Cannabis Council of Canada Alert: Overview of the amendmendments to cannabis regulations March 2025

On March 12, Health Canada published amendments to the Cannabis Regulations under the Cannabis Act. Our team at C3 has been working diligently to get this across the finish line ahead of a potential federal election and we are pleased to see it implemented.

The updated regulations include a number of changes that should reduce bottlenecks and ease the regulatory burden on LPs.

Key Changes Include:
​

  • Quality Assurance Persons (QAPs): The main QAP will be able to delegate certain activities while maintaining accountability and overall responsibility and to allow for multiple alternative QAPs. This change will reduce production bottlenecks and ease the burden from having a single person oversee the entire QA process.
  • Updated packaging and labeling requirements:  New regulations will allow for accordion or peel-back labels, QR codes, and simplified potency information. Transparent packaging and cut-out windows are now permitted for dried cannabis.
  • Expanded capacity for micros: Grow area limits for Micro-cultivation have increased from 200 m² to 800 m². For Micro-processing, the annual dried cannabis possession limit increased from 600 kg to 2,400 kg. If you would like to change from a standard licence to a micro for this year, you’ll need to apply for the change by March 26, 2025.

See below for further instructions.

We have included an overview of the amendments below.
PACKAGING AND LABELLING REQUIREMENTS

ALL CANNABIS PRODUCTS

  • The cap and container may now be different colors.
  • Wrappers may include images or other information if required by law (e.g., a recycling symbol).
  • Simplified potency information: Only total THC and total CBD are required, and font size may be as large as the Health Warning Message.
  • QR codes are now allowed for inventory tracking and consumer information.
  • Accordion or peel-back labels are now allowed on any package size.
  • Informational inserts and leaflets: Permitted, provided they do not contaminate the product and are available in both English and French. These inserts are now excluded from the definition of “label”.
  • Packaging date: The date on the label must be within ±7 days of the actual recorded batch date.
  • The following statements are no longer required: Dried cannabis equivalency (e.g., “contains the equivalent of #g of dried cannabis”) and “No expiry date has been determined”
  • A printed consumer information document (CID) is no longer required​for each package shipped to provincial/territorial retailers or direct-to-consumer sales.
  • Amended health warning messages:
    • A 12-month transition period applies for the display of new warnings.
    • Messages must rotate equally across product types and container formats.

DRIED CANNABIS, FRESH CANNABIS & SEEDS

  • Transparent packaging and cut-out windows are now permitted.

CO-PACKAGED PRODUCTS

  • Must contain cannabis of the same class.
  • The total quantity must not exceed 30g of dried cannabis or its equivalent. 
  • The properties of the cannabis must be consistent across all immediate containers. 
  • Note that this has changed since the initial consultation language that seemed to allow for multi-packs to contain multiple flavours.

OUTER CONTAINERS 

  • No longer required to be child-resistant.
  • Must meet all labelling requirements.
  • A packaging date is no longer required.

INNER/IMMEDIATE CONTAINERS

  • THC limits: 10 mg per package for edibles; 1000 mg per package for cannabis extracts.
  • Must be in child-resistant packaging.
  • Must meet all labelling requirements.
UPDATED HEALTH CANADA WARNING LABELS
The updated warning labels are divided into three parts, ensuring customers have both general and category-specific information.
GENERAL UPDATES
  • 15 messages – includes both general messages for all cannabis products as well as product-specific messages
  • Emphasis placed on youth and young adults, frequency of use, potency, mental health, and product-specific risks
  • New themes addressed include pediatric poisoning from edible cannabis, psychosis and schizophrenia, heart/lung disease from cannabis smoke, public safety risks of cannabis-impaired driving, cognitive health, and fetal growth and development.
Part 1 – Dried cannabis and extracts intended for smoking
  • Smoking-Related Health Risks: Highlights that cannabis smoke contains toxic chemicals, increasing the risk of heart and lung diseases.
Part 2 – Cannabis edibles
  • Child Safety: Emphasizes the risk of poisoning in children, particularly those under 5, if they consume edibles, which can lead to severe health issues, including hospitalization.
  • Delayed Onset of Effects: Advises that effects from edibles can take up to 4 hours to manifest, cautioning against consuming more before feeling the initial effects to prevent poisoning and severe anxiety.
Part 3 – Extracts intended for ingestion
Delayed Onset of Effects: Similar to Part 2, it warns that ingesting cannabis extracts can take up to 4 hours for effects to be felt, advising against additional consumption before the initial effects are experienced to avoid poisoning and severe anxiety.
PRODUCT REGULATONS

PRE-ROLLS 

  • 1g per unit limit removed—pre-rolls can be any size as long as the total package quantity does not exceed 30g of dried cannabis.

ETHYL ALCOHOL IN CANNABIS PRODUCTS

  • Extracts (inhalation/topicals): Allowed up to 10 mg per activation, max 7.5g per package. 
  • Extracts (ingestion): Allowed up to 0.5% w/w​for products over 7.5g.

