A processing licence (standard or micro) is required in order to produce edible cannabis and to package and label this type of cannabis product for sale to consumers. In order to sell products within this new class of cannabis, individual licensed processors will need to apply to Health Canada to amend their licence.
It is important to note that the Quality Assurance Person is required to have the necessary training, experience, and technical knowledge applicable to the class of cannabis they are producing. If the Quality Assurance Person does not have the qualifications required for edible cannabis, the licensed processor must retain the services of another individual with the necessary qualifications.
Restricting the use of certain types of ingredients (no added vitamins or minerals) and limiting the use of others (caffeine).
Placing a limit of 10 mg of THC in each individual package of edible cannabis product.
Requiring child-resistant and plain packaging for edible cannabis. All packaging is required to display the standardized cannabis symbol and a health warning message.
Prohibiting any claims regarding health, dietary or cosmetic benefits on the label.
Requiring the production, packaging, labelling, and storage of edible cannabis products to be conducted in a separate building from the production, packaging, and labelling of food products.
All edible cannabis products must be shelf-stable and cannot require refrigeration or freezing. The use of meat, poultry and fish products will be restricted exclusively to dried products. Additives are limited to food and food additives in accordance with the Food and Drug Regulations. The sale of edible cannabis products in a hermetically sealed container (ie. can) are prohibited if the edible cannabis product has a pH above 4.6 and a water activity higher than 0.85 at a temperature of 22°C.
The immediate container of edible cannabis products must be ‘food-grade’ and meet the requirements of the Food and Drug Regulations and the Safe Food for Canadians Regulations. Multi-packs of edible cannabis will be permitted provided the total quantity of THC in the multi-pack does not exceed 10 mg and the total amount of cannabis in the multi-pack does not exceed the public possession limit of 30 grams (dried cannabis equivalent). It is a requirement that each of the products in the multi-pack be consistent (no sampler packs).
With the legalization of edible cannabis products, there are many public health and safety risks to consider including food-borne illness and cross-contamination. Manufacturers of edible cannabis and cannabis extracts will need strict manufacturing controls for production and handling, including development and implementation of a written Preventive Control Plan (PCP). These new control measures are drawn from and align with requirements that apply to food products under the Safe Food for Canadians Regulations.
Does your PCP cover all the risk assessment of all potential hazards?
Does your PCP answer the who, what, when and how of the designed process?
Does your PCP describe the risks to food, including how they are controlled?
Does your PCP describe the measures to take to meet other regulatory requirements for standards, packaging and labelling?
Licensed processors (that produce edible cannabis or cannabis extracts) are required to prepare, retain, maintain and implement a PCP to identify and address through effective control measures any potential hazards that pose a risk of contamination for these products. The Quality Assurance Person (QAP) must sign-off on the PCP prior to its implementation. Furthermore, the PCP must include documents that show evidence that the requirements of the PCP have been met. A PCP must be reviewed and updated when there are changes to any of the conditions considered during the PCP development process. This include changes to process, ingredients, regulatory requirement, formulations, responsibilities etc.
The manufacture of all cannabis products (cannabis edibles, cannabis extracts, cannabis topicals) in the same building as regular food products is prohibited. The production, packaging, labelling, and storage of cannabis and the production, packaging, and labelling of food products will need to be conducted in separate buildings.
Food-grade packaging (i.e. packaging that meets requirements set out in the Food and Drugs Regulations and the Safe Food for Canadians Regulations for food) must be used for the immediate container of edible cannabis and for any wrappers of edible cannabis and cannabis extracts intended to be ingested.
Only food and food additives will be allowed to be used as ingredients in edible cannabis products. Edible cannabis products will not be allowed to contain poisonous or harmful substances, nor will it be permitted to fortify edible cannabis with vitamins or mineral nutrients.
Edible cannabis products must be shelf stable (i.e. not requiring refrigeration or freezing) and ingredients such as raw meat, poultry and fish are strictly prohibited.
Edible cannabis products as well as ANY ingredients used to produce them will be subject to controls that are designed to address the risks of food-borne illness and contamination.