At present, Canada does not permit the manufacturing of concentrates and edibles for retail to the general public. In 2019 this is changing.
Cannabis Compliance Inc is currently engaged with Health Canada in stakeholder consultations to develop new regulations to allow their manufacturing and sale. The term “edibles” within our discussion includes all cannabis-infused food products, including beverages and baked goods. It is expected that regulations around edibles will be proposed in early 2019, with regulations being published in the summer of 2019 – and coming into force in the Fall of 2019. However, this timeframe is only estimated by CCI based on prior communications from Health Canada.
In theory, the manufacturing of cannabis food products is expected to fall within the Micro Processing and Standard Processing Licences once regulations are introduced and come into force (as per above). However, many companies are getting ready by applying for a Research and Development Licence under the Cannabis Regulations. This would permit a company to “play around” with cannabis in creating recipes and product formats ahead of large-scale manufacturing which could begin late 2019 with the new regulations. Given the expected very high demand around edibles in the years ahead, getting an early start in the R&D is highly recommended.
In addition to achieving a Research & Development Licence, an edibles manufacturer would also implement Hazard Analysis and Critical Control Points (HACCP) and good practices within their facility, which is standard practice for many food manufacturers. Cannabis Compliance Inc has extensive experience working on Health Canada applications and developing (and auditing) best practices within the food industry, as many of our regulatory experts have a long history of food compliance prior to joining CCI.
With regulations being introduced in the year ahead, established food manufacturers who do not yet have cannabis experience would be very interested in achieving a Research & Development Licence for a designated area in their existing facility. For example, a chocolate manufacturer could continue manufacturing non-cannabis chocolate while at the same time devoting some of their facility space to experimenting with infusing cannabis into chocolate, assessing the shelf life and taste, and testing the consistency and potency of its experimental formulations.
CCI can also offer the following services to help our clients prepare for the upcoming edibles market:
- Building HACCP / Preventative Control Plan and environmental program to be compliant within food safety regulations
- Gap assessment of existing programs against regulatory requirements or Global Food Safety Initiative (GFSI) benchmarked schemes
- Compliance within the Safe Foods for Canadians Regulations or other food safety regulations relevant to the industry and jurisdiction
- Building Quality Management Systems (QMS) based on GFSI benchmarked schemes such as Safe Quality Food (SQF), The British Retail Consortium (BRC), Food Safety System Certification (FSSC 22000), or International Featured Standards (IFS), (etc).
- Training in current Good Manufacturing Practice (cGMP), HACCP, Preventative Controls and other relevant regulatory requirements
Cannabis Compliance Inc is the world’s largest professional cannabis consulting firm, with over 60 full time salary employees across Canada. Contact us today to start a conversation around preparing for the upcoming edibles market.