Cannabis 3.0

The following article appeared in Natural Sci Regulatory Consulting – January 2020 Newsletter:

Cannabis 2.0 products have arrived, but what’s next for cannabis in Canada? Early indications are that Cannabis Health Products (CHPs) are next in line, so what exactly are they? In essence, CHPs are Natural Health Products (NHPs) with cannabis as the primary active ingredient. This means that cannabis must be the active ingredient. so you can’t simply add cannabis to an NHP or other medicinal/non-medicinal ingredients and call it a CHP. This also means that CHPs are unique from other cannabis products, as they are intended to have potential therapeutic uses for minor ailments. Much like NHPs, CHPs would be allowed to contain medicinal ingredients and non-medicinal ingredients, and have health claims associated with them.

Unlike the separate classification of NHPs and VHPs, Health Canada has indicated that CHPs would be available for both human and animal use. All of these features of CHPs demonstrate that they are intended to fill gaps that currently exist both in the cannabis and NHP markets.

Health Canada have also given their first indications about how CHPs might be regulated.

1. CHP health claims will be regulated much more strictly than NHPs. For example, general health claims will not be allowed; the specific health claims that are allowed need to be supported by a higher level of evidence than with NHPs.

2. Licensing requirements for CHPs are likely to be the same as the requirements for all other cannabis products: only those companies designated federally as a Licensed Producer would be able to produce and sell CHPs.

3. Labelling requirements for CHPs will likely be a combination of current cannabis and NHP labelling. NHP information such as directions for use and cannabis information such as the health warning message will likely be required.

Although it’ll probably take time and many changes before regulations for CHPs are finalized, these preliminary details provide valuable insight into how Health Canada sees these products. The question now is whether the Canadian public sees CHPs in the same way and whether this will have any impact on Health Canada’s thinking.

For further information from Natural Sci Regulatory Consulting: https://www.naturalscireg.ca

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