OTTAWA — Health Canada initiated a 60-day comment period on Dec. 22, 2018, when it published draft regulations for the manufacture and sale of edible products containing cannabis in the Canada Gazette. On Oct. 17, 2018, Canada legalized the recreational use of marijuana and said it would allow the sale of edible products within approximately one year.

“These proposed regulations under the Cannabis Act support our overarching goal of keeping cannabis out of the hands of youth and protecting public health and safety,” said Ginette Petitpas Taylor, the Canadian minister of health. “We look forward to hearing the views of Canadians from across the country.”

Under the proposed regulations, all edible products would need to be shelf stable, and the government would place a “hard cap” of 10 mg of tetrahydrocannabinol (T.H.C.), the psychoactive component of cannabis, that could be in a package. The agency also is proposing that edible products may not be fortified with vitamins or minerals and may not contain added caffeine beyond what naturally occurs in such ingredients as chocolate, tea or coffee. The maximum level of naturally-occurring caffeine may not exceed 30 mg in a product.

Canadian regulators are going to great lengths to separate the manufacture and marketing of products containing alcohol or cannabis.

CBD cookies“It is proposed that the amended regulations would also prohibit all representations that associate a cannabis product, its packaging or its labelling (including its brand element) with an alcoholic beverage,” the proposal said. “For example, it would be prohibited to use terms related to alcoholic beverages, such as ‘beer’ or ‘wine,’ on cannabis products.

“It would similarly be prohibited for the name or logo of a company that manufactures alcoholic beverages to be used on a cannabis product. In addition to reducing inducements to use cannabis, this prohibition is felt to be necessary given the known health risks associated with the concurrent use of alcohol and cannabis.”

Conventional foods and foods containing cannabis will not be allowed to be manufactured in the same facility, according to the proposal. Manufacturers also may be required to use child-resistant, plain packaging to lower the risk of accidental ingestion by minors. The labeling of cannabis edibles would need to display Canada’s standardized cannabis symbol and a health warning message. Health claims or nutrition benefits would not be allowed to appear on the labels of cannabis edibles.