In Canada, currently only cannabis oil (liquid, soft gels) is permitted as a finished product. This is now changing.
Some licensed producers have launched “kit products” which provide the consumer with cannabis oil as well as something to combine it with (e.g., cream + cannabis oil = cannabis cream), which is permitted. However, at present edibles, concentrates, beverages, and cannabis health products are not permitted for manufacturing or resale.
To extract cannabis oil, a company has to achieve either a Micro Processor Licence or a Standard Processor Licence. The key difference is around permitted capacity, where a Micro is permitted to process up to 600 kg of dried flower (or its equivalent) per year, whereas a Standard has no limitation. Note that a facility is permitted to achieve both a Micro Cultivation Licence (up to 200 square metres canopy space) as well as a Micro Processor Licence (processing 600 kg dried flower equivalents per year) at the same location. It is anticipated that most small facilities will desire both a Micro Cultivation and a Micro Processor Licence, however the framework was designed to allow a facility to only process (without cultivation), dried flower purchased from a licensed cultivator.
Note that Micro and Standard Cultivation Licence holders are not permitted to supply wholesale to any provincial distribution body (for the recreational retail market). However, both a Micro and Standard Processor are authorized to supply wholesale to a provincial distributor. Therefore, if a company wishes to cultivate as well as sell wholesale to a province, they would need to achieve both a cultivation and processing licence.
To acquire a Micro Processor Licence, CCI carefully prepares an application package (with supporting documentation) which is submitted to the Office of Medical Cannabis at Health Canada. CCI provides strong recommendations around the proposed site and floor plan, physical security design, Standard Operating Procedures (SOPs) for the operations of the facility, security clearances for key personnel, guidance for notifying local authorities, quality assurance reports, recruitment of the Quality Assurance Person (QAP) and ongoing communication with Health Canada post-submission.
Note that a Micro Processor requires a Quality Assurance Person (QAP) with appropriate qualifications or experience from highly regulated sectors (e.g., pharmaceutical, food, tobacco, alcohol), which is not a requirement for the Micro Cultivation Licence on its own. Note that both the Micro and Standard Processor Licences require a Head of Security staff position. Note that the physical security requirements are also lower than those for a Standard Processor. Note that Health Canada does not have application fees at this time, although they are expected to start charging for applications at some point in the year or two ahead. The timeframe to achieve a Micro Processor Licence is still unknown, as Health Canada has not set performance targets for application processing, but it is expected to follow similar patterns observed previously under the Licensed Producer (LP) licensing within the Access to Cannabis for Medical Purposes Regulations (ACMPR) (i.e., at minimum 18 months from submission to licence).
It should also be noted that Health Canada does not provide a “ready to build” letter or authorization ahead of facility construction, which means that the construction or renovation of the facility would be completed before or during the application review period. Therefore, the Micro Processor Licence will only be issued once the facility is fully built out and operationally ready, and after the application is thoroughly reviewed by Health Canada.
Cannabis Compliance Inc is accepting new clients for the preparation and submission of Micro Processor Licences and has a 100% success rate with previously submitted applications under the former ACMPR regulations. With a team of over 60 full time salary employees, CCI is the world’s largest professional cannabis consulting firm, with expertise from pharmaceutical, food, alcohol, natural health products and medical device industries. Contact us today to start a conversation around how CCI can help you achieve a Micro Processor Licence.