Last week, the federal government ended its public consultation related to proposed regulations concerning edible cannabis, cannabis extracts, and cannabis topicals. The goal of the regulations – and in turn the consultations – is to help minimize the public health and public safety risks posed by the legalization of these cannabis products (expected no later than Oct. 17, 2019).
In the meantime, though, there seems to be a great deal of public confusion about edibles: why their regulation is so important; what Canadians can expect edibles to look like and how they’re made; the efforts being made to help keep edible cannabis products out of the hands of youth; and why black market cannabis products continue to create a dangerously murky perception of a legalized cannabis offerings.
These now-complete consultations are a tremendously important part of the process and it is critical that reasoned, informed voices help better inform Canadian decision makers and the general public so that decisions and rules are made in a reasoned and informed way. I am hopeful that Health Canada’s proposed guideline will help to clear up the confusion that many Canadians have with regard to edibles.
For example, a recent report by Brightfield Group that explored Canadian cannabis users’ reaction to the new recreational market, and specifically why more people aren’t purchasing through the legal, adult-use market, 37 per cent of respondents cited that “I’m waiting for the confusion to clear out.”
Similarly, some media coverage has focused on what they refer to as the “unknown risks of marijuana edibles” based on recent anecdotes of individual Canadians’ experience with illegal edible cannabis products. And while it is tremendously important for Canadians to be informed about the cannabis options they select, it is also critical for Canadians to understand any edible product found today – whether accessed through unregulated sources such as dispensaries or websites – are first and foremost still illegal. Secondly, these untested products are being sold outside of the regulated framework the government, the cannabis industry and other engaged stakeholders are working so hard to develop responsibly.
Rather than turn people away from edible cannabis products overall, these kinds of incidents underscore the need for a carefully regulated market as it relates to infused edibles (think suckers, gummy bears, etc.) which are so prevalent within the illicit market.
For example, the proposed regulations ensure a limited level of THC (the psychoactive ingredient in cannabis that is typically associated with the feeling of a high) of 10 mg/serving, which would be tested by an accredited lab much like today’s cannabis products available through licensed retail outlets. It’s also important to note that historically illicit market products have been known to carry an additional risk of contaminants, a risk that is minimized under strict control and regulation such as those proposed by Health Canada.
The proposed regulations also help address some of the common concerns related to legal, adult use cannabis: proper labelling, tamper-resistant packaging, child resistant closures, and minimizing the appeal to youth.
If we look to our neighbours south of the border, we benefit from the lessons learned in jurisdictions like Colorado who, over the course of the last five years, have worked hard to effectively evolve their market regulations to reflect real world experiences with legal cannabis edibles and concentrates. We should be confident that the proposed Canadian rules model where Colorado is today, and that they do a good job translating knowledge into a reasonable and responsible framework.
Looking ahead, what does this kind of regulation mean for product development and the consumer experience? From a licensed producer perspective, it means we will see deep industry expertise, a stalwart commitment to quality and safety, and a keen understanding of the product itself reflected on both sides of the legal edibles coin: products developed with consumer safety and satisfaction in mind.
At the end of the day, there is tremendous opportunity ahead of us as we consider expanding the product offering of the legal adult-use cannabis market. But clarity must replace confusion; we need to look for and encourage more public discussion about the products so that we proceed cautiously but confidently.
Ray Gracewood is the chief commercial officer of Organigram Inc.