Canada legalized the sale of five classes of cannabis. This year will now see the addition of three new permitted classes of cannabis: (a) edible cannabis, (b) cannabis extracts, and (c) cannabis topicals.[1] Accordingly, Health Canada has released the order and targeted regulations amending the Cannabis Act and Cannabis Regulations (collectively, the Amending Regulations) governing these new classes of cannabis, coming into force on October 17, 2019.
Licensing & timelines: implications for licensed producers
As is the case for dried or fresh cannabis and cannabis oil, a processing licence (either standard or micro) will be required in order to produce edible cannabis, cannabis extracts and cannabis topicals, and to package and label these types of cannabis products for sale to consumers. Current holders of processing licences must amend their processing licence once the Amending Regulations take effect before they can begin manufacturing products belonging to the new classes. Although processing licence holders may currently engage in many research and development activities, administering cannabis to a test subject (i.e., for the purposes of palatability testing) requires a specific research licence for each specific project.
Although the Amending Regulations will come into force on October 17, 2019, since there is a required 60-day notice period before any new cannabis product can be made available for sale, Health Canada has announced that it is expecting that sales of such products will not occur any sooner than mid-December 2019.
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