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Health Canada announced changes to the process of adding sale authorization of cannabis products to processing licences.
As of October 1, 2023, the federal health agency will phase out inspections for authorized activities change requests from processors to add the activity of sale of extract, edible, and topical cannabis products. This change applies to all processing licence holders, micro or standard.
While Health Canada made changes in 2022 to begin granting dried fresh sales licences to all processors, the application process for these sales licence amendments for extract, edible, and topical are still required to be filed through the CTLS.
However, the newly implemented changes do mean that processors will no longer need to request changes to inner and outer labels, no longer need to provide photos of the entire lot, or provide completed packaging records, a master list of SOPs, evidence that packaging meets the child resistance requirements, or proof that each lot or batch has been tested using validated test methods including evidence that test methods have been validated for the appropriate class of cannabis, such as method validation reports.
Despite no longer needing to provide this information as part of the authorized activities change request, processors will still need to adhere to these requirements, which can be verified by Health Canada inspection. Inspections will be organized by using a risk-based approach.
Health Canada says they will update the manage your cannabis licence webpage to reflect these changes.
The federal regulator will also no longer provide an in-person compliance promotion session to processors seeking a sales licence, replacing it with compliance promotion material that will be accessible online.
Licence holders will still be required to submit their Notification of New Cannabis Product (NNCP) 60 days prior to selling extract, edible and topical cannabis products to provincially and territorially authorized retailers and sale for medical purposes licence holders once their licence has been amended.
More information is available here and in the guidance document Overview: Preventive control plan for cannabis extracts and edible cannabis.
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