National Garden Wholesale (US) and on-sold to retailers who vis-a-vis are on selling a product that, at the very least, must raise suspicions (nevertheless, at $120USD for a 34 ounce (1L) bottle, who cares I guess)

Bullshit radar bleeping, I commissioned solicitors in BC to access a company listing of Envy Plant Products Inc with Director names. Other than this, I dropped an email to a contact in the Californian State Government Ag Department.  Who is the mysterious Flower Dragon I pondered?

Not to give the game away, let’s rewind this for a moment.


A BRIEF HISTORY: 2003- 2005

In 2003 the shit hit the fan over a product called Superbud™. It was alleged, that Superbud™ contained carcinogenic (or potentially toxic) properties and that the manufacturers of Superbud™ (South Australian company, Dutchmaster/Transloc/Futchatech) had misled consumers by marketing Superbud as a safe and organic product that’s secret lay in their “proprietary phospholipid technology and powerful rare earth elements known as humatic isolates”.

Superbud™ was the most talked about product of ALL time – Dutchmaster’s magic bullet (gold does grow on trees) and their juggernaut into International markets. No product had ever been talked about on forums to this extent before- nothing even came close. A major thread on, the worlds largest online grow community, started by ‘Superbud SOG’ expoused the virtues of Superbud with boasts of massive increases in yields and gold does grow on trees claims etc. What was never exposed on this thread was ‘Superbud SOG’ was a young Dutchmaster employee and was thus promoting his employers product to unsuspecting forum members – an example of how subversive marketing takes place via chat forums (whether cannabis specific or otherwise).

Then in 2003, some British industry members decided to go after Dutchmaster and Superbud™. To cut a long story short they used an Australian industry member to take the fall for them and by the time the affair was over Superbud had been slammed Internationally on just about every internet forum in the world. Like the formidable marketing of Superbud itself – nothing had been this big; it was by far the biggest shitfight in the history of cannabis forums. Once again Superbud was the most controversial and talked about product ever, only this time Dutchmasters reputation lay in ruins.

Superbud would be pulled from the British, Australian, US, Canadian and European markets (or at least they could no longer sell it openly) and Dutchmaster’s reputation would be left in tatters. Their drive into the highly lucrative North American markets was over. Their flagship had been blown out of the water (Superbud –“Is it a bird? Is it a plane?”-  given a dose of kryptonite). Dutch Master would pull out of Canada sometime in 2005 – 2006 (leaving Futchatech behind as their distributor) having lost their campaign for world domination.

Craig Gribble (owner and CEO of Dutchmaster) returned to South Australia with Steve Berlow (Craig Gribble’s right hand man and largely the brains behind Dutchmasters product line and advertising) and built himself a multi million-dollar apartment in Adelaide.

In 2005, Craig Gribble and a Finks MC enforcer would brutally assault Adam Tanton (from SupplyNet International/Phat Filter) after they discovered Tanton was selling counterfeit Superbud on behalf of Hells Angels MC members who have interests in the Australian hydroponics wholesale and manufacturing sectors.

Dutchmaster had released this memo to all Australian hydroponic stores in 2005 – 18 months after Superbud had been (apparently) removed from the market.

The Store Owner

Tuesday January 11, 2005

To whom it may concern,

It has come to our attention that there is a counterfeit Superbud being offered in the marketplace to unsuspecting stores. The product looks almost identical to Superbud but has an incorrect batch code number on the rear label (BN 031108). The counterfeit product also displays a distinct moiré pattern on the rear label (a checkerboard pattern of round dots).
The counterfeit product is not Superbud, was not manufactured by our company & has no association with our company. After laboratory testing of this counterfeit product it was confirmed that the counterfeit product does not contain the same ingredients as the genuine Superbud. As such this product will not perform the same as original Superbud & will only lead to frustration & anger from your customers should you purchase & sell this counterfeit product.
If you have been approached by companies or persons offering this counterfeit Superbud for sale, please contact myself on (08) 8447 1222 to report this matter. All information regarding this matter will remain in strictest confidence.
As the names “Dutch Master” & “Superbud” are registered trademarks; producing, selling or knowingly purchasing counterfeit product for sale is a breach of trademark law and can lead to substantial damages being awarded against those who partake in such activities. Our lawyers have instructed us to collate a list of those who continue to knowingly sell this counterfeit product for future actions.

