Micro Processing Licence
CLASS: Processing SUBCLASS: Micro
Our internationally acclaimed cannabis regulatory business consultants know the nuances of Micro Processing Licences. The holder of a Micro Processing Licence is permitted to possess and produce (manufacture) cannabis products, other than by propagating, cultivating or harvesting these. In general, the licence permits a wide range of cannabis products to be manufactured or produced, including pre-rolls, vape cartridges and pens, edibles, beverages and topicals. Licenced standard processors can also produce and package cannabis products, including dried and fresh cannabis, plants, seeds and oils. A micro-processing licence holder is allowed to alter chemical or physical properties of cannabis by using an organic solvent, but processing of cannabis oils is limited to 30mg of THC per mL.
The Licence Holder is permitted to sell and distribute cannabis to other licence holders, such as other processors, analytical testers, researchers, and cannabis drug licence holders. Only plants or seeds may be sold/distributed to licenced nurseries. Cannabis produced for the purposes of testing (needed to determine the chemical characterization of cannabis. e.g., for a reference standard) may be sold or distributed to all of the preceding licence class holders. Finally, a micro processing licence allows cannabis products to be sent to a buyer at the request of a Licence Holder who is authorized to sell cannabis for medical purposes, or who is authorized to sell under provincial/territorial statute.
Licence Holders are restricted to certain processing limits: a maximum of 600 kg of dried cannabis (or equivalent) in one (1) calendar year as per section 21 of the Cannabis Regulations. However, If a Licence Holder also has a micro-cultivation licence for the same site and the cannabis comes exclusively from that site, this maximum quantity does not apply. Cannabis must also be produced, packaged, labelled, stored, sampled and tested indoors, and meet all Good Production Practices (GPP). Cannabis obtained under this licence class cannot be recovered by the synthesis of cannabinoids. Analytical testing of cannabis must occur prior to sale.
Key personnel who must be identified and obtain security clearance are the Licence Holder (who has overall responsibility for the licence), Responsible Person (responsible for activities conducted by the Licence Holder), Head of Security (Responsible for ensuring that the physical security measures comply with Part 4 of the Cannabis Regulations and for the Organization Security Plan), and the Quality Assurance Person (QAP).
The QAP is responsible for assuring the quality of the cannabis before it is made available for sale. The QAP also investigates complaints about cannabis and takes steps to mitigate risks. The Licence Holder must retain a QAP who has the training, experience and technical knowledge related to the requirements of Parts 5 and 6 of the Cannabis Regulations. Where the QAP lacks the expertise to process edibles, the Licence Holder must retain an alternate who has the needed training, experience and technical knowledge. Up to two individuals may be hired as alternate QAPs if they are qualified to replace the primary QAP.
Security Clearances are needed for key investors, directors and officers of the corporation or cooperative (if the Licence Holder is a corporation or cooperative); for any person who exercises, or is in a position to exercise direct control over the corporation or cooperative; any individual who is a partner in a partnership that exercises (or is in a position to exercise) direct control over the entity; and typically, the Responsible Person, Head of Security, QAP and designated Alternates of key personnel.
Security Requirements and standards for the Micro Processing Licence are less onerous than for most other licence classes. As per Part 4 of the Cannabis Regulations, a Licence Holder must ensure that the site is designed to prevent unauthorized access; that both the site and storage areas are surrounded by a physical barrier to prevent unauthorized access; and that access to storage areas is restricted to persons who are required to be there to exercise their duties.
Those applying for a Micro Processing Licence must file a key investor report with their application, which is required if the entity does not have publicly traded shares.