CANNABIS BEVERAGES

  • Labels must be updated to reflect the new dried cannabis equivalence. Note that this change, implemented over a year ago, should not significantly impact industry operations.
  • Consumers can now purchase more cannabis beverages within the 30g possession limit.
LICENSING AND OPERATIONS

KEY LICENSING CHANGES

  • Alternative Quality Assurance Persons (QAPs): No longer limited to two; delegation of activities is now permitted while maintaining overall accountability.
  • Notice of New Cannabis Products (NNCPs): No longer required for dried cannabis, fresh cannabis, and pre-rolls, allowing immediate market entry.
  • Export Permits: Ports of exit are no longer specified, providing greater flexibility.
  • Import Permits: Port of entry and customs office details are no longer required.
  • Licence Suspension:​Unpaid fees or failure to submit a Statement of Cannabis Revenue (SCR) may result in suspension.
  • Irradiation (anti-microbial treatment): No longer requires a security-cleared person to accompany cannabis upon return or distribution to other licence holders.
  • Destruction of Cannabis & Waste:
    • Only one witness (an LP employee) is required for both on-site and off-site destruction.
    • Cultivation waste (e.g., leaves, branches) no longer requires a witness.
  • Cannabis Pollen: Newly defined and now permitted for intra-industry sales between certain licence holders.
  • Industrial Hemp & Non-Cannabis Materials:
    • Non-viable hemp seed derivatives: No Cannabis Processing Licence required if derivatives do not contain concentrated phytocannabinoids.
    • Industrial hemp grain derivatives: No longer require THC testing, and their import, export, sale, and processing no longer require a licence or permit.
  • Non-Human Research:
    • A research licence is no longer required for studies that do not involve human or animal participants and use up to 30g of dried cannabis equivalent.
    • Research may not be conducted in a private dwelling.
  • Expanded Micro-Class Licence Capacity
    • Canopy size increased from 50 m² to 200 m².
    • Harvested flowering heads increased from​5 kg to 20 kg.
    • Micro-Cultivation:​ Canopy limit increased from 200 m² to 800 m².
    • Micro-Processing: Annual dried cannabis possession limit increased from 600 kg to 2,400 kg.
    • Nursery:
      Canopy size increased from 50 m² to 200 m². Harvested flowering heads increased from 5 kg to 20 kg.
CHANGING FROM A STANDARD
TO A MICRO LICENSE

With the updated limits on micro-cultivation capacity, Members who currently hold a standard class licence and are operating within the new threshold may be able to become a micro and benefit from lower fees. Note that you must submit your request to Health Canada by March 26, 2025. To have your request considered within this timeframe, this must be the only change requested at this time.
If you want to change your licence subclass from standard to micro or nursery, fill out this form and email it to licensing-cannabis-licences@hc-sc.gc.ca. Use the subject line “Changing licence subclass from standard to micro for LIC-#”.
It is important to note that if you transition from a standard processing licence to a micro-processing licence, you will no longer be allowed to produce cannabis by synthesis. Producing cannabis by synthesis generally refers to the process of creating cannabinoids (e.g., THC and CBD) by chemical reactions or other means, rather than extracting them from the cannabis plant itself. This could also refer to the process of creating cannabinoids by using biotechnology, such as engineered yeast or bacteria, to produce cannabinoids in a lab setting.
 
SECURITY AND RECORD-KEEPING

SECURITY 

  • Security-Cleared Personnel (SCPs):​No longer required on-site at all times during cannabis-related activities.
  • Physical Security for Standard Licence Holders (LHs) & Cannabis Drug Licences (CDLs):
    • Site Perimeter:
      • Intrusion detection system no longer required.
      • Continuous visual recordings no longer required.
    • Storage Areas:
      • “Room within a room” requirement removed.
      • No longer need to record and track personnel entry/exit.
    • Operations Areas:
      • No visual recording required if no cannabis is present.
    • Security Camera Recordings:
      • Motion-activated recording: Only required to retain footage showing movement.
      • Non-motion-activated recording: Full footage must be retained for one year.

RECORD-KEEPING

  • Seed Production: Inventory reporting now tracked by number of seeds rather than weight.
  • Pesticide & Sanitizer Use: No longer required to record quantity, method, or rationale—only the name and date of application.
  • Sales & Export Records: No longer required to list individual ingredients for cannabis extracts, topicals, or edibles.
  • Annual Promotions Report: No longer required to track promotional expenses but must retain copies of materials for two years.
  • Cannabis Waste Management:
    • No longer requires witness or attestation.
    • Only total number of destroyed cannabis plants needs to be recorded.

Annual Key Investor Report (KIR): No longer required for licence holders publicly traded on a recognized exchange or wholly owned by such an entity.
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