What Might Cannabis 3.0 Look Like?
Published on May 15, 2020
Author: Anthony Brunski
Cannabis 2.0 is finally here but the question is what comes next for legalized cannabis in Canada?
Health Canada has made indications that the next step of legalization could very well be Cannabis Health Products (CHPs). Although Health Canada hasn’t revealed any concrete plans yet, they had a public consultation from July - September of 2019 to gain feedback on the potential legalization of CHPs.
In addition to this, Health Canada provided information on what CHPs are and how they envision regulating this product class. Although these potential regulations may change a lot before they become reality they still give important insights into what legalized CHPs might look like.
CHPs are essentially Natural Health Products (NHPs) that contain cannabis. In other words, they are cannabis products with potential therapeutic uses for minor ailments such as pain relief. Like NHPs, they would not require prescriptions or the oversight of a health practitioner such as a doctor. Health Canada has indicated these products can be both for human and animal use. Much like Natural Health Products, CHPs would be allowed to contain various medicinal and non-medicinal ingredients as long as the efficacy of these ingredients is supported by evidence. These products would also be able to make health claims (approved by Health Canada) about improving or maintaining an individual’s health.
Although CHPs will be very similar to NHPs, it appears that CHPs will be regulated much more strictly. For example, health claims for CHPs will be more restrictive as Health Canada does not want to normalize or promote the consumption of cannabis. General health claims about health maintenance, support, and promotion will not be allowed. Specific health claims will be allowed but they will need to be supported by evidence. The level of evidence required will be higher than that of NHPs. For example, a history of use of that product in traditional medicine would not be considered sufficient evidence. Similarly, cannabis must be an active ingredient in the product and the health claim must directly result from its presence. In other words, you would not be able to just add cannabis to an existing NHP and get it approved as a CHP.
In terms of retailing, Health Canada has indicated that CHPs would require the same licensing as all other current legal cannabis products. This would mean to produce CHPs you would need to become a Licensed Producer of cannabis. It also means that CHPs would only be able to be sold at the same retail locations as other cannabis products such as brick and mortar stores or online provincial retail sites. In terms of labelling, CHPs would likely have a hybrid label that is a combination of current Cannabis and Natural Health Product labels. More specifically, the labels would have to contain NHP information such as dosing, directions for use, a listing of ingredients, and side effects. The labels would also need to contain features from cannabis product labels designed to protect youth such as the standardized cannabis symbol and health warning messages.
Looking Towards The Future
Although Health Canada has only provided preliminary details about CHPs they provide an interesting look at how these products might be introduced to the Canadian market. It will be interesting to see what the regulations for CHPs will look like once they’re fully established. The question now is what impact the public consultation might have on Health Canada’s approach to these products. There is no doubt that some portions of the public are going to be unhappy that Health Canada wants only licensed producers of cannabis to be able to produce/sell these products. Regardless, the introduction of CHPs is definitely needed as they fill an important gap that currently exists in the Canadian cannabis market.
Find Out More
If you are interested in obtaining a cannabis license, NaturalSci Regulatory Consulting can help you to get started. The best place to start is to set up a consultation with one of our specialists. Click the link below to get in touch with us.