On Monday, Health Canada released a report that summarizes the feedback from its 60-day consultation on the proposed regulatory approach to cannabis. The department heard from more than 3,200 Canadians and 450 stakeholders, existing licensed producers and prospective producers, provinces and territories, and Indigenous organizations.

Significantly, the report provides details on the expected requirements for packaging and labelling of cannabis products, the highlights of which are as follows:

  • General labelling requirements would be the same for all cannabis products, regardless of whether the cannabis is sold for medical or non-medical purposes.
  • All cannabis products would need to be packaged in a manner that is tamper-evident, child-resistant, prevents contamination, and keeps cannabis dry, consistent with the requirements in the ACMPR.
  • The maximum amount of cannabis in a single package would be 30 grams of dried cannabis, in keeping with the amount that the adults would be able to possess in public places upon coming into force of the proposed Cannabis Act.
  • Regulations would set out the following general labelling requirements:
    • Name and contact information of the processor who packaged the product
    • Product description
    • Product lot number
    • Product weight or volume, depending on the product class
    • Packaging date (and expiry date, if one has been set)
    • Recommended storage conditions
    • THC / CBD content (expressed as the percentage of THC / CBD the product could yield and by unit or dose, if applicable)
    • Inclusion of the statement: "KEEP OUT OF THE REACH OF CHILDREN"
  • Rotating mandatory health warnings would be required on all product labels (similar to what is done currently for tobacco products)
  • In order to prevent accidental ingestion, it is proposed that products intended for ingestion that contain more than 10 parts per million (10 ppm) THC (equivalent to 0.001% THC) be labelled with a clearly recognizable standardized cannabis symbol.
  • Use of colour, graphics, and font size on the product (package and label) would be strictly regulated in order to ensure that the key information, such as the standardized cannabis symbol and the health warning messages, would be the most prominently displayed elements. Further to this, text and graphics used in brand elements could not be appealing to youth and would be subject to the packaging and labelling restrictions in the proposed Cannabis Act.

Gowling WLG's Advertising & Product Regulatory Group will continue to monitor these developments and provide further updates as they become available.