Exclude cultivation waste from cannabis reports

Summary#

This is a proposed Order Amending the Cannabis Tracking System Order (Cultivation Waste) from the Department of Health. It would change how licensed cannabis businesses report certain inventory items, mainly by excluding “cultivation waste” from some monthly unpackaged-cannabis counts and by clarifying seed counting. Public comments are open for 30 days from publication on June 8, 2024.

What it does#

• Removes “cultivation waste” from the counts of unpackaged cannabis that must be reported as added to inventory each month under the Cannabis Tracking System Order.
• Removes “cultivation waste” from the counts of unpackaged cannabis that must be reported as removed from inventory each month under the Cannabis Tracking System Order.
• Adds a short definition note that says “cultivation waste” has the same meaning as in subsection 1(2) of the related regulations (so the term is tied to the broader regulatory definition).
• Updates a French-language subparagraph for clarity (a technical language fix).
• Changes the unit of measurement for seeds in Schedule 2 to “number of seeds.”
• Timing: the Order would come into force on the day it is published in Canada Gazette, Part II, except that the main changes in section 1 would come into force on the later of that day and the day the Regulations Amending Certain Regulations Concerning Cannabis (Streamlining of Requirements) come into force.

Who's affected#

• Licensed cannabis growers and other holders who must use the federal tracking system and file monthly inventory reports with Health Canada.
• Compliance and record-keeping staff at licensed producers who count unpackaged cannabis and seeds.
• Health Canada (as the regulator) and its data systems that receive those monthly reports.
• It is unclear from the notice whether small licence types or processors who do not handle unpackaged plant matter will see any impact.

Why it matters#

• By excluding cultivation waste from some inventory counts, the change should prevent waste (like unusable plant trimmings) from being treated as reportable inventory. That can reduce paperwork and the risk of misreporting for licensed growers.
• Changing the seed measurement to “number of seeds” standardizes how seeds are counted and reported, which may affect inventory records and audits.
• The change ties reporting rules to a legal definition already in the regulations, which reduces ambiguity about what counts as “cultivation waste.”
• For most consumers, there is no direct effect. The main impact is administrative and compliance-related for licensed industry and for the federal tracking system.