Applying for a micro-cultivation, nursery and micro-processing licence

On this page

1. 1.0 Authorized activities for micro-cultivation and nursery licences
2. 2.0 Authorized activities for micro-processing licences
3. 3.0 Scaling up to a standard licence

This page provides the information about limits on authorized activities and how to:

• calculate your grow surface areas
• calculate your possession limits
• scale up to standard cultivation or standard processing licences

1.0 Authorized activities for micro-cultivation and nursery licences

There are different authorized activities for micro-cultivation and nursery licences.

1.1 For micro-cultivation licences

A micro-cultivation licence allows you to produce cannabis plants, seeds, pollen and fresh and dried cannabis. You can use a grow surface area (plant canopy) of up to 800 m² for growing cannabis plants. The grow surface areas include:

• all horizontally and vertically arranged surfaces
• all indoor and outdoor cultivation operation areas that you are using at any single time

Your size limit only includes operations areas where you'll be:

• growing cannabis plants
• propagating and harvesting cannabis plants and seeds

There's no size limit for areas used for non-cultivation activities and storage.

You need Health Canada's approval to add outdoor grow areas after you've received your licence. You won't be able to use the area until Health Canada approves it. After the grow areas are approved, you don't need to notify Health Canada if you decide not to use them.

1.2 For nursery licences

A nursery licence allows you to produce cannabis plants, seeds and pollen for starting material. You can have up to 20 kg of harvested flowering heads at any time (except seeds). You must destroy flowering heads (except seeds), leaves and branches of the plants within 30 days of harvesting them.

You can use a grow surface area (plant canopy) of up to 200 m² for growing flowering and budding cannabis plants. The grow surface areas include:

• all horizontally and vertically arranged surfaces
• all indoor and outdoor cultivation operation areas that you are using at any single time

Your size limit only includes operations areas where you'll be growing flowering and budding cannabis plants.

There is no size limit for:

• areas used to grow cannabis plants in their vegetative stage (mother plants, or plant cuttings or clones that are non-budding or non-flowering)
• areas used for non-cultivation activities and storage

Figure 1 shows an example where the non-budding and non-flowering cannabis plants aren't included within the 200 m² size limit. The flowering and budding cannabis plants are only grown in the indoor area (100 m²) and the outdoor area (100 m²). The total grow surface area that counts towards the limit is 200 m².

Figure 1 - Text version

The image shows an indoor grow surface area (100 m²) that is counted towards the limit. There is another indoor grow surface area that's for non-budding or non-flowering plants (400 m²) that doesn't count towards the limit. There is an outdoor grow area (100 m²) that is counted towards the limit.

You need Health Canada's approval to add outdoor grow areas after you've received your licence. You won't be able to use the area until Health Canada approves it. After the grow areas are approved, you don't need to notify Health Canada if you decide not to use them.

1.3 Calculating a grow surface area

This section provides information on how you can calculate your total grow surface areas. Figure 2 represents what 800 m² looks like compared to a hockey rink.

Figure 2 - Text version

The image shows a top-down view of a standard hockey rink, measuring 61 metres by 26 meters. The rink is divided in half horizontally. The lower half of the rink is shaded in green, roughly representing the maximum grow area size allowed for a micro-cultivator.

You can calculate grow surface areas using different methods. You can combine these methods. Don't exclude areas or count them more than once. You'll need to provide your calculations in your site evidence package. For example, you can calculate:

• the total surface area of all plants
• the total surface area of all equipment (such as grow trays or grow tables)
• the total surface of all grow areas

Your total grow surface area can be made up of only indoor or outdoor grow areas, or both. The total grow surface areas in use can't exceed the size limit at any given time. If you use different areas according to the seasons, calculate your total grow surface area for those periods, such as during both the warmer and colder months.

The following operations areas and storage areas aren't included in the grow surface area calculations:

• areas where there's no cannabis growing
• storage areas only used for the storage of cannabis
• operations areas only used for packaging and labelling cannabis
• walkways used to access the grow trays, grow tables and row crops of cannabis plants in operations areas for growing cannabis

No matter how you decide to calculate your grow surface area, it needs to include all parts of the cannabis plant.

