Can I Hold Multiple Cannabis Licenses with Health Canada at the Same Site?
The simple answer: Yes.
The Cannabis Act and Regulations provided opportunities to apply and receive different cannabis license classes and subclasses. These include:
- Cultivation License class with subclasses Nursery, Standard Cultivation and Micro-Cultivation
- Processing License class with subclasses Standard and Micro-Processing
- Sales for Medical Purposes class with or without possession
- Analytical Testing
- Research
How can my business hold multiple cannabis licenses?
First, there are acceptable combinations of cannabis license classes and subclasses based on the activities each cannabis license authorizes the holder. For example, the Analytical and Research license classes can be combined with both Cultivation and Processing classes and their respective subclasses. Cultivation license and its subclasses can be combined with both Processing and Sales for Medical Purposes Licenses. The processing license can be combined with the sales for medical purposes license.
There are a few combinations of cannabis licenses that can be applied. The best approach in determining which cannabis license class and subclasses to apply for and combine is by establishing your business model and identifying which activities the end products entail to produce. The combination of cannabis licenses you should apply for must be based on your company’s business model and the activities you wish to conduct at your site.
Cannabis license combinations you may want to consider
Here are some scenarios of combinations of cannabis licenses you can apply for based on the activities set forth in your business model:
- You want your company to distribute your own brand of pre-rolls made from cannabis grown by your Master Grower. You also have identified that you want to focus on craft growth and keep a small cultivation footprint. In this case, your site must be authorized to grow cannabis, process and package the dried cannabis into prerolls and sell directly into the medical and retail market. For these activities, you will need to apply for the following cannabis licenses: Micro-Cultivation license, Micro-Processing license, and Sales for Medical Purposes license.
- You want to focus on sales and distribution into the medical and retail markets and be a sales hub for other cannabis license holders. For this, you can apply for only the Sale for Medical Purposes license.
- You want to package bulk products from Cultivation license holders and sell their brand into the medical and retail market. For this, you can apply for both Processing and Sale for Medical Purposes licenses.
Cannabis License Amendments
Cannabis license classes can also be added through amendments. For example, if you received your cultivation and processing licenses, and realized that you would prefer to do your sales directly instead of selling business-to-business to other license holders, you can apply for a Sales license and amend your existing cannabis licenses to get authorization to sell and distribute.
How We Can Help
CLE can help you in determining which licenses are best for your business, navigate the preparation and submission of cannabis licenses, and prepare and submit amendments to your existing licenses. Give us a call and we would be happy to help.
