Bill C-45 – Summary of Submissions The Cannabis Trade Alliance of Canada (CTAC) is a trade organization established to represent a broad range of cannabis industry participants. CTAC advocates for the creation of an inclusive framework. A healthy cannabis industry, like other sectors, is better served by a large number of small, medium and large businesses competing fairly (and regulated/taxed equally) for consumers, government and the general public to be best served. Licensing - Classes The mention of “classes” or “categories” of producers in the licensing framework are in-line with the recommendations put forth by CTAC to the Task Force. If properly implemented, separate licensing categories will lead to the creation of a viable inclusive industry, so long as there is flexibility to allow for a diversity of participants: Nursery, Grower, Processor, Laboratory, Retail, Wholesale. Security Clearance Process CTAC advocates for a clear, transparent, and accountable security clearance process. Section 62 of the Cannabis Act is an arbitrary tool to deny any current or future application based on a belief, without presenting any facts or evidence. It would also appear that individuals have no recourse or means to address and arbitrate those accusations. Canadians should expect more clarity and transparency – section 62 is a closed-door approach. How can business people be expected to invest into an industry without clear expectations? Extracts, Oils, Concentrates & Derivative Products Consumer demand for alternatives to smoking dried cannabis is driving the fastest growing category of cannabis products: cannabis extracts. Edibles, tinctures, topicals, sprays, capsules and vape pens are just a few of the diverse array of cannabis concentrate products being sought after for medical and recreational use. Reports predict that by 2020, oil consumption will grow by 198,000%. The move towards extract-based products supports public health policies that provide for safer and more discreet alternatives to combustion-based methods of cannabis consumption. Research CTAC fully supports the Task Force recommendation that the government “Promote and support preclinical and clinical research on the use of cannabis and cannabinoids for medical purposes, with the aim of facilitating submissions of cannabis-based products for market authorization as drugs”. Scientists have discovered 483 different chemical compounds in cannabis including 104 cannabinoids, over 100 different terpenes, more than 20 flavonoids in addition to other nitrogenous compounds and more common plant molecules. The therapeutic and medicinal effects for the vast majority of these compounds are still unknown and understanding how these work individually and in concert has barely just begun.
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Branding, Packaging, Potency & Labelling CTAC is strongly opposed to prohibitions on branding and the institution of ‘plain packaging’. Responsible branding and marketing are powerful tools to use against black market product. Restrictions on branding and marketing gives an unfair advantage to black market operators: without factual and informative branded packaging, consumers will be unable to distinguish legal product from low-quality, untested, black market product for cheaper prices. In addition, without branding, smaller legal producers will be unable to differentiate their products from larger, well-financed competitors. CTAC’s full submissions also contain recommendations on: •
Taxation and Pricing
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Home Cultivation
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Limitations on Quantities for Personal Possession
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Places of Use | Consumption Spaces
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Minimum Age and Teen Use
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Medical Cannabis
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