Edible cannabis, cannabis extracts and cannabis topicals will become legal to sell in Canada no later than Oct. 17, 2019, a year after the federal government legalized recreational cannabis use. Health Canada is now seeking feedback on proposed edible cannabis regulations that will come into force under the Cannabis Act. This public consultation period will run until Feb. 20, 2019.
What could the edible cannabis regulations mean for foodservice?
As is currently the case with non-edible cannabis, the new federal regulations will leave it up to each province and territory to decide:
- The legal minimum age for edible cannabis use
- Where adults can buy it
- Where adults can use it
- How much adults can possess
Since rules related to the point of sale and consumption of edible cannabis will be left up to lower levels of government, this will not be the focus of Health Canada’s consultation on the proposed edible cannabis regulations. Still, this is an important moment for making sure that the voice of foodservice is heard, as the federal regulations will determine the future possibilities for Canada’s soon-to-be legal class of edible cannabis products.
What are the proposed edible cannabis regulations?
Below is an overview from Health Canada of some of the key regulations being proposed for the new classes of cannabis products.
In addition to the restrictions listed in the infographic above, the proposed regulations would prohibit the production of food and edible cannabis in the same facility. They also propose that:
- All edible cannabis products would need to be shelf-stable (i.e., they could not require refrigeration or freezing)
- Aside from cannabis itself, only food and food additives could be used as ingredients in edible cannabis, and the use of food additives would need to be in accordance with the limits and purposes that are prescribed for foods in the Food and Drug Regulations (FDR)
- The use of meat products, poultry products and fish as ingredients would be prohibited; but because dried products pose a lower risk from a food safety perspective than raw products, an exception to this prohibition would be provided for dried meats, poultry or fish, provided they are obtained from a person who is authorized to produce such products under provincial / territorial laws or the Safe Food for Canadians Act (SFCA), and that they have a water activity of 0.85 or less at the time they are obtained
As is currently the case with non-edible cannabis, plain packaging and labelling will be required for the new classes of cannabis products, including strict limits on the use of logos, colours, and branding. And consistent with requirements that apply to food under the FDR, the proposed regulations state that the following would be required on the label of edible cannabis products, in addition to the current labelling requirements, which apply to all cannabis products:
- A list of ingredients
- The common name of the cannabis product
- An indication of the source of an allergen or gluten, or that sulphites have been added to the product (alternatively, this information could appear as part of the ingredient list)
- A “durable life date” (more commonly known as a “best-before date”); this requirement would apply only to edible cannabis products whose qualities are expected to deteriorate over a period of 90 days or less
- A cannabis-specific nutrition facts table (NFT)
We want to hear from you
As part of the public consultation process, Restaurants Canada will be participating in an industry roundtable with Health Canada at the end of January. We encourage all interested members to read the proposed federal regulations for the new classes of cannabis and share any thoughts or concerns with David Lefebvre, Restaurants Canada Vice President, Federal and Quebec, who can be reached at firstname.lastname@example.org or 1-800-387-5649 ext. 6000.
Our latest Restaurant Outlook Survey is also asking restaurateurs how the legalization of recreational cannabis use is impacting their operations and gaging their interest in the potential for adding edible cannabis products to their menus. If you are a Canadian foodservice operator, we welcome you to participate in the survey to ensure your voice is heard. You can send an email to Restaurants Canada Senior Economist Chris Elliott at email@example.com to request a link.