1.3.1 Surface area of each cannabis plant

If you use the surface area of each cannabis plant to calculate your grow surface area, you need to include all parts of the plant. This includes all the leaves and branches, such as the canopy, the over-hanging leaves and branches. You will need to ensure that your grow surface area doesn't exceed the limit as your plants grow to their mature size. There's no limit on the height of the cannabis plants.

For example, Figure 3 shows 2 correct plant surface areas (left and centre) that include all the cannabis leaves and branches. The area on the right is wrong, as parts of the cannabis leaves and branches aren't included.

Figure 3 - Text version

The cannabis plants on the left (1 m in width) and the centre (3 m in width) show correct estimations of the plant surface areas because they include the leaves and branches that are over-hanging out from the pots. The cannabis plant on the right (1 m in width) shows an incorrect estimation of the plant surface area because it doesn't include the leaves and branches that are over-hanging out from the pot.

1.3.2 Surface area of equipment

If you use the surface area of each piece of equipment, such as grow table or shelf to calculate your grow surface area, you need to include all parts of the plant. This includes all the leaves and branches, such as the canopy, the over-hanging leaves and branches. There's no limit on the height of the cannabis plants.

You also need to include all surfaces if the equipment unit has horizontal or vertical trays.

Figure 4 shows the total grow surface area of a shelf unit. This shelf unit has 3 trays, each is 6 m² (2 m by 3 m). This means that this shelf unit's grow area is 18 m² (numbers of trays multiplied by the surface area of 1 tray) if no part of the cannabis plant is over-hanging.

Figure 4 - Text version

There is a shelf with 3 layers of trays. The trays' dimensions are 2 m (width of tray) by 3 m (length of tray).

1.3.3 Surface area of general grow areas

If you use the general grow area to calculate your grow surface area, you still need to include all parts of the plant. This includes all the leaves and branches, such as the canopy, the over-hanging leaves and branches.

You can calculate using the size of your indoor grow room or outdoor grow area. You can exclude non-grow areas such as the space between row crops.

Figure 5 shows a grow area where cannabis plants are grown in row crops. With 7 row crops of 30 metres by 3 metres, this grow surface area is 630 m². You don't have to include the non-grow areas between the row crops in your surface area calculation.

Figure 5 - Text version

The total area is 30 metres by 45 metres. There are 7 green-shaded rectangles showing row crops. The row crops are 30 meters by 3 metres. The spaces between the grow areas don't count toward the limit.

Figure 6 shows how a micro-cultivation licence can have a total of 1,400 m² of indoor (800 m²) and outdoor (600 m²) grow areas on their site. In the warmer months, they only use 200 m² of indoor grow areas and 600 m² of outdoor grow areas. During the cooler months, they only use 800 m² of indoor grow areas. Overall, they don't exceed the 800 m² size limit at any given time.

Figure 6 shows how a micro-cultivation licence can have a total of 330 m² of indoor (200 m²) and outdoor (130 m²) grow areas on their site. In the warmer months, they only use 70 m² of indoor grow areas and 130 m² of outdoor grow areas. During the cooler months, they only use 200 m² of indoor grow areas. Overall, they don't exceed the 200 m² size limit at any given time.

Figure 6 - Text version

There are 2 separate floorplans showing the grow surface areas used during the warmer months and cooler months. The warmer months' image shows that an outdoor area (600 m²) and an indoor area (200 m²) are used. 1 indoor area (600 m²) isn't used during this period of time. The cooler months' image shows that both indoor areas (600 m² and 200 m²) are used. 1 outdoor area (600 m²) isn't used during this period of time.

1.3.3.1 Irregular grow surface areas

If it's hard to calculate the total surface of irregularly shaped grow areas, you can break it down into regular shapes (such as squares, rectangles and triangles). You can then calculate the surface area of each shape, and add the total surface areas to get an estimation. You'll need to show how your estimation is not an under-estimation.

Figure 7 shows an example of breaking up the total surface for an irregularly shaped grow area. The area is broken into regular shapes, 2 triangles and 2 rectangles. The smaller shapes cover more than the actual area.

Figure 7 - Text version

An irregularly grow area that's divided into 2 triangles and 2 rectangles.