I thank you for your understanding and cooperation in this matter.

Steve Berlow”


Author’s note: Dutchmaster’s highly acclaimed Plant Physiologist, Dr Deepak, resigned the company in 2003 citing two reasons for the resignation. One was his family were unhappy with him working in, what they perceived to be a shady (criminalized) industry, and the second reason was Dr Deepak (PhD) was unhappy with the direction of Dutchmasters product line. Presumably, this meant he had an ethical and moral crisis with marketing a probable carcinogenic, illegal/non compliant product (s?) as organic and safe to unsuspecting consumers.

Dr. Deepak – of Sri Lankan origin- was hired by Craig Gribble after applying for a job as a retail assistant at an Adelaide Dutchmaster owned store (Hydro Superstore). When the staff saw his CV they took it out to Craig Gribble, who immediately hired Deepak and used his PhD in plant physiology as a marketing tool for the company. Until then Dr Deepak had been selling vacuum cleaners door-to-door.

While ‘Dr D’ (PhD) was applauded as the innovator for the Dutchmaster nutrient line the true story is very different. In fact, it was Steven Berlow who was largely behind the Dutchmaster formulations and likely Steven Berlow who developed Superbud.


In 2009, Australian Federal Authorities raided hydroponic stores and wholesalers across Australia. Their target… non-compliant products, namely PGRs and more importantly Superbud. While details of the raids are sketchy, it seems apparent that the APVMA, in conjunction with the Australian Federal Police, seized numerous products, including the long banned Superbud.

Later the APVMA released this memo to hydro stores around Australia.



Important Regulatory Information for Hydroponic Retailers
If you sell chemical products to the commercial hydroponic industry or to the general public you need to be aware of the laws that govern the sale of such products. Under the Agricultural and Veterinary Chemicals Code of each jurisdiction (collectively, the ‘Agvet Codes’), it is an offence to advertise or supply unregistered agricultural chemical products. These offences carry fines of up to $33,000 for an individual or $165,000 for a company.

Selling plant growth regulators or other hydroponic chemicals in Australia
Agricultural chemical products that might typically be supplied by a hydroponics store and fall under the definition of an agricultural chemical product include: Plant Growth Regulators (PGRs) or products that contain plant growth regulating chemicals, such products can also be described as nutrients, growth boosters, vitamins, hormones and bloom enhancers.  These types of products generally require registration with the Australian Pesticides and Veterinary Medicines Authority (APVMA) as agricultural chemical products.

How do I know if a product is registered?
To check if a product is registered, you need to check the label on the product. Labels on registered products carry an APVMA or NRA approval number. This number is typically found at the base of the rear label panel on the main container. The approval number contains the product number, the pack size identifier and the month and year of initial registration. A typical example might be: APVMA (or NRA): 54321/1kg/0909.

What if I am selling unregistered agricultural chemical products?
It is important to note that as a hydroponic retailer, you have a responsibility to ensure that only registered agricultural chemical products are sold or supplied via your store. The fines and penalties for supplying unregistered agricultural chemical products are significant.

The supply of an unregistered chemical product is an offence under section 78 of the Agvet Codes.
Action that could be taken by the APVMA if a hydroponic store is found to be selling unregistered agricultural chemical products can include compulsory product recalls, compulsory stop supply notices and even criminal prosecution. Fines relating to the supply of an unregistered chemical product can be $165,000 for each offence.”


The Recidivists

Let’s compare some jargon for a moment.

Flower Dragon Phyto Mineral Mix
“Rare Earth Elements”
“Flower Dragon is a new kind of flower booster. The easiest most powerful flower booster you have ever used.

Flower Dragon Bio Sorb PK
“Unlocking the floodgates”

Dutchmaster Superbud
“Rare Earth Elements”
“Unlocking the floodgates”
“SUPERBUD is the most innovative & powerful flowering additive to hit the market EVER!

