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Summary of changes following the streamlining of regulations

On March 12, 2025, the Regulations amending certain regulations concerning cannabis (streamlining of requirements) and the Order Amending Schedule 2 to the Cannabis Act came into force. The Order Amending the Cannabis Tracking System Order (Cultivation Waste) will come into force on April 1, 2025.

The Regulatory Impact Analysis Statement was published in the Canada Gazette, Part II and a notice of the amendments was published in the First Nations Gazette. The Regulatory Impact Analysis Statement describes all of the changes made to the:

These amendments will reduce regulatory burden and support diversity and competition in the legal cannabis market while maintaining the Act's public health and public safety objectives, and will affect both licence holders and applicants. Health Canada is updating online web pages, and will publish them over the coming months. In the meantime, you can contact cannabis@hc-sc.gc.ca to request a copy of pages not yet updated. Licence holders and applicants are still required to meet the requirements of the amended regulations.

The official regulatory amendments can be found in the Canada Gazette, Part II, and a summary of the regulatory changes can be found below.

Summary of changes

General considerations for licence holders

Licence holders are responsible for updating all internal process or specification documents to reflect new processes at their site as permitted by the amended regulations.

Licence requirements for non-human and non-animal research

In certain cases, a research licence is no longer required to possess up to 30 g of dried cannabis or its equivalent for non-human and non-animal cannabis research.

For licence holders

If your research activities meet all the requirements of section 28.01 of the Cannabis Regulations, you don't need a research licence. You can either continue to hold a research licence or you can request to revoke your licence.

To revoke your licence, or if you have questions about this regulatory change, email Health Canada at sp-licensing-cannabis-licences-sp@hc-sc.gc.ca and use the subject line "Revocation question for research under 30 g for LIC-#".

Your licence will remain valid until Health Canada confirms that it's been revoked. Until then, you must continue to meet all requirements under the Regulations and the Act.

For applicants

If your intended research activities meet all the requirements of section 28.01 of the Cannabis Regulations, you can choose to withdraw your licence application.

Applicants can continue to apply for a research licence even if they possess less than 30 g of dried cannabis or its equivalent.

If you have questions about this regulatory change email Health Canada at sp-licensing-cannabis-licences-sp@hc-sc.gc.ca and use the subject line "Question for research under 30 g for APP-#".

Limits for micro-cultivation, nursery and micro-processing licences

New limits for micro-cultivation, nursery and micro-processing licences

For licence holders

If your activities meet the requirements for a micro or nursery licence, you can request to change your licence subclass from standard to micro or nursery.

It's important to note that if you transition from a standard processing licence to a micro-processing licence, you're no longer allowed to produce cannabis by synthesis.

If you want to change your licence subclass from standard to micro or nursery, email licensing-cannabis-licences@hc-sc.gc.ca for instructions. Use the subject line "Changing licence subclass from standard to micro for LIC-#".

The annual regulatory fee is lower for micro class licences. However, your annual regulatory fee is based on the licence class you hold on April 1. If you still hold a standard class licence on April 1, you must pay the full standard licence annual regulatory fee. This includes if you switch to a micro licence at a later time during the year. If you have questions about the fees associated with your licence, email cannabiscrf-rcf@hc-sc.gc.ca.

For applicants

If your intended activities meet the requirements of a micro or nursery licence, you can change your licence application from:

It's important to note that if you apply for a micro-processing licence, you aren't allowed to produce cannabis by synthesis.

If you would like to change your application, email licensing-cannabis-licences@hc-sc.gc.ca . Use the subject line "Changing licence subclass from standard to micro for APP-#".

The application screening fee is non-refundable, and any difference in fees will not be refunded if you transfer to a micro licence.

Alternate quality assurance persons (QAPs)

Processing licence holders are now allowed to have more than 2 alternate quality assurance persons (QAPs). QAPs can now delegate activities while maintaining accountability and overall responsibility.

For licence holders

You can submit a change request to add more alternate QAPs in the Cannabis Tracking and Licensing System (CTLS).

For applicants

If you have already submitted your application and want to add new alternate QAPs, email licensing-cannabis-licences@hc-sc.gc.ca . Use the subject line "Request to add a new alternate QAP for APP-#".

Note that licences can't be issued until all people associated with the licence requiring security clearances have been issued their security clearance. Adding a new alternate QAP after submission may delay the issuance of your licence. However, you can add additional alternate QAPs after receiving your licence.

Cultivation and research licence holders authorized to sell pollen to other licence holders

For licence holders

Existing cultivation and nursery licence holders are not allowed to obtain, sell or distribute cannabis pollen due to restrictions on their licence. If you would like to change your licence, email licensing-cannabis-licences@hc-sc.gc.ca . Use the subject line "Adding pollen for LIC-#".

