8 September 2016

Cannabis Industry Journal report..

Read the full report at https://www.cannabisindustryjournal.com/column/the-devil-is-in-the-detail-changes-to-canadas-cannabis-regs-to-encourage-patient-independence-and-business-credibility/

Curious to know more? Our regulatory department manager Elfi Daniel-Ivad is an expert in regulatory change. She has worked on close to 150 submissions for cannabis licensees in Canada and beyond. Here are a few key changes from her department’s overview to better understand.

MMPR

ACMPR (Updated)

No personal production or designated production available to patients (aside from that grandfathered in by MMAR).

Personal production and designated production available. Patients may grow 5 indoor plants OR 2 outdoor plants at any given time per gram prescribed to them.

Licensed Producers were not required to label THC or CBD amounts in dried cannabis, though most producers did for sales and educational purposes. Oils had to be labeled with THC and CBD amounts.

Licensed Producers must label their percent THC and CBD for dried and fresh cannabis products.

For the labelling of oils, the total quantity of THC, CBD and oil in a container had to be shown. Restrictions on THC allowed no more than 10mg/mL THC per capsule and no more than 30mg/mL THC per mL oil to be distributed.

In addition, oil labels must now include information on “carrier” oil and allergen information. Containers must be labelled with number of capsules, the net weight and volume of each capsule. .

No reference to validation of analytical testing methods.

Analytical testing must be completed using validated testing methods; confirming reliability and consistency in results for   contaminants, disintegration, residues and THC, THC-A, CBD and CBD-A

Accredited labs can only test products as received from Licensed Producers.

In addition to Licensed Producers, patients growing their own or having a designated grower growing for them may also test their products at an accredited lab.

In addition to these changes, it is important to note that if an individual or company has an MMPR proposal already submitted they can now revise it to include oil production (previously, it was first dried bud only). If a company submits a new ACMPR proposal, they can include oil production on their application right away. Interested in submitting your own application? Or need help with one in the USA? Our regulatory department would be happy to answer any questions you might have about the process.