Could it be? No… Surely not…

The company listing information for Envy Plant Products Inc arrived June 20, 2010. On it:

V6X 8H3

Incorporated on May 13, 2009

Last Name, First Name, Middle Name:
Magowan, Susan Jane

Mailing Address:
Last Name, First Name, Middle Name:
Tagliafierro, Tammy Michelle

So who are these “leading plant physiologists, bio-chemists and plant performance researchers from around the world ” with “a combined 100 cumulative years of industry specific expertise” between them?

Well, to put it bluntly, I for one had never heard of them.

Not deterred, I Googled Tammy Tagliafierro.

From LinkedIn…


  • Operations Manager at Florigen Research Laboratories Inc.


  • Indoor Garden Division Manager at Commercial Lighting Products

Wow! Could this be it? It looked promising. Tammy Tagliafierro was the Division Manager of the indoor garden division at Commercial Lighting Products. It looked as if she was connected to the hydro industry. Now she was Operations manager at Florigen Reseacrh Laboratories Inc.

 Florigen was, until recently, a mythological flowering hormone. The discovery of the molecular nature of florigen was a major scientific breakthrough in 2005.The discovery was made due to DNA technologies, combined with molecular biology/plant physiology research, whereby the florigen gene was isolated in flowering/fruiting plants. Florigen is probably a small protein called FT. FT is produced in the leaves and is transported via the phloem to the shoot apical meristem (SAM). FT acts like a molecular “alarm-clock”, evoking a complex genetic scenario, which culminates in flower formation. The process seems to involve red, far-red, and blue light, the length of the night, and the plant’s biochemical clock. There is still much to be understood about florigen and there is no single ubiquitous hormone that can be used to mimic the florigen response. Genetic research has succeeded, to some degree, in developing mutant hybrid strains of tomato whereby florigen levels were successfully manipulated (through select breeding), inducing early flowerset, and larger and sweeter fruit. This, however, needs to be done at a genetic level (I.e. breeding or through other mechanisms which are far too complex to go into). Put simply, there is no product in a bottle that can trigger (“speed shift”) florigen in a plant.

Florigen Research Laboratories Inc. Now I’m seriously impressed! Perhaps Envy Plant Products Inc have done what DNA research is yet to come to terms with– perhaps they have cracked the Florigen code (‘Florigen Dragon’ , “speed shifting” your plants into overdrive…).

But seriously…

This aside, I then searched for Florigen Research Laboratories and found a BC company listing.


 Business – Licences Approved During Period
From: Feb 01, 2010 To: Feb 28, 2010
Research and development of horticultural products

Bingo! The address matched that of Envy Plant Products Inc. Confirmation that Florigen Research Laboratories, Envy Plant Products and Flower Dragon were all one and the same thing.

OK – let’s cut to the chase (this is getting old and Sherlock Holmes grows weary my dear Watson). Who is the mysterious Flower Dragon… really?

The answer/confirmation to the curious case of the Flower Dragon came on June 21 2010. That is, the name or, at least one of the names that I had been looking for from day one.

“…the person behind Flower Dragon is Stephen

We met Mr. Berlow a couple of years ago when he worked for the BC
company Futchatech, which, at the time, was the North American
distributor for Dutch Master. A year or so ago Mr. Berlow and
Futchatech had a very rancorous falling out. At a later date, Dutch
Master and Futchatech fell out, and Futchatech is no longer the Dutch
Master distributor. It all begins to be a bit of soap opera.” (I bet!)

Could it be? Steve Berlow, AKA Dutchmaster, AKA Futchatech, AKA Transloc, AKA Superbud, AKA Phosphoload, AKA Florigen Research Laboratories Inc, AKA Envy Plant Products Inc, AKA the mysterious Flower Dragon…


Author’s note: The author would like to express his regrets to Susan MacGowan and Tammy Tagliafierro, and thank Ms Tagliafierro for responding to an email with:

“…On a side note, in my opinion, your allegations and slander towards Mr. Berlow seem a bit harsh. If you know as much as you say you do, you should know that Mr. Gribble is known to manipulate and instill fear in those around him. I would not be so quick as to judge Steve or other ex-employees of the Gribbler’s empire.”

Of course there were also a few colorful words thrown my way.

