February 1, 2023
To: Health Canada
Re: Ingestible Cannabis Extracts/Edibles
We are writing you to express our serious concern with recent news that Health Canada is seeking to remove products such as lozenges, capsules, and chewable extracts that contain greater than 10mg of THC per package (the “Extracts”) from the licensed market.
One of the fundamental components of the licensed cannabis industry is to reduce risk and harm, creating safe access to cannabis for recreational consumption.
The consumer market has clearly born out the desire to access a higher dosage product such as the chewable Extracts. During the past four years of legalization there has been a constant demand, both in-store and a as a request made to Health Canada, for a higher per-package dosage in this category.
These Extract products have been created to offer higher orally consumable THC doses. They comply with the 10mg/unit requirement, allowing the consumer to manage the amount they ingest. They offer a safe and ingestible option to high THC consumers.
The uptake and popularity of these products is quite significant, and the demand for them has become strong and constant. By removing these high-dosage packages, Health Canada is effectively sending these consumers back to the unlicensed market to source the products they clearly want.
The Cannabis Act doesn’t prohibit the sale and consumption of larger doses of THC edibles. A retailer can sell 44 packages of chocolate in one transaction, providing the consumer with a purchase of 440mg of THC – but the problem is consuming that enormous quantity of chocolate – amounting to a huge number of calories, sugar and grams of fat content at an unreasonable price point.
If the goal of the Cannabis Act is to mitigate harm, it would stand to reason that providing a safe, digestible cannabis product created with licensed cannabis would be the least harmful option when presented with the alternative – high potency, untested, unregulated, unlicensed products – which we know contain harmful components and fuel an unregulated industry.
Please be advised that we consider the decision to remove these Extracts to be counterproductive to the goal and spirit of legalization and the Cannabis Act. We strongly urge Health Canada to recognize that products need to be assessed with a more reasonable, solutions-based lens.