1.3.4 Examples of grow surface area calculation

Here's an example of how to calculate your grow surface area. A micro-cultivator has multiple types of grow areas, including:

• 5 vertical shelf units with 3 trays each. Trays are 8 m² (2 m by 4 m). Each vertical shelf unit is 24 m² (8 m² multiplied by 3 trays)
• 1 outdoor area only used during warmer months. Area is 400 m² (40 m by 10 m)
• 10 tables. They're 10 m² (2 m by 5 m)
• 1 indoor area only used during colder months. Area is 200 m² (20 m by 10 m)

Since the grow areas change in the warmer and colder months, the micro-cultivator will need to calculate the total grow surface area twice.

For warmer months

The micro-cultivator's total grow surface area during the warmer months is 620 m². They're compliant with the 800 m² total surface grow area limit.

For colder months

The micro-cultivator's total grow surface area during the colder months is 420 m². They're compliant with the 800 m² total surface grow area limit.

2.0 Authorized activities for micro-processing licences

A micro-processing licence allows you to produce all types of cannabis, other than by synthesizing, cultivating, propagating, or harvesting it. You can possess up to 2,400 kg of dried cannabis (or its equivalent amount) in a calendar year.

Cannabis in inventory carried over from the previous calendar year is included in the current year's possession limit. The licence holder can't be in possession of more than 2,400 kg of dried cannabis (or its equivalent amount) in a calendar year.

The possession limit doesn't apply if the only cannabis you possess was grown from your own micro-cultivation licence at the same site. However, the limit will apply if you grow your own cannabis and get cannabis from other licence holders. This means that the total amount of cannabis you possess, including the cannabis grown on own site and from other licence holders, must not exceed the possession limit.

Cannabis plants and seeds don't count towards the possession limit.

If you receive other types of cannabis besides dried cannabis at your site, refer to the equivalency table to calculate your dried cannabis equivalency. The table lists the equivalent amount to 1 kg of dried cannabis for other types of cannabis. However, you may also need to refer to the definitions for the types of cannabis to help you determine which type it belongs to.

These general examples of types of cannabis are to help you determine the equivalency.

• Fresh cannabis
  • Freshly harvested cannabis buds and leaves
• Solids containing cannabis, such as substances that are in a solid form at room temperature with a low level of THC (3% or less)
  • Solid edible cannabis such as baked goods
  • CBD crystals with a low concentration of THC (3% or less)
• Non-solids containing cannabis, such as substances that are in a non-solid form at room temperature with a low level of THC (3% or less)
  • Cannabis topicals, such as lotions, liquid soaps and oil applied to hair and skin
  • Cannabis extracts, such as CBD oil, and capsules containing CBD oil
  • Non-solid edible cannabis, such as beverages
• Cannabis concentrates, such as extracts or other substances that have a high concentration of THC (more than 3%) like kief

If you have both a micro-processing licence and a micro-cultivation licence at the same site, depending on whom you receive your cannabis from, the possession limit is calculated in 1 of 2 ways:

1. If you receive any cannabis (except plants and seeds) from other licence holders

The yearly possession limit of 2,400 kg of dried cannabis (or its equivalent amount) includes the total amount of the following:

• all the cannabis (except plants and seeds) you received from other licence holders
• all the cannabis harvested from your own micro-cultivation licence at the same site
• any cannabis you received in the last calendar year that wasn't sold or distributed

2. If you don't receive cannabis from other licence holders (except plants and seeds)

This means you only possess cannabis harvested from your own micro-cultivation licence at the same site or receive only plants and seeds from other licence holders. In this case, the 2,400 kg possession limit does not apply. You can process all the cannabis harvested from your micro-cultivation licence.

2.1 Calculating a possession limit

Calculating your possession limit can be divided into two steps.

1. Calculate the equivalency of other types of cannabis.

Use the equivalency table and this formula to calculate your dried cannabis equivalent.

(Amount of one type of cannabis) divided by (Amount that is equivalent to 1 kg of dried cannabis)

2. Add up all your dried cannabis and equivalent to dried cannabis amounts.

Example 1: A licence holder with a micro-processing licence receives cannabis from another licence holder

Cannabis from previous calendar year

• Received 2,400 kg of dried cannabis
• Didn't sell or distribute 120 kg of dried cannabis

Cannabis from current calendar year

• 190 kg dried cannabis each month

Since this micro-processor has 120 kg of dried cannabis left over from the previous year, they can only possess 2,280 kg of dried cannabis this year (2,400 kg yearly possession limit minus 120 kg from previous year). In this example, since the micro-processor only possessed dried cannabis, there's no need to calculate the dried cannabis equivalency.

