As much as we are a medical cannabis sales only license, we have some working experience in the adult recreational space. These are our opinions only, on what we think should be done to improve the Canadian adult recreational industry. We will discuss our vision of medical cannabis in a different post.
- 10% Ad Valorem Tax. Not to beat a dead horse on this one, as this has been well vocalized. Get the tax reasonable and more in line with alcohol. This will allow LPs to maybe survive, keep jobs and the economy going in many rural areas. Consider the unpaid excise tax reports in the media, it just make sense to keep taxes flowing and sustainable.
- One Federal Excise Stamp or a National Digital Code. Mirroring alcohol will be a theme. It is a labour nightmare for LPs to manage inventory stamps for all provinces and territories, let alone applying the stamps to perhaps 10,000’s-100,000’s items per order, all of strange shapes and packaging pending on the SKU. If you never seen an excise party, it is a sight to see.
- Remove 2.3% annual regulatory fee. Match tobacco with no fee – seems fair.
- The 10 mg THC Limit. This one is something as pharmacist’s we have a different take. Yes, cannabis cannot kill you, but it can make a person feel pretty awful and cause ER visits. We also get that some medical patients may require higher oral doses. Sending consumers to the illicit market makes no sense either. Our recommendation is up to 100 mg of THC per package in edibles, either in 10mg x 10 format or 25 mg x 4 units, but with a specific high alert packaging. Solid extracts with 1000 mg limit we still support, but a 25 mg per unit is reasonable with high alert packaging. Tablets, softgels are less appealing for accidental consumption. We feel pharmacies and medical cannabis could be a solution for customized dosing for patients requiring dosing beyond these formats, though they would be rare.
- Farmgate/Retail model in all provinces. The cannabis plans of many producers was originally to develop a vertical, seed to sale integration. Depending on the province, that really has not happened. Provincial Boards have really handicapped producers from even getting their products in front of a consumers, let alone high forcing lower prices due to their high markups. If a province does not list an LPs product, it sits in a vault and likely goes bad, or gets sold at less than cost of production just to get some cash flow. Provinces need a model to allow ALL LPs, or at least in their LPs in their respective provinces to get theirs product in front of a consumer somehow. One simple way is if the provincial distributer will not wholesale the product, the producers need to be able to sell directly to a dispensary, via an online, traceable portal, where the province can get a service fee for providing the service, and the dispensaries can access an unlimited supply of legal products and producers at least have a chance of competing. For provinces with no private model, they need to offer something to their local LPs at least.
- Indigenous retail. Both federal and provincial bodies need to make an effort to get an agreement somehow to allow legal LP products to enter indigenous retail environments. The point of legal cannabis was to provide safety to Canadians with tested, safe products. This would ensure that customers will have access to at least Health Canada tested products. Create a excise/HST rebate or partnership with the indigenous communities and everyone will benefit.
- CTLS Reporting for ACMPR Designated Growers. Report the quantities of cannabis and cannabis products being provided and to whom. Do not even report any financial information. One would think any legitimate medical provider would be fine with this process. Abnormalities would simply trigger an inspection or audit.
- 19+ Consumption Events. Why are non-combustible cannabis products not allowed in restaurants or concerts, or sporting events where alcohol is consumed? And if outdoor concerts and events have designated smoking areas, why should cannabis be frowned upon. Reduce the stigma, but post-COVID, everyone needs more revenue, especially in the hospitality industry.
- More Branding and Advertising and Public Sampling. You cannot drive by a lounge or bar without alcohol signs, and they have their names in under 19+ public area, and on buildings like arenas. Have you been to Las Vegas lately? Branding on every cab/van on the strip. Maybe a little extreme, but perhaps in Canada we ease off a bit. Also, being in Nova Scotia, I get offered to try an alcohol product almost every time I go to our NSLC. Why not a take home 0.3 gram trial product?
- Reduce the Security Requirements for LPs. The need for security clearance of Master Grower, and QA departments is silly. The only needed security clearances are actual persons in control of the business (large shareholders/Board Members), and perhaps the manager/responsible person and Head of Security. That is it. Rest is just a waste of time and money.
- Standardized Lab Testing and Labels. Pick one universally approved lab method of cannabis testing to stop the silliness of wildly variable cannabinoid levels. And by the way, in a 28 gram bag, not every bud is 270 mg/g of THC. How about we do 2 logical things. Use percent like the rest of the world, and just a range. The contents of the package are between 23 and 28%. That is pretty easy,
We are sure their are more issues, and many people will disagree with the above, but if these 11 items were implemented, we predict the cannabis industry will become more sustainable, actually create more social inclusion, and increase safety and confidence for the public, and in all likelihood, more taxable revenue and jobs for Canadians. You notice we did not say more policing. Making cannabis accessibility simpler, more affordable, and at the same time safer, will continue to reduce the illicit market further and all Health Canada maintain it’s goals but not bankrupt the industry.