Quebec City, November 25, 2022 – As the voice of the industry in Quebec, the Association québécoise de l'industrie du cannabis (AQIC) submitted to Health Canada a brief entitled "A sustainable and responsible industry: key success factor in the legalization of cannabis", as part of the legislative review of the Cannabis Act. The document includes requests for changes that require legislative amendments and requests for changes that do not require such amendments, that can be implemented quickly. The Canadian Cannabis Act Review Committee proposes 30 recommendations that aim to enable the Quebec and Canadian cannabis industries to help governments achieve public health and safety objectives.
Indeed, 4 years after legalization, industry faces many obstacles that have significant impacts on its operational efficiency, hinder its growth and sustainability, and limit its ability to fight against the illicit market. The review of the Cannabis Act is therefore an important moment for the industry to help the government achieve the many objectives set in 2018.
30 recommendations to enable industry to help the government achieve its public health and safety objectives
The recommendations made by the AQIC and its committee to the federal government are intended to ensure that the industry has the predictability, agility and efficiency essential to its development, its outreach and its full contribution to the objectives of the Act. A total of 30 requests were made. Here are some of them:
Replace the precautionary approach that has prevailed since the legalization of cannabis with an approach based on a risk assessment;
Review the legislative and regulatory framework to effectively govern cannabis products by taking into account their specific characteristics rather than their forms;
Implement a digital national excise stamp and collect excise tax on the retail sale of cannabis products;
Improve patient access to medical cannabis through pharmacy distribution and subject medical cannabis to a tax treatment similar to that of other products for medical or therapeutic uses;
Support industry to increase its ability to divert or keep consumers away from the illicit market;
End the delegation of production to a designated person authorized in Health Canada's Access to Cannabis for Medical Purposes Regulation and establish a registry of producers, processors and sellers of legal cannabis (recreational and medical) for law enforcement organizations ;
Ensure a proactive Canadian presence on the international scene to increase the acquisition and sharing of cannabis knowledge and facilitate the dissemination of Canadian know-how ;
Recognize and treat the cannabis industry as well as all other consumer product industries;
Establish a research and development program dedicated to acquiring, increasing and sharing knowledge on cannabis, funded not only by Health Canada, but also by other departments or organizations.
The report and all recommendations are available on the AQIC website:
French version: aqic.ca
English version: aqic.ca
"To curb the black and illicit market, a resilient, efficient and optimized supply chain is paramount. That is what our demands to the government are all about. Progress has been made, but now is the time to act and move up to achieve our mission: to keep cannabis out of the hands of youth, to prevent profits from going into the pockets of criminals, and to protect public health and safety by allowing adults access to legal cannabis. This cannot be done without reluctance giving way to confidence in all decisions and public actions concerning cannabis and pride replacing discomfort so that cannabis and its undeniable virtues are recognized at their true value on the one hand and, on the other hand, an industry that should not have the impression, as tenacious as it is undeserved, to be tolerated or to have to apologize for existing," explains Pierre Leclerc, Executive Director of the AQIC.
"The Canadian legislator had the good conscience to provide for a legislative review process in its own Act. Considering the issues at stake, we hope that this mechanism will remain in future amendments. In general, our written submissions did not criticize the approach taken by the Canadian government but presented observations and solutions in light of the experience accumulated over the past four years. Some of the policy concerns simply do not exist anymore and what is known today is that the industry is in a state where it needs the same level of support and recognition that is given to other innovative industries, especially in light of recent developments in the international marketplace. It must be recognized that a greater focus on scientific developments and the sharing of know-how is to the benefit of the commercial community as a whole, since cannabis is both a product and a source of ingredients and raw materials and biomass. There is a serious risk here of jeopardizing advances in this area and losing excellent research and development projects that can make Canada a leading centre of innovation," said Jason Moscovici, Chair of the Canadian Cannabis Act Review Committee, of ROBIC.
"The Canadian legislator was well aware of providing for a legislative review process in its own legislation. Considering the issues at stake, we hope that this mechanism will remain in future amendments. Ingeneral, our written submissions did not criticize the approach taken by the Canadian government, but presented observations and solutions in light of the experience accumulated over the past four years. Some of the political concerns simply no longer exist and what is known today is that the industry is in a state where it needs the same level of support and recognition that is given to other innovative industries, especially in light of recent developments in the international market. It must be recognized that a better focus on scientific developments and the sharing of know-how is to the benefit of the business community as a whole, since cannabis is both a product and a source of ingredients and raw materials. There is a serious risk here of jeopardizing progress in this environment and losing excellent research and development projects that can promote Canada as a pool of innovation," said Jason Moscovici, Chair of the Canadian Cannabis Act Review Committee, of ROBIC.
AQIC members at the heart of the memory creation process
This document is based on the results of a survey of AQIC members conducted during the month of September 2022. It therefore reflects the reality, issues and perceptions of Québec stakeholders. It was drafted by the Association's Canadian Cannabis Act Review Committee.
A special committee set up by the AQIC
To review the Government of Canada's cannabis legislation and regulations, the AQIC established the Canadian Cannabis Act Review Committee. It is made up of cannabis producers, ancillary service providers and lawyers. Its mandate is to prepare AQIC's interventions related to federal cannabis legislation, and more specifically to produce briefs as part of the Government of Canada's public consultations. The committee is chaired by Jason Moscovici of ROBIC.
About AQIC
Founded in 2019, the AQIC represents a vast ecosystem, composed of more than 80 members, within which we mainly include Quebec companies subject to federal and provincial legislation and regulations, in this case producers (cultivation and micro-cultivation), extractors and processors of cannabis (recreational or therapeutic). Including companies specializing in the development, production and marketing of cannabis-based pharmaceuticals or biopharmaceuticals. There are also businesses whose activities (commercial or professional) are related to cannabis.
The AQIC offers its members a forum for reflection on issues affecting the Quebec industry in this sector and acts as a constructive interlocutor with government authorities and stakeholders. It aims to responsibly develop a regulatory framework adapted to Québec, in order to achieve the public health and safety objectives of cannabis legalization, namely the reduction of the harms associated with consumption by offering quality products subject to rigorous controls and redirecting the purchase of cannabis to the legal economy.
For more information, visit: aqic.ca. To discover the AQIC committees and their members, visit: aqic.ca/fr/nos-comites.
