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C-45 QA's response to proposed changes to the federal Cannabis Act and Cannabis Regulations

The C-45 Quality Association (“C-45 QA”) is pleased with the recent announcement from Health Canada on several proposed changes to the federal Cannabis Act and Cannabis Regulations.

These proposed amendments intend to:

● facilitate non-therapeutic research on cannabis involving human participants

● allow analytical testing licence holders and government laboratories to produce, distribute, and sell cannabis reference standards and test kits

● expand the educational qualifications for the head of laboratory position that is required for an analytical testing licence

● increase the public possession limit for cannabis beverages

Such changes include those that the C-45 QA has brought to the attention of Health Canada during several recent engagements and reflects the positive direction the federal cannabis regulator is taking when listening to C-45 QA and other industry stakeholders.

C-45 QA’s members—primarily made up of Quality Assurance professionals within the cannabis industry—are the front line of Canada’s highly regulated cannabis industry, and as such can provide various regulatory agencies with unique on-the-ground insight into the challenges facing the industry today.

While C-45 QA is very pleased with these changes, they still reflect only a small portion of overall industry concerns and challenges. Our organization looks forward to future engagement and opportunities to continue to improve upon the foundation created by the Cannabis Act and Regulations.

“We welcome the proposed changes to dried cannabis equivalency for beverages,” says Tom Ulanowski, Chair, C-45 Quality Association.

“Although the changes will only impact a very small portion of the market, they are a step in the right direction, and it shows that Health Canada is willing to reassess their original restrictions, based on feedback from the industry and organizations like the C-45 Quality Association. We will continue to provide feedback to Health Canada on behalf of our members as it relates to possession and THC limits for other classes of cannabis such as edibles.”

“In addition, the ability for licence holders to conduct non-therapeutic trials on cannabis products, particularly as it relates to onset and effects of THC, CBD, and other cannabinoids, is critical for product development. This is a very important and positive change for the industry and consumers, alike.”

C-45 QA will be engaging our members on their feedback to these proposals in the coming weeks, and will continue to engage with regulatory agencies like Health Canada on the concerns and perspectives of our growing membership.

Click here (link: to read the proposed changes in Canada Gazette 1.

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