With the cannabis industry rapidly growing and expanding, many companies are looking to enter this exciting market and manufacture new and innovative cannabis products that will be available for recreational and medicinal use. Some of these companies looking to enter the cannabis space already manufacture non-cannabis products such as foods and beverages, natural health products and cosmetics. Therefore, a common question we get is, “How can I process cannabis and non-cannabis products at the same site?”
Before delving into details, we’ll start with the basics. A Processing licence is required to manufacture and package cannabis-based products such as edibles, topicals and extracts. Currently, Health Canada offers two variations of the Processing licence; Standard Processing and Micro-Processing. The Micro-Processing Licence is generally reserved for smaller manufacturers, as it only permits up to 600 kg of dried flower (or the equivalent) to be handled each year. This option is ideal for businesses that do not intend on expanding their market reach in the near future. The Standard Processing licence functions much like the Micro-Processing Licence, but there is no limit on the amount of cannabis product your business can handle each year. You can manufacture, sell, and distribute an unlimited amount of cannabis with this licence. Both Processing licences allow for the sale and distribution of cannabis products to other licence holders, or to provincial and territorial retailers. It is important to note that Processing licences do not allow for the cultivation or harvesting of cannabis plants. These activities are covered under Health Canada’s Cultivation licences.
Businesses that will be processing cannabis and food products (including beverages) at the same site must ensure that production, packaging, labelling, and storage of cannabis products and production, packaging, and labelling of food products are conducted in separate buildings. This requirement applies to all classes of cannabis (not just to edible cannabis). This means that any cannabis production (edibles, extracts or topicals) must occur in a separate building from any non-cannabis food or beverage production. This measure will help minimize the risks of cross-contamination of Canadian food products with cannabis, as processes will be completely separated and isolated. This includes separate personnel, equipment, production rooms, HVAC and air filtration. The requirement for separate buildings will ensure there are no mix-ups, mis-labelling, cross-contamination or confusion amongst employees. While this requirement may be burdensome and could pose a barrier for small food businesses interested in producing cannabis products, it is a key strategy to mitigate against the food safety and public health concerns associated with multiproduct manufacturing facilities.
Businesses that do not produce food products, but rather natural health products, cosmetics or other consumer goods, won’t require a separate building to process cannabis, but will still need to manage risks by other means. For example, a holder of a licence for processing must ensure that physical or other effective means are used to separate any incompatible activities, in order to prevent contamination of cannabis or anything that will be used as an ingredient. Therefore, processing of cannabis products would need to occur in physically separated spaces (e.g. rooms strictly used for cannabis processing). To prevent any sort of cross-contamination, mix-ups or mis-labelling, risks would also need to be managed through the use of dedicated equipment and employees, strict sanitation, and Standard Operating Procedures (SOPs).
Furthermore, consistent with the SFCR, licensed processors (that produce edible cannabis or cannabis extracts) are required to prepare, retain, maintain and implement a written preventive control plan (PCP) to identify and address through effective control measures any potential hazards posing a risk of contamination for these products.
How we can help you
At Cannabis License Experts, we provide you with the guidance to plan your cannabis processing business, acquire funding, navigate the legal requirements, and acquire the appropriate licence for your operations. As the Canadian cannabis industry develops, more and more licensed producers will be needed to meet the demands of consumers.
Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs, Preventive Control Plans (PCPs) and more.
Our Edibles Compliance division can provide you with a solid plan for your edibles business to help get your products on store shelves.
Contact us today to discover how we can license and legalize your cannabis business to meet federal or provincial regulations.