“ I am informing you that if you choose to mention anything about myself, my partner, my products, my company, or make any suggestion or inference that either of us are associated with Steven Berlow, Craig Gribble, organized crime, or any bike gangs anywhere around the world, I will seek legal action against you”

[End Quote]

Ok, I’ll be advised. On this note, the author has no idea whether Envy Plant Products Inc is linked to organized crime, bike gangs (from anywhere around the world) etc. Envy Plant Products, however, is linked to Steven Berlow, who is/was linked to Dutchmaster, bike gangs and organized crime.

To quote further:

“Steve left Futchatec/Transloc etc “for reasons that you can imagine, but won’t get into…” Not much of a drama, Steve has been pretty quite (quiet) about the whole thing, as has Craig. I can’t imagine Craig would want to rustle Steve’s feathers too much, after all, that much time with a company you gain a lot of confidential operational knowledge.” (I bet!)

So I’m confused? You seem to know so much about Steven Berlow and yet you threaten to sue me if you, your partner or, your company are linked to Steven Berlow, while linking your company to Steven Berlow (if you follow my drift).

Of course there was also this:

Perhaps it’s true our copy is a little ‘American-hype styled’.

Well no, I didn’t actually say this. I think I refer to your copy as “jargon”,”dribble”, and subversive marketing. That’s extremely tough on the Americans’ (your consumers). You’re a Canadian company connected to an Australian who clearly wrote your “copy” (which by definition is false marketing and not “hype”).

“…we have been actively looking for a good copywriter to mellow it out and make it more suited for the average grower. I’m sure you can empathize with that since your writing style is also a bit too evolved for most people, with too much technical jargon and ramblings about biochemistry, plant physiology etc, couple with a tendency to stray off topic, and often lacking a point; perhaps that’s why your book doesn’t sell… just trying to help:-)”

Aghhh – I’m gobsmacked! Too evolved? Ouch! Is that to say your consumers aren’t evolved?

“I’m not an expert in the sciences myself, but I do work with certified plant physiologists, and biochemists, and they expressed to me some of their concerns of the formulas you have posted on your website. They have mentioned that the concentrations of some of the ingredients, along with the lack of proper processes to allow plants to metabolize certain ingredients could be quite toxic to animals & more importantly people. I recommend you have someone look at those formulas before someone gets sick.”

Someone has looked at the formulas Ms Tagliafierro. The APVMA in Australia, the EPA in North America and so on. The formulas of which you speak are PGRs (poisons thinly disguised as powerful “rare earth elements” etc). Hence the skull and crossbones featuring at the top of the page and the “Darkmaster Superbad” label on the sites hompage.  You will also note warnings and “for demonstration purposes only”. I think I make my views more than clear. PGRs are poisons!

One formula is based on Dutchmaster’s (aka Steven Berlow’s) Superbud (SB). The Paclobutrazol, Alar formula on my site has less Alar than the original, which was, if my memory serves me correctly, approximately 300 – 330g/L Alar (when the APVMA seized samples in 2003 and analyzed these samples).

The other formula is a two part (Paclobutrazol and Cycocel) – ppm for ppm to another PGR product that is sold in Australia and elsewhere. The formula is manufacturer direct and this particular product is sold widely through hydroponic stores in Australia and elsewhere. It is now registered for use with berries, so if you’re growing berries it should be just fine. However, if you are growing a short-term deciduous crop (i.e. cannabis) it should be considered a toxin and given a wide berth. As you put it: “They have mentioned that the concentrations of some of the ingredients, along with the lack of proper processes to allow plants to metabolize certain ingredients could be quite toxic to animals and more importantly people.”

It sounds like your people know a thing or two about PGRs… I agree completely!

Let’s move on!

More Soon….. Information on PGR definitions, classes, and regulations to be added shortly.

Recommendation:  Where a retailer, wholesaler or manufacturer claims that a product acts in a similar way to Superbud or any other known PGR product ask to see the MSDS and registration number for that product. Furthermore, actives with other information as to safe handling, disposal, poisons schedule etc are required by law to be attached to that product at point of sale.  If a product is claimed to have a dramatic effect on plants (e.g. reduce internodel length, induce early flowerset etc) it is safe to assume that product is not strictly mineral based. I.e. It contains at least some PGR component/s.

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