For applicants

All new cultivation, nursery and research licences will be allowed to obtain, sell or distribute cannabis pollen when they receive their licence.

Changes to the Consumer information document requirements

Licensed processors no longer need to provide paper copies of the Consumer information document to provincially or territorially authorized retailers or consumers. Sale for medical purposes licence holders and heads of hospitals must continue to provide the document to registered clients or patients or responsible adults respectively when cannabis is distributed or sold to them.

Changes to import and export requirements

Licence holders no longer need to provide:

Contraventions of the Cannabis Fees Order

Health Canada may now suspend any licences for a contravention of the Cannabis Fees Order.

Production of derivatives with exempted plant parts

You can now produce, import, export, sell and process derivatives with exempted plant parts (listed in Schedule 2 to the Cannabis Act) without a licence. However, if you wish to isolate or concentrate phytocannabinoids from cannabis stalks, you need a cannabis processing licence.

For licence holders

Depending on your activities, you can choose to keep your licence along with all the applicable requirements, or you can request to revoke your licence.

For applicants

Depending on your intended activities, you may not need to apply for a licence. You can choose to withdraw your licence application.

Presence of a security-cleared person

You're no longer required to have a security-cleared person on-site when you're conducting activities with cannabis. You're also no longer required to have them accompany cannabis during off-site antimicrobial treatments.

Physical security measures for certain licences

Changes for standard cultivation, standard processing, sale for medical purposes with possession of cannabis and some cannabis drug licences include:

In addition to the regulatory changes, cultivation waste (defined as leaves, shoots or branches obtained during cultivation, propagation or harvesting of cannabis and are intended for destruction) can now be stored in operations areas, including outdoor grow areas. Licence holders are required to meet the good production practices to ensure the quality and safety of the cannabis that will be processed or stored with cultivation waste.

For licence holders

Licence holders who decide to remove the impacted physical security requirements may need to submit an updated organizational security plan.

For applicants

Applicants who have already submitted a licence application don't need to change their application. Health Canada will not review this information.

Applicants who decide to remove the impacted physical security requirements may need to submit an updated organizational security plan. If you've already submitted your application and want to submit an updated plan, email licensing-cannabis-licences@hc-sc.gc.ca. Use the subject line "Request to update OSP for APP-#".

Pre-rolled cannabis

Pre-rolled dried cannabis no longer has a limit of 1 g.

Ethyl alcohol in limited cases

You can now use ethyl alcohol (up to 10 mg per activation) in cannabis extracts intended for inhalation, and denatured alcohol in cannabis topicals.

Packaging and labelling changes

Changes include:

For licence holders

Licence holders can use the old labels displaying the actual THC and CBD quantity or concentration in bold for 1 year until March 12, 2026. After March 12, 2026, labels applied to products must meet the new requirement and licence holders can choose to continue displaying the actual THC and CBD quantity or concentration, but this information cannot be displayed in a bold font. Provincially or territorially authorized retailers can continue to sell products with old labels indefinitely.

Substances applied to cannabis

You are no longer required to record the following information about substances applied to cannabis:

Notice of new cannabis product

You are no longer required to submit a Notice of new cannabis product for dried and fresh cannabis products.

For licence holders

If you have already submitted a Notice of new product for dried or fresh cannabis product, you can begin selling these products right away. You don't need to wait 60 days before selling them.

Licence holders must still submit a Notice of new cannabis product for any new cannabis topical, extract or edible products at least 60 days prior to sale.

Retention of record of ingredient list for shipments

You are no longer required to retain a document that contains the list of ingredients for cannabis extracts, cannabis topicals or edible cannabis when selling, distributing or exporting cannabis.

Destruction of cannabis

Changes to record-keeping requirements for the destruction of cannabis include removing requirement to:

Changes to destruction witnessing requirements include:

Monthly Cannabis Tracking System (CTS) reporting

Effective April 1, 2025, licence holders are no longer required to report on plant trimmings (cultivation waste) for whole cannabis plants and vegetative cannabis plants in their monthly CTS reports. In addition, the unit of measurement for unpackaged seeds in CTS reports will change from the weight of seeds (in kg) to the count of seeds (whole numbers).

Starting with the monthly tracking report for April 2025 (due May 15), the plant trimmings fields will no longer appear for whole cannabis plants and vegetative cannabis plants when using the manual entry report format. These fields will also be inactive in the.csv file template. The data fields for unpackaged seeds will be updated to reflect seed count and there will be updated system validation to ensure that the new unit of measurement is captured in monthly tracking reports.

Annual promotion report

You're no longer required to submit and keep an annual report of promotional (advertising) expenses. Licence holders still need to keep a sample or copy of any promotional materials for at least 2 years after the day on which the promotion ended.

Key investor reporting

Changes include:

Hemp seed derivatives

Removing hemp seed derivative requirements under the Industrial Hemp Regulations, including:

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