In November 2017, Health Canada opened a public consultation on their proposed approach to regulating cannabis upon legalization. They have recently posted the summary of the comments they had received during the consultation, in addition to further information about upcoming label and packaging requirements upon cannabis legalization.
In summary, Health Canada’s consultation paper proposes a set of regulations for licences, permits and authorizations that intend to deliver high quality legal cannabis, allow for a diverse and healthy legal industry involving large and small players, as well as reduce the possibility of crime that may infiltrate the industry.
Notable information taken from their consultation summary includes Health Canada’s proposal of a Cannabis Tracking System. This national system would allow the Minister of Health to track cannabis throughout the supply chain, in hopes of preventing the risk of cannabis diverting into the illegal market. While many respondents agreed with the idea of ensuring legal cannabis isn’t entering the illegal market and product recalls, there were concerns about the cost of a system like this and its effect on licensed smaller scale growers. As a result, there will be changes to this proposed system.
Also, the existing regulations surrounding health products containing cannabis established by the Food and Drugs Act will be maintained in the early stages of the Cannabis Act. Health Canada will continue to accept new applications for prescription drugs containing cannabis and medical devices, natural health products (NHPs) and veterinary health products containing cannabis parts.
Regarding non-prescription drugs and NHPs containing cannabis, there will be further public consultation on Health Canada’s proposed regulations. This will include the discussion of the amount of regulatory oversight preferred as well as evidence required in order to make these products available without prescription. Until these consultations are complete, new applications for NHPs and non-prescription products containing cannabis parts must not have a THC content more than 10 ppm.
In addition to its public consultation summary, Health Canada released more details on their proposed label and packaging requirements for cannabis. A standardized cannabis symbol, health warning message and THC/CBD content must all appear on the principal display panel. In addition, there will be varying requirements on the net weight, percentage of THC and CBD based on the class of cannabis (fresh, dried cannabis, or cannabis oil). The overall packaging of cannabis must be plain, with no metallic, fluorescent or eye-catching colours. In addition, only a single branding element, besides the brand name of the cannabis, is allowed, but must be the same size or smaller than the standardized cannabis symbol.
For more information, please do not hesitate to contact Focal Point Research Inc. We are leading Canadian regulatory and Health Canada consultants for Natural Health Products, OTC Drugs, Cosmetics, and other personal care products.
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