Permitted Licence Activities: Indoor Cannabis Cultivation
The Standard Cultivation Licence is needed if you plan to cultivate, propagate, and harvest fresh cannabis plants and seeds indoors, dry and cure, and sell bulk-packaged cannabis to other cannabis licence holders. The licence holder may sell and distribute fresh and dried cannabis, plants and seeds to other licence holders, with the exception of nursery licensees, to whom only cannabis plants and seeds may be sold or distributed. Holders of a Standard Cultivation Licence may also conduct ancillary activities (e.g., drying, trimming, milling) and alter the physical or chemical properties of cannabis for testing purposes. This licence does not allow the licensee to package, apply an excise stamp or to sell directly to the provincial wholesaler, retailers or to medical patients.
Capacity Limits: (none)
Physical Security Requirements: $$$$
Specialized Personnel: (none required)
Recommended Personnel: Skilled/experienced Master Grower
Est. Application Review Timeline: 4-6 months with consultant, 12+ months without a consultant
Permitted Activities: Propagation, cultivation, harvesting, drying, trimming, milling, and selling bulk (unpackaged) cannabis within licensed areas of the site perimeter only.
Site ownership is a key point of interest to Health Canada, with the Department’s requirements geared to ownership type. Depending on whether the site is owned by an individual, partners, a corporation or co-operative, a consent form may be submitted.
A Business Plan for the proposed operation is needed to help secure this licence. The plan should describe the applicant’s business model indicating the products they intend to sell and the activities that will be conducted. Attention will be paid to any affiliations or business relationships the operation will maintain with other companies.
All cultivation licence applicants must provide the authorized source of starting material. Where the applicant intends to use cannabis plants or seeds not obtained in accordance with the former Access to Cannabis for Medical Purposes Regulations, the former Industrial Hemp Regulations, the Industrial Hemp Regulations or with the Cannabis Regulations or from a person authorized to sell cannabis under a provincial Act, they must select “Declaration under 10(2) of the Cannabis Regulations” as their source.
In the licence application, the applicant will be asked to identify key site personnel involved with the proposed facility, including the Responsible Person, Master Grower, and Head of Security. One Alternate to each of these positions is also permitted. Applicants must show that identified personnel have the knowledge, qualifications, experience, and ability to fulfill applicable responsibilities. The requirements of the Responsible Person are noteworthy as this individual will have the authority to bind the licence holder; has overall responsibility for activities conducted by the licensee; and must know the provisions of the Cannabis Act and Cannabis Regulations that apply to the holder of the licence. The Responsible Person also serves as the official point of contact with Health Canada.
Security Clearances are a critical requirement, for all key site personnel, directors and officers of the corporation and all main investors in the enterprise. An organizational chart is needed with the package to show the structure of the enterprise, with names, titles and reporting relationships, including management positions and any other roles that influence strategic business and operational decisions, and the movement of money or cannabis.
Facility requirements, starting with a building location survey and certificate prepared by a qualified person in the jurisdiction where the facility is located, such as a land surveyor. An aerial view of the proposed site and surrounding lots to within 500 metres must also accompany the application. The objective is to accurately depict the site at the time of submission. It is important to include the size of the proposed facility and to ensure the site is zoned for cultivation, usually with industrial, commercial or agricultural zoning. Typically, this licence type addresses a facility sized 5,000 square feet or larger.
Facility information is closely related to estimated annual production capacity, such as kilograms (kg.) of dried flower, or a number of plants or seeds per year (see Schedule 4 of the Cannabis Act). The application requests disclosure of the total combined production area with grow areas and other operational areas clearly demarcated. Grow areas should address all surface areas to be used in production, including vertically arranged areas.
Physical site security pertaining to all operations areas where cannabis will be present, is a critical requirement for Health Canada. Security risks and mitigation measures to address these should include arrival/departure procedures; access and response procedures for breaches; storage, retrieval and record-keeping requirements for video surveillance; and other activities. Detailed site drawings and specifications for access control, intrusion detection, visual surveillance around the site perimeter (exterior and interior), and restricted access to all Secured Storage areas must be included with the licence submission. Further information re. the Head of Security and Alternate Head, such as proposed work schedules and hours, and contact information will be required.
The applicant may need additional licences to help realize their business plan. Licences for standard processing, research, testing and sales are permitted combinable licences with the Standard (indoor) Cultivation Licence. All cultivators of cannabis products are required to obtain a cannabis licence from the Canada Revenue Agency (CRA).
If you’re thinking of setting up a cannabis business in Canada to grow cannabis or hemp, manufacture cannabis products, conduct research, analyze or sell cannabis, you will need to obtain a licence (or several licences) from Health Canada. This series introduces the licence types, authorized activities, conditions and other key considerations you must know before you set forth. Eleven (11) Federal licences comprise the series, each of which with a specific scope, conditions and requirements.
The following licence descriptions cover general information and are not exhaustive – there are many details to include in a successful application.
Let CanndDelta can guide you through the process, step by step. Our goal is to ensure a smooth, cost-effective experience in obtaining your federal cannabis licence. Whether you aim to cultivate, process, test or pursue other commercial cannabis-related activities, we can help!