More food for thoughtAgain, courtesy of pulverizer...
Looks like Jm’s Slow practical approach might be the deciding factor to keeping the ship afloat while navigating an ever changing landscape...
The draft regs for edibles can be found here: https://www.gazette.gc.ca/rp-pr/p1/2018/2018-12-22/html/reg4-eng.html No idea on why other than you have to think like Health Canada. They are looking at this from a public health perspective and they monitor "over doses" of all kinds. With respect to cannabis, all "over doses" are always edible related. Yes, an "over dose" on cannabis is somewhat laughable, but if someone calls 9/11 and uses the public system's resources, then it is catalogued as such. Because of this, they are more concerned about the edible space over everything else. I was surprised to read in the draft regs that vape pens can have 1000mg of THC, for instance. So pills and tinctures began as medicine, but they allowed them to come into the adult use space as well, just cannot provide health information through that channel. As a result they have different monitoring systems and they remain in place, however if you read those draft regs, they propose to extend the definition of cannabis oils for 6 months after Oct 17 and then reclassify them. So in those draft regs it suggests that all edibles never exceed 10mg per package. Not per dose. Per package. If that maintains the status, then edibles will see a huge challenge. A 6pk of THC beer for instance cannot exceed 10mg for the whole 6pk. I don't honestly understand why anyone sees value in 2.13L of liquid to be drank to equate to a single capsule.... people are strange. Again, these are draft. HC has allowed public consultation until Feb 20th and the industry is targeting this as well as the 2nd site for food producers. But, targeting HC on the context of "it's not fair to my bottom line" is not the strategy that works. You have to offer it in a public health context that meets their desire to mitigate the concept of edible over doses. It even states in the draft regs they want to see more industry push for lower dose consumption. So if someone doesn't put a real adaquate thought in how to convey that message, then this barrier will remain true. Meaning all doses will be tops, 10mg per package, per single bite. So if you want 70mg you must by 7 packages or 7x 6pks of THC beer. HAHHAHAHAHAHA. Now, with the THC beverages, if say, over time, the Hospitality industry can sell a THC beverage, then I will see value in that space. Because I know a lounge doesn't want to sell you a $15 gummie bear and let you use their lounge for hours on end. But low dose THC beverages being sold over and over again at $6ea, yes. So long as a cultural shift in the cannabis consumer ebraces such a product. Time will tell. Also gummie bears are out, all candy and sugar products are out. No sweeteners in your concentrates, so no blueberry flavored vape pens. Chocolate might make it in there, but definately not lolly pops, gummie bears etc. I've been reading the draft regs and taking notes. They're amusing to say the least and demonstates the risk in getting too excited about investing in the wrong firm too quickly. These are draft regs, then Feb 20th is the cut off for consultation, then in March or April reading 1, then 2 then 3 then a full senate review, amendments added, voted on all amendments, some win, some loose and then by July/August we have actual defined regulations. Then Oct 17th products are supposed to be procured into the space meanwhile these food manufacturers are applying for Standard Processing licenses so they can manufacture products they don't even know will or will not work, if they need a 2nd site with a whole 2nd set of production equipment or not and lets not forget how long it takes to get an LP status license, so put in your application today and when exactly will you even have a license to make something let along procure it into a provincial distribution channel????? Canopy is building an actual beverage company on a 2nd site, so I know Canopy will have beverages by Oct 17th because they will just over spend now based on the draft regs. Think of it like when LPs needed a $1mil vault. All these LPs in the building phase, halfway through construction of that vault and all the sudden it's waived. So there's a savings of $1mil to late staged applicants versus early adoptors. The industry is riddled with this. You have CHOO running around telling everyone they're this retail giant, paying for over 100 leases. Where are their stores exactly? They have 5 late stage LPs with one in BC with a cultivation license and all the sudden Ontario does a lottery system and says 25 stores until December 13th, period. Also, if you're owned by more than 9.9% of an LP then zero stores for you. How's those 5 LPs going for CHOO now??? Where's Tokyo smoke outside of Manitoba, or Hiku? Medmen stores? BC keeps licensing small hick town locations, why? Because the background checks are so hard that if you're an owner operator with 2 employees you go to the top of the pile and get a license. If you're a chain with 8 locations and 60 employees, back of the bus buddy. A ton of lost investor money is being wasted by all the eager early adoptors trying to make moves ahead of sound regulations. My advice is don't. And then all these firms going global, looking to latin america as this dark horse for cheap input materials. Columbia licenses oil production for EXPORT MARKETS ONLY. But Europe will only import GMP compliant manufacturing from firms with a 5yr experience record. Australia only has 2000 registered patients and Medipharm Labs is building an onsite facility there to capture that market and Germany only has 5000 registered patients with the most strict GMP rules in the world. Aphria buys a firm to get the license connected to Germany and Germany deletes all the applications, wipes everything out and the very next day reinstantes the RFI (Request for information) the very next day. Boom levels the playing field to rebuild and has said it intents to stop imports once it can build its own facilities in the coming years. Latin America cannot be cheap input materials to Canada. It's baked into the Cannabis Act as such: Importation and exportation of cannabis
Part 10 of the Regulations deals with the importation and exportation of cannabis. As set out in the
Cannabis Act, the import and export of cannabis
is permitted only for medical or scientific purposes, or in respect of industrial hemp.
No major changes are proposed to this part of the Regulations. Each importation and exportation of cannabis will continue to require a permit issued by the Minister. The following minor change is proposed: whereas import and export permits must currently set out "
the description of the cannabis," they would now set out "
a description of the cannabis."
The yellow identifies that Canada's Cannabis Regulations are going to maintain that barrier. Export from Canada to Europe requires GMP certification. There's no other way to do it.
The green identifies that every single shipment must have a permit. Each shipment's permit takes close to 40 days to retain. Because each shipment must have a permit applied for it will create risk of being denied for any reason necessary by both Health Canada and/or Canada Customs and Revenue. Additionally some products such as seeds and edibles and even raw hemp will require a CFIA permit. The forms are attached, although I have attached an ACMPR form which will be under a different title.
The drug that is investing in cannabis firms is a frenzie of chaos. Absolutely winners are out there and opportunity to make money, but oh my god is it ever risky.
Then you got sketchy Raven Quest and Bonify doing god knows what. And Organigram, Aphria, Isodol, MYM and ASNT all with their own baggage.
A very interesting industry to say the least.
I'm looking for the vape pen players. Who is going hard, literally hard on that. ASNT was supposed to be that dark horse. Who will buy it, take that beautiful IP they earned over the years and run with it? Could be worth holding this stock to hitch onto that waggon.