Medical vs Recreational
It’s been recommended that both medical and recreational cannabis streams run in parallel for at least five years.
It is not yet clear how different the medical vs recreational systems will co-exist or compete with one another. The Access to Cannabis for Medical Purposes Regulations (ACMPR), and its predecessor Marihuana for Medical Purposes Regulations (MMPR), prohibited the sale of cannabis in person (i.e., storefront). Facilities required extensive security monitoring and video storage – more than any other type of precursor or narcotic – and the production areas had to be virtually sterile. Our team has helped many companies and startup groups ready their business for the application process.
The task force report was laced with ambiguity; throughout most of the report, the distinction between medical and recreational was not clear cut. However, the report has recommended that both medical and recreational run in parallel for at least five years. It is certainly possible that they may simply combine them into one larger system.
The take-home message for recreational cultivation, however, is that we should expect similar standards for production as on the medical side. It should also be stressed that Canada is not going back to the old designated grow-op system from years ago. Canada does not want tens of thousands of facilities to monitor. They are looking for professional commercial production facilties that will be responsible in running their business. Significant security clearances, pharmaceutical standards of production, and air-tight record keeping. We also fully expect Health Canada to inspect such recreational producers regularly for compliance – e.g., every month, as they do now on the medical side.
Again, all of this is guess work – but for the time being, it is plausible that they may only allow certain dosage forms on the medical side. For example, capsules, tablets, creams – any dosage format that implies a medical purpose.
Also, it is expected that licensed producers under the medical system would also be permitted to cultivate and sell recreational product. However, this has not yet been confirmed.