Under the Cannabis Act & Regulations, applicants are required to obtain a licence issued by Health Canada in order to conduct various activities with cannabis. These licences include Cultivation (micro, standard, and nursery), Processing (micro and standard) and Sale for Medical Purposes. Research and Analytical Testing licences are also available.
Applicants and licence holders are responsible for compliance with the Cannabis Act and its Regulations, as well as compliance with other applicable federal, provincial and territorial legislation and municipal by-laws.
The success of a cannabis business even getting off the ground and licensed will rely heavily on the quality of one’s application to Health Canada, which demonstrates compliance with the legislation mentioned above.
A complete, fulsome and accurate application package can help get you through Health Canada’s queue quickly and smoothly. To help you through the process of obtaining a cannabis licence, here’s a list of our top 5 tips to help avoid your application from being rejected.
1. COMPLY WITH ALL APPLICABLE REGULATIONS
When it comes to running a cannabis business, there is much to know. It’s important that you are knowledgeable on the relevant federal, provincial and municipal legislation around cannabis. By familiarizing yourself with legislation, you will gain an understanding of activities that are permitted or prohibited, as well as your responsibilities as a licence holder. Success comes with compliance, so this is a great place to get things started.
The Cannabis Act and Cannabis Regulations are available online for anyone to view. This legislation outlines a wealth of important information and we recommend you read through them as much as possible to gain a thorough understanding of the roles and responsibilities of a licence holder. By familiarizing yourself with this information, you can ensure your application to Health Canada meets all the necessary requirements and that your business is compliant.
2. BE OPEN AND HONEST!
Much personal and professional information needs to be disclosed when you submit a cannabis licence application to Health Canada. This includes info about yourself and your employees, as part of the security clearance applications, as well as information about your business and corporate structure, your site location, and the methods and procedures you will use on site.
When preparing your application, it’s important that you’re open and honest about your business and all of the individuals/companies involved. For example, you will need to disclose key investors, directors, officers, partners, as well as any other corporations/individuals that are in a position to exercise direct or indirect control over the licence holder (e.g. parent/holding companies). All of these individuals will also need to apply for security clearance.
It may seem like a good idea to keep your application simple by only including a few individuals and not mentioning any controlling organizations such as parent companies, in hopes that this will speed up the review of your application. BUT BEWARE – this can be a disastrous decision. Not only will it slow down the review of your application (because Health Canada will send requests for more information asking you to disclose this information), but it could put your application in jeopardy due to required info not being provided.
Keep in mind, Health Canada can also refuse/reject your application if there are reasonable grounds to believe that false or misleading information has been submitted. Therefore, being open and honest throughout the entire application process is crucial to the success of your cannabis business!
3. PROVIDE A COMPLETE AND FULSOME APPLICATION
There are two parts to submitting an application for a cannabis licence to Health Canada. The first part is to prepare a “paper” application, which incorporates all the necessary documentation that is requested by Health Canada. This documentation includes items such as:
● a copy of your incorporation documents;
● an aerial view of your site;
● a floor plan;
● a site plan/survey;
● a physical security plan, and;
● an organizational security plan;
● a good production practices report, and more.
These documents must be uploaded onto the Cannabis Tracking and Licensing System (CTLS) as part of your application.
The second part of your application is to film your Site Evidence Package (a.k.a. the video attestation for your site). The site evidence package provides visual verification to demonstrate the completion and functionality of your facility. It generally includes a guided video tour of your entire site, as well as video footage and photographs from the visual recording devices installed at your site.
It is crucial that your site evidence package and your paper application are both complete, accurate and correlating. Health Canada may refuse to consider an application if any of the required information is not provided. Furthermore, submitting an incomplete or “messy” application can slow down the review of your file, which will ultimately result in extra waiting time for you to receive your licence.
4. ENSURE YOUR SITE EVIDENCE PACKAGE IS COMPLETE, ACCURATE AND DELIVERED ON TIME
The site evidence package is a key portion of your application. It shows Health Canada that your site is complete, functional and ready to go. Therefore, it’s important that your site package is complete with all of the necessary pieces required by Health Canada. For example, a business looking to obtain a Standard Cultivation and/or Standard Processing licence would need to provide the following items in their site evidence package:
- Guided video tour of entire site (including both indoor and outdoor areas), highlighting all security features of the site perimeter, operations areas (including all grow areas) and storage areas. All devices must correspond to their location as indicated on the site plan (including all floor plans);
- Photographic overview of each side of the defined site perimeter;
- Visual recording device footage that includes the front, back and sides of the defined site perimeter (e.g., east, west, south and north walls). Complete coverage may be best demonstrated by displaying multiple visual recording device feeds that capture an individual walking around the perimeter;
- Footage from all visual recording devices in each operations areas (including the entry and exit points of the grow areas) and all storage areas.
Keep in mind, your site evidence package submission must be received by Health Canada before your application can be considered. Furthermore, your site evidence package submission must be received by Health Canada within 10 business days following the submission of your “paper” application in the CTLS (as mentioned in point 3 above). If you don’t submit your site evidence package within the timeframe requested, you may have your application refused as incomplete. We sure don’t want that!
5. WORK WITH AN EXPERT (THAT’S US!)
Working with a consultant can make all the difference when it comes to preparing something as intricate and complex as a cannabis licence application. They can help assist you with achieving points 1-4 mentioned above and provide sound advice when it comes to running your cannabis business.
Cannabis License Experts offers support from day one of starting your cannabis business, including strategic planning, floor plan preparation, site audits, SOPs and more. Our team is equipped with professionals who have extensive experience in the Cannabis, Pharmaceutical, Natural Health Product, Food and Medical Device industries.
We leverage years of cannabis quality assurance, operational and cultivation knowledge with real-life hands-on experience. Our team has the experience of submitting Over 125 cannabis license applications under ACMPR and the Cannabis Act with NO refusals to date! This speaks to our team’s dedication and due diligence to help our clients succeed. Through trust, transparency and respect, our team will work with you to achieve your goals of getting your cannabis business licensed and legalized.
There you have it – our top 5 tips to help avoid your application being rejected. Contact us today for a free consultation, and let us help you get started on the path to obtaining a cannabis licence and running a successful cannabis business!