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CANNABIS CULTIVATION LICENSE


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Those looking to cultivate cannabis are required to hold one of the following licenses under the Cannabis Act & Regulations: Standard Cultivation license (permits cultivation in an unlimited-sized grow space). Micro-Cultivation license (allows for cultivation in a grow space of up to 2,152 square feet). Nursery license (permits the cultivation of cannabis genetics such as clones and seeds, within a maximum 540 square feet).


Cultivation of medical and recreational cannabis in Canada is permitted both indoors (year-round within a constructed facility or permanent greenhouse) and outdoors (seasonally, within a temporary greenhouse or in an open plot of land). Furthermore, a cultivation licence allows for the holder to grow cannabis through unspecified means, including but not limited to using aeroponics, hydroponics, aquaponics, vertical planters, and in traditional soil.

To decide which license class is the best fit for your business, you may want to consider the amount of canopy space available within your chosen facility or outdoors. Canopy space that is equal to or less than 200 square meters in size (this includes multiple and vertically arranged surfaces) fit within the description of Micro-Cultivation and is perfect for small batch or craft growers. Anything larger would require a Standard Cultivation License, which is a great option for large and growing companies.

Alternatively, a Nursery license would be the best fit if your business is interested in the development of starter plant material and new plant varieties with goals of altering cannabis genetics to make seeds, seedlings and clones.

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License Overview

Who is a Cultivation or Nursery License for?

Micro and Standard Cultivation Licenses are designed for business that would like to be able to legally grow, possess, sell (in bulk – to certain parties), and research cannabis. The Micro-Cultivation License is perfect for smaller business and craft growers that are working with a limited amount of unique strains. Standard Cultivation Licenses are ideal for larger companies that want to build and grow in a large-scale facility or are exploring outdoor growing on a large plot of land.


What can you do with a Cultivation or Nursery License?

Micro and Standard Cultivation Licenses permit the possession, propagation, cultivation, harvesting, chemical or physical alteration, sale (in bulk – to certain parties), and distribution of cannabis. Dried and fresh cannabis, as well as plants and seeds, can be sold to other holders of Cultivation, Processing, Analytical Testing, Research & Development, or Cannabis Drug Licenses, with licensed nurseries exempt from buying dry or fresh flower. Sale and distribution to license holders that are authorized to sell cannabis for medical purposes is allowed for plants and seeds only. Furthermore, cultivation licence holders can sell seeds and plants, not dried or fresh cannabis, to the provinces, for recreational cannabis sales. Obtaining a Nursery License also allows the holder to possess, propagate, cultivate, harvest, and alter the chemical and physical properties of cannabis. It permits the sale and distribution of plants and seeds to other Cultivation, Processing, Analytical Testing, Research & Development, and Cannabis Drug License holders. As with Cultivation Licenses, selling plants and seeds to license holders that are authorized to sell cannabis for medical purposes and those who can sell it under a provincial or territorial Act is allowed as well.


What isn’t covered under a Cultivation or Nursery License?

Cultivation license holders are not permitted to sell or distribute cannabis to the general public (recreational cannabis) or direct to medical patients (medical cannabis). This is because cultivation licence holders do not have a Quality Assurance Person (QAP) to perform finished product release.




Micro Cultivation and Nursery License Requirements

  1. The holder of a Cultivation or Nursery license must hold a security clearance. In addition, key personnel required under the cultivation or nursery license (e.g. Responsible Person, Master Grower, Head of Security), as well as any directors, officers and key investors, are also required to hold a security clearance.
  2. The license holder must retain the services of one individual as the Responsible Person, who has the authority to bind the holder. The Responsible Person will be accountable for the license holder’s activities and should have an adequate understanding of how the Cannabis Act and Regulations apply to the licence holder. They are also required to hold a security clearance. The license holder may designate one qualified alternate Responsible Person (who is also required to hold a security clearance).
  3. The license holder must retain the services of one individual as the Head of Security who is responsible for ensuring that the applicable physical security measures set out in Part 4 of the Cannabis Regulations are complied with and that implements the organizational security plan of the licence holder. One qualified alternate Head of Security may be designated. The Head of Security, and any alternate, must hold a security clearance.
  4. Hiring a Master Grower is also a requirement for license holders. The Master Grower is responsible for the cultivation, propagation, and harvesting of cannabis, and must be familiar with the Cannabis Act and Regulation’s provisions as they relate to their activities. The Master Grower (and one optional qualified alternate Master Grower) must hold a security clearance.
  5. The facility must have any on-site storage areas and the site perimeter surrounded by a physical barrier in order to safeguard against unauthorized access. It should be possible to demonstrate how the barrier’s construction, as well as the required access controls on the exit and entry points, are able to achieve this goal. Access to all storage areas must be restricted to authorized personnel only.
  6. Micro-Cultivation Licenses allow up to 200 square metres (approx. 2,152 sq. ft.) of canopy space. A Nursery license is limited to 50 square metres (approx. 540 sq. ft.) of seed production (flowering heads) with no limitation of space to cultivate clones and/or genetics.
  7. To ensure production standards, analytical testing for microbial and chemical contamination is required. Those with the appropriate licence can conduct analytical testing in-house, but pesticide testing must be done via a third-party (Analytical Testing License holder). License holders must also establish appropriate Standard Operating Procedures (SOP’s) for their operations (e.g., recall, record keeping, sanitation, pest management).
  8. Only fully-built facilities are eligible for a license. Applicants are required to submit a site evidence package with visual evidence to demonstrate the completion and functionality of their facility.

Standard Cultivation License Requirements

  1. All of the requirements listed for Micro-Cultivation and Nursery Licenses above.
  2. The facility must have any on-site storage areas, operations areas, and the site perimeter surrounded by a physical barrier in order to safeguard against unauthorized access. It should be possible to demonstrate how the barrier’s construction, as well as the required access controls on the exit and entry points, are able to achieve this goal. Access to storage and operations areas must be restricted to authorized personnel only.
  3. A record must be made of everyone who enters and exits from storage areas.
  4. Each storage area must be located in a place that satisfies the security measures outlined in the Cannabis Regulations.
  5. The site perimeter, operations areas, and storage areas are required to be monitored by visual recording devices at all times to detect and record any unauthorized attempts, successful or unsuccessful, to access the site. Entry and exit points on grow areas must be visually monitored as well.
  6. The site perimeter, operations areas, and storage areas must have an intrusion detection system operating 24/7 to discover any unauthorized attempts to access the site or tamper with the system. It must also be possible to detect unauthorized movement within operations and storage areas.
  7. The intrusion detection system is required to be monitored at all times, and the license holder is responsible for determining what measures are appropriate in response to any incidents. In cases of an incident, the holder must retain a document that contains the date and time of the occurrence, how it was responded to, and the date and time of when that response took place.


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