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Who can a Canadian “micro” sell to?

"Natural Medicine Extractors"

Who can a Canadian “micro” sell to?

 

There is a rumor floating around that the new micro-processors and micro-cultivators can sell their products ONLY through “standard” LPs. I believe this to be false and here’s why:

Excerpts from the Regulations:

Authorized activities — licence for micro-processing

(2) Subject to the other provisions of these Regulations, a holder of a licence for micro-processing is authorized to conduct those of the following activities that are authorized by the licence:

(a) to possess cannabis;

(b) to produce cannabis, other than obtain it by

(i) synthesis, (this means that a micro can’t add molecules together to form synthetic cannabis – I assume this method is reserved for Big Pharma) or

(ii) cultivating, propagating or harvesting it (means a micro-processor can’t grow it unless the micro-processor also has a micro-cultivation licence); and

(c) to sell cannabis.

It is clear that a micro-processor can be licensed to sell its processed products – but sell to who?

 

Sale

(5) A holder of a licence for micro-processing or standard processing whose licence authorizes the sale of cannabis is authorized to ….- my edit for brevity … sell to:

 (ii) a person authorized to sell cannabis under a provincial Act by reason of subsection 69(1) of the Act; this includes provincial sales agencies as well as provincially-authorized dispensaries – see subsection 69(1) of the Act following:

 

Provincially authorized selling

69 (1) A person may possess, sell or distribute cannabis if the person is authorized to sell cannabis under a provincial Act that contains the legislative measures referred to in subsection (3).

 

Following is subsection (3)

Legislative measures

(3) For the purposes of subsection (1), the legislative measures in a provincial Act that authorizes the selling of cannabis are the following in respect of persons authorized to sell cannabis:

(a) they may sell only cannabis that has been produced by a person that is authorized under this Act to produce cannabis for commercial purposes;

(b) they may not sell cannabis to young persons;

(c) they are required to keep appropriate records respecting their activities in relation to cannabis that they possess for commercial purposes; and

(d) they are required to take adequate measures to reduce the risk of cannabis that they possess for commercial purposes being diverted to an illicit market or activity.

 

The above relates specifically to micro-processors but micro-cultivators have a similar position. Batch testing is required before sale.

Add to the above all of the 200,000+ Canadian medical prescription holders and you have plenty of potential outlets for micro-cultivators/processors. Then there’s the Export Licence but that’s another discussion…

Table

 

In conclusion, I see nothing in the Regulations or the Act or the above Table that makes me think that micros can sell ONLY through standard LPs. Furthermore, I can’t imagine the Federal Government creating the micro classes only to then place them squarely under the thumbs of the standard LPs. That would create a direct conflict of interest and would not support the goal of moving away from the black market.

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