On May 8, 2019, Health Canada published a statement concerning changes to the licensing process for cannabis.
Effective as of the date of the statement, new applicants for licences to cultivate, process or sell cannabis for medical purposes must have a fully constructed site that meets the requirements of the Cannabis Regulations and other applicable requirements.
For applications that are already submitted and waiting to be processed, Health Canada will make a general review of the applications. The applications that are considered as being complete will receive an update letter that will indicate the result. Once a full constructed and compliant site is available to applicants, Health Canada will review the application in detail in priority based on the original application date.
This statement represents a significant change. Until now, applicants have submitted an application through the Cannabis Tracking and Licensing System (CTLS) providing all the required information but not requiring final site construction evidence. The application was verified by Health Canada who conducted a thorough exam to determine whether the requirements where met according to the filed application. Following this exam, a confirmation email was sent to the applicant and following the reception of that email, said applicant had to provide evidence (visits, videos, pictures or other) to demonstrate that an operational installation or building existed, after which licenses would be issued.
From now on, in assessing the risks inherent to a major project, applicants will have to construct their production or processing facilities without any specific comments by Health Canada on the regulatory conformity of the project.
Other regulatory requirements remain the same, including the rigorous security clearance process which applicants' personnel and directors must undergo. It remains to be seen what impact this change will have on the processing time of related requests, including security clearance requests.
To support license applicants, Health Canada has updated their Cannabis Licensing Application Guide and has published a guide of good production practices as well as a guide on physical security measures. In addition, Health Canada has advised that they will provide increased assistance to indigenous affiliated applicants and will put in place other measures to assist "micro" license applicants.
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