Earlier this month, Health Canada announced some changes being made to the Cannabis Tracking and Licensing System (CTLS) which allows cannabis license holders to submit applications for cannabis import and export permits.
What changes are being made?
Starting April 4, 2022, cannabis license holders will see an ‘Import-Export Permit’ module in the CTLS under the ‘Licensing’ heading of the taskbar. Health Canada has asked that license holders do not submit cannabis import and export permit applications through the CTLS until May 16, 2022, as some time is still needed to adjust internal processes to receive applications electronically.
How do these changes differ from previous processes?
Before April 2022, Health Canada only accepted cannabis import and export permit applications by email. A physical application form would need to be populated and emailed to Health Canada for review. Upon successful review and approval, a cannabis import, or export permit would be issued.
As a reminder, the Cannabis Regulations set out the restrictions about the import and export of cannabis. Only license holders under the Cannabis Regulations may import or export cannabis, and only for medical or scientific purposes. Cannabis import and export for any other purpose (such as distribution or sale for non-medical purposes) is strictly prohibited. Furthermore, cannabis import and export for medical or scientific purposes requires a permit from Health Canada for each shipment.
What does this mean for cannabis import and export requests going forward?
Health Canada will continue to accept cannabis import and export permit applications by email until May 13, 2022. After May 13th, cannabis import, and export permit applications will need to be made via CTLS only. Any email applications received after this date will be returned and license holders will be asked to submit via CTLS.
License holders will be required to submit new permit applications, permit change requests, and endorsements through the CTLS, like their other licensing requests.
Guidance on how to use the new feature will be sent to license holders before May 16, 2022.
What does Health Canada consider when deciding to grant a cannabis import or export permit?
Before cannabis import and export permits are issued, Health Canada considers the following:
- Canada’s obligations under international treaties
- Whether the application is compliant with the Cannabis Act and its regulations
- Whether the import or export will be used solely for medical or scientific purposes
- In the case of exports, whether the country of final destination has issued an import permit
- Whether there are risks to public health given that imported products are not subject to the same strict production standards or Health Canada inspections
- Whether there are risks to public safety and security, including the risks of diversion and
- For the import or export of drugs containing cannabis, whether import/export requirements of the Food and Drugs Act and its regulations have been met
How we can help?
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Contact us today to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.