Eric Nash and Wendy Little - Canada's Marijuana Experts

Bringing over ten years of qualified expertise to your court case

Marijuana - Commercial Production Licence

Opportunity for Those Interested in Becoming a Licensed Commercial Producer

February, 2012

Wendy Little and Eric Nash have been legally producing and selling cannabis for over a decade, and have significant experience in Health Canada's medical marijuana access program and the federally regulated cannabis industry. They own and operate Island Harvest, a privately held British Columbia medical cannabis production and distribution company.

For five consecutive years Island Harvest has produced the world's first certified organic medical cannabis. Wendy Little and Eric Nash provide consulting services to assist those seeking information on the legal medical marijuana business and industry opportunities in Canada.

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The Opportunity

Health Canada is aware that transition to the proposed redesigned Program requires access to an adequate supply of dried marihuana to meet the needs of current and future program participants.

Commercial Marijuana Production

In this regard, Health Canada has identified compliance with requirements relating to the following aspects of production and distribution as being key to obtaining a commercial producer licence:

Dried Marihuana Production, Distribution and Disposition

  • indoor production in a non-residential area;
  • physical security standards;
  • product quality standards;
  • packaging and labelling standards;
  • requirements for the disposal of excess plant material, excess dried marihuana and/or expired dried marihuana.

Personnel

  • designation of an individual responsible for managing the production and distribution of dried marihuana;
  • specific qualifications for all personnel involved in production and distribution.

Record-keeping and Reporting

  • requirements to keep records relating to all on-site activities for a set period of time, and the ability to provide set records to Health Canada on request;
  • requirements for reporting on activities associated with the cultivation of marihuana and the distribution of dried marihuana.

Compliance and Enforcement

  • pre-qualification audits and pre-licence inspections;
  • inspections and/or audits on an ongoing basis.

Licenced Commercial Marijuana Production

The prices set by the commercial producers would likely be influenced by market competition. Commercial producers would have to be subjected to regular audits and inspections.

  • The licensed commercial producers would be able to produce any strain(s) of cannabis, giving individual customers greater choice.
  • Licensed commercial producers would set the price of the cannabis they produce.

Dried Marihuana Production and Distribution

  • Under the proposed redesigned program, Health Canada would no longer enter into a contract with a commercial entity to supply and distribute dried marihuana and marihuana seeds.
  • The only legal source of dried marihuana would be commercial producers, who would be licensed by Health Canada to produce and distribute dried marihuana.
  • Individuals would purchase their supply of dried marihuana from one of these licensed commercial producers.
  • Personal and designated production would be phased out.
  • In order to be licensed by Health Canada, licensed commercial producers would have to demonstrate compliance with requirements related to, for example, product quality, personnel, record-keeping, safety and security, disposal and reporting, as set out in new proposed regulations. These controls would aim to ensure the quality of the product being purchased by program participants, as well as the security of production sites.
  • Health Canada would establish a comprehensive compliance and enforcement regime for licensed commercial producers, centered on regular audits and inspections.
  • Licensed commercial producers would be required to comply with specific product labelling and packaging requirements. The label and/or the package itself could be one way by which a program participant could demonstrate that their supply of marihuana is legal.
  • Licensed commercial producers would only be permitted to produce marihuana indoors.
  • Licensed commercial producers would be able to produce any strain(s) of marihuana, thus giving individuals greater choice as to which strain(s) they wish to use.
  • Licensed commercial producers would set the price for marihuana for medical purpose.
  • Licensed commercial producers would only be able to send the dried marihuana they cultivate to individuals by registered mail or bonded courier.

 

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