The formula to calculate the total dried cannabis possessed within 1 calendar year is:

Total amount of (cannabis from current calendar year) + (cannabis from the previous calendar year)

• = (dried cannabis received monthly x 12 months) + (120 kg of dried cannabis)
• = (190 kg of dried cannabis x 12 months) + (120 kg of dried cannabis)
• = 2,280 kg of dried cannabis + 120 kg of dried cannabis
• = 2,400 kg of dried cannabis

The micro-processor complied with the Cannabis Regulations because they didn't possess more than 2,400 kg of dried cannabis within 1 calendar year.

Example 2: A licence holder with a micro-processing licence and a micro-cultivation licence at the same site receives cannabis from other licence holders

A licence holder receives cannabis within a calendar year from their own micro-cultivation licence and from other licence holders. The breakdown is:

• 2,000 kg of fresh cannabis harvested from their own micro-cultivation licence at the same site
• 8,000 kg of non-solids containing cannabis from licence holder A
• 300 kg of cannabis concentrates from licence holder B
• 25 kg of cannabis plants and seeds from licence holder C

In this example, the steps to calculate the total dried cannabis possessed are:

1. Exclude any amount that doesn't count towards the possession limit. In this case, the plants and seeds from licence holder C don't count towards the possession limit. Convert the total amount of each type of cannabis to dried cannabis.
   • 2,000 kg of fresh cannabis ÷ 5 kg equivalent = 400 kg of dried cannabis
   • 8,000 kg of non-solids containing cannabis ÷ 10 kg equivalent = 800 kg of dried cannabis
   • 300 kg of cannabis concentrates ÷ 0.25 kg equivalent = 1,200 kg of dried cannabis
2. Add the total dried cannabis equivalency amount received within 1 calendar year. In this example, the formula to calculate this is:
   • 400 kg of dried cannabis + 800 kg of dried cannabis + 1,200 kg of dried cannabis = 2,400 kg of dried cannabis

The licence holder complied with the Cannabis Regulations because they didn't possess more than 2,400 kg of dried cannabis at any time in the calendar year.

Example 3: A licence holder with a micro-processing licence and a micro-cultivation licence at the same site that only receives cannabis plants and seeds from another licence holder

A licence holder with a micro-processing licence and a micro-cultivation licence at the same site receives the following cannabis in a calendar year:

• 12,500 kg of fresh cannabis from their own micro-cultivation licence at the same site
• 25 kg of cannabis plants and seeds from another licence holder

In this example, the only cannabis the licence holder received from another licence holder were plants and seeds. The cannabis they possessed is from their own micro-cultivation licence at the same site, so the possession limit doesn't apply. As a result, the licence holder complied with the Cannabis Regulations even though they possessed more than 2,400 kg equivalent of dried cannabis within 1 calendar year.

3.0 Scaling up to a standard licence

Micro-cultivation, nursery and micro-processing licences can start with a modest-sized site and scale up later to a standard cultivation or standard processing licence. Scaling up to a standard licence will remove the grow area limit or possession limit, depending on your initial licence.

3.1 Before receiving your licence

If your micro-cultivation, nursery and micro-processing licence application is being processed and you want to change to a standard licence application, there are 2 methods to do this.

Transfer method

1. Create the new standard licence application
2. Transfer all your information to the new application. Health Canada doesn't return information or data submitted
3. Responsible person links the identified people from the original application to the new application
4. If your original application is in active review, contact Health Canada immediately by email at licensing-cannabis-licences@hc-sc.gc.ca. The subject line should be, "Subclass change to APP #" of the new or existing licence application

In this case:

• you won't have to pay the security clearance application fees again
• your application-screening fee won't be refunded or transferred to the new application. You'll have to pay another application-screening fee for the standard licence application

Withdraw method

To withdraw, click on the delete button on the Licence application page in the CTLS. If you withdraw your licence application before starting a new standard licence application:

• the security clearance applications for your identified people may be deactivated and you may have to pay the security clearance application fees again
• your application-screening fee won't be refunded or transferred to the new application. You'll have to pay another application-screening fee for the new licence application

3.2 After receiving your licence

You can scale up to a standard cultivation or standard processing licence after you receive your initial licence.

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