The VCBC Responds to Health Canada’s Proposed Edibles Regulation Survey

1- What do you think about the proposed THC limits for the new classes of cannabis products?

The 10 mg per serving limit is far too low for consumers, especially anyone using cannabis for medical purposes.  There are several reasons this limit is unreasonable. After advocating for the end of prohibition for 24 years, it is disheartening to see such severe restrictions that will harm consumers, the environment, small business and government tax revenues.

For many regular cannabis consumers, 10 mg is an extremely small dose.  Personally, I can consume 100s of mg of THC before feeling its effects. This would mean i would require dozens of servings to achieve a desirable effect.  Even if the products were made so small that the amount of food I would typically eat might remain the same but the amount of packaging is absolutely excessive.

With so many stronger products currently available on the black market, it is unlikely that most consumers will switch to legal products if they are both more expensive and less potent.  If the government intends on drawing customers away from illegal suppliers, then it has to ensure that comparable products are available. If the 10 mg limit stands, the government is ensuring the black market will thrive, most products used by Canadians will not have been properly made and tested, plus a great deal of potential taxes and economic stimulation will have been lost.

Moreover, for patients using cannabis the 10 mg limit is a disaster.  Most patients dealing with chronic pain, cancer or other severe medical problems require far more than 10 mg of THC perserving to achieve relief.  Again these regulations will cause many people to use dozens of serving to achieve the desired effect, creating a massive garbage problem and unnecessarily causing the prices to go much higher.

It is common knowledge that the medical establishment wants to eliminate the program for patients to gain access to cannabis and force them to the general market.  If this happens with THC levels so low, we will see many patients suffer unnecessarily.

Indeed, in the Smith decision that made extracts legally available to patients, the judges clearly informed the government that any restrictions on cannabis derivatives needed to be based on science.  The science proves that cannabis, even in its most concentrated forms, is safer to use than most medications and fatal overdoses are impossible.

No doubt the matter of the 10 mg limit will end up back in front of the courts.  The government has little chance of convincing judges that these limits are necessary, epecially in light of the opiod crisis the country is experiencing.  It is impossible for the government to justify such a low limit in the face of a black market all to ready to sell the public what they desire and a lack of safe medications for doctors to prescribe to people in pain.

2-Do you think the proposed new rules addressing the types of ingredients and additives that could be used in edible cannabis, cannabis extracts, and cannabis topicals appropriately address public health and safety risks while enabling sufficient product diversity?

These proposed rules appear adequate.

3-Do you think that the proposed rules for other classes of cannabis will accommodate a variety of oil-based products for various intended uses, even though cannabis oil would no longer be a distinct class of cannabis?

It is hard to say what effect the government’s change in the classification of cannabis oil ill have on the variety of products available.  Seems like the real barrier to a variety of products will be the THC limits per package/serving. Without more information it appears all the government has done is refine the category that as formerly called cannabis oil and broken it down into three sections: edibles, extracts and topicals.  If the question is really, ‘Do we think these three new classes adequately break up cannabis oil in a way that is understandable and comprehensive’?, then we would agree that it is.

4-What do you think about the proposed six-month transition period for cannabis oil? Is a six-month transition period sufficient?

That seems like lots of time for the LPs to switch their products over to the new system of classification.  Without more information it is hard to understand why it could not be done in three months given the long advance warning the LPs have that this change will occur starting Oct 17, 2019.

5-What do you think about the proposed new rules for the packaging and labeling of the new classes of cannabis products?

The packaging and labeling rules seem adequate, except for the fact the small THC limits force consumers to purchase excessive plastic packaging. The requirements appear no different than any other food product and should be adequate.

6-With respect to edible cannabis, what do you think about the requirement for all products to be labelled with a cannabis-specific nutrition facts table?

Yes it makes perfect sense that given the very low THC limits on the edibles and extracts that the packages will be far too small to contain all of the information being required by the government.

7 -What do you think about the proposal that the standardized cannabis symbol would be required on vaping devices, vaping cartridges, and wrappers?

It appears adequate.

8-Do you think that the proposed new good production practices, such as the requirement to have a Preventive Control Plan, appropriately address the risks associated with the production of cannabis, including the risk of product contamination and cross-contamination?

9-What do you think about the requirement that the production of edible cannabis could not occur in a building where conventional food is produced?

This is absurd.  As long as the cannabis extracts are not directly added to the other non-cannabis recipes, there is no risk of getting THC into food products that are not intended to have it.  Such a requirement is built on fear and suspicion. This proposed regulation drastically limits commercial activity, stopping many in the existing food industry from entering the market and cutting off other potential revenue sources from new cannabis processors.

10-What do you think about the overall regulatory proposal?

This process is very frustrating.  The government is only seeking input after making several key decisions that they are unlikely to change regardless of public input.  The 10 mg limit on edible and extracts should not have been decided until after the public has had a reasonable opportunity to provide input.  Aside from the 10 mg per serving limit, these regulations appear adequate but that limit is a huge problem.

11-Are there any additional comments you would like to share on the proposed regulations for the new classes of cannabis?


If the government had intended on attracting consumers from the black market to legal suppliers, then the focus should be on regulating what is happening in the current marketplace.  The THC limits in these regulations ensure that recreational and medical consumers will continue to rely on the black market for the products they require.

Does the government know there is an opioid crisis sweeping the country?  Any unnecessary limitations on THC content will directly contribute to the death toll and suffering felt across Canada.  Access to the strongest medicines possibly made from this plant should b the focus of government, not excessive restrictions.

There are so many problems with the way all three levels of government appear to be handling the implementation of legalization that it would take a lengthy novel to spell it all out.

To start with the federal government needs to immediately begin registering small micro-production facilities, so the bulk of cannabis being grown in the country can jump fro the illegal industry to the legal one.  Tightly restricting the supply by only giving licenses to large corporations will certainly appease law enforcement and the stock market but it does nothing to shift the massive established cannabis industry over to the legal system.

Not allowing a retail license holder to also have a micro-processing or mirco-production facility is very harmful to compassion club like ours that have produced our own edible and topical products for years.  

We would list more problems with legalization but it seems very unlikely that any changes will be made as a result of consultation and that we will have to fight the government in court for years to come before the entire scheme is satisfactory.

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