Cannabis tracking: cultivation waste changes

Summary#

This is a proposed Order Amending the Cannabis Tracking System Order (Cultivation Waste) under the Cannabis Act. It would change how “cultivation waste” is handled in monthly inventory reports and update the unit for reporting seeds; the public can comment for 30 days after the notice that appeared in the Canada Gazette on June 8, 2024.

What it does#

• Clarifies that monthly inventory reports must treat unpackaged cannabis “other than cultivation waste” when listing quantities added to or removed from inventory.
• Adds a definition of “cultivation waste” by referring to the definition in the Cannabis Regulations (the Order says cultivation waste “has the same meaning as in subsection 1(2) of the Regulations”).
• Updates the French wording for some report categories (technical wording change in the French text).
• Changes the unit of measurement for seeds in Schedule 2, item 1, column 2 to “number of seeds.”
• Sets the coming-into-force timing so most of the Order takes effect on publication in Canada Gazette, Part II, but the section that depends on related regulatory changes comes into force on the later of that publication date and when the related regulations come into force.

Who's affected#

• Licensed cannabis growers and other businesses required to report inventory to the federal Cannabis Tracking System.
• The Department of Health, which oversees these reporting rules, and other federal regulators who receive and use the tracking data.
• Others in the cannabis supply chain (processors, potentially some distributors) who handle unpackaged product and must track inventory, to the extent they report through the tracking system.

If it’s unclear whether a specific business must report under these rules, that is not spelled out in this notice.

Why it matters#

• It changes what counts in the formal inventory reports. Items classified as “cultivation waste” would be excluded from the monthly counts described in the Order, which affects how businesses record and report losses or unusable plant material.
• Changing the seed unit to “number of seeds” standardizes one part of reporting and may change how seed inventory is recorded.
• The timing of the change depends partly on a separate set of amendments (the Regulations Amending Certain Regulations Concerning Cannabis (Streamlining of Requirements)), so businesses should watch for when both instruments come into force.
• Stakeholders have 30 days from the Canada Gazette notice to comment on the proposed Order if they want to influence the final text.