As of late 2018, small “craft” cultivation facilities will now be eligible for a unique type of licence called a Micro Cultivation Licence.
The security and operational requirements are less stringent than the larger production facilities (which fall under a Standard Cultivation Licence), making this a very attractive opportunity for small business entrepreneurs.
The Micro Cultivation Licence permits 200 square metres of canopy space (around 2152 square feet), and it can be either indoors (greenhouse, warehouse) or outdoors (farming). For information on outdoor farming, please see the other page in this section called Outdoor Cannabis.
Historically, small cultivation businesses have always been permitted in theory, but in practice the staffing and operational requirements made it a cost-prohibitive venture. Now, with the Micro Cultivation Licence small business owners can run a lean operation with minimal staff and security. It is expected to spark a new “revolution” in craft cannabis production in Canada.
Only one licence is permitted per unique address. However, in theory a larger facility which has unique addresses for different sections could achieve a licence per section, similar to different warehouse bays within a larger warehouse facility. The Micro Cultivation Licence allows a facility to cultivate cannabis and sell (wholesale) to a third party and also allows the direct sale to provincial distributors (fresh/live plants/seeds only), other Processors (dried flower, oil) retailers or direct to medical patients. In order to supply to the provincial retail supply chains, a Micro Cultivator would also need to achieve a Micro Processor Licence for the same facility (Health Canada has confirmed that a Micro Cultivation Licence cannot be combined with a Standard Processor Licence).
To achieve a Micro Cultivation Licence, an application has to be thorough and professionally drafted, and submitted to Health Canada for review. Extensive details of the facility and operations are required, including (but not limited to): a professional floor plan, site and physical security design (and risk management programs), Standard Operating Procedures (SOP’s), Security Clearances, corporate structure summary, site survey, filed notices with local authorities, various quality assurance reports and administrative forms. The timeframe to achieve this type of licence does not fall within a performance target, but historically ACMPR applications were at minimum 18 months from application to licence. It is expected that Micro Cultivation Licences will follow a similar pattern. Note that only a fully built-out facility will be eligible for a licence, and Health Canada does not offer any “ready to build” (or similar) authorizations ahead of construction; the applicant will need to build out the facility before/during the application is under review.
A notable change in the Canadian regulatory system for 2018 is that “black market” genetics (i.e., plants and plant seeds) that are illegal will now be allowed to be brought into a newly licensed facility. The plants or plant materials must be brought into the facility on the first day of licensing, as a one-time influx of genetics. As this was not permitted under the previous regulations, this is seen by many to be a huge opportunity to welcome illegal growers into the new legal market. Note that this is not an allowance for existing licensed producers; it will only be permitted as a one-time allowance for new applicants.
After the initial licence is achieved, it should be noted that Health Canada will inspect the facility on a regular (usually monthly) basis to ensure compliance in all areas covered within the Cannabis Regulations. CCI is often recruited to provide operational readiness programs and training programs to ensure the facility is functioning without error or non-compliance.
Cannabis Compliance Inc is recruited to complete a Micro Cultivation Licence Application, together with the required paperwork. CCI has a 100% success rate in achieving production licences under the historical frameworks, and is accepting new clients for micro cultivation licensing.