Canadian organizations are urging Health Canada to reconsider proposed regulations in an effort to save the country’s craft cannabis industry.

Yesterday (May 18), representatives from a collective of five national and provincial pot organizations announced they would hand-deliver an open letter to the constituency offices of Federal Justice Minister Jody Wilson-Raybould and BC Minister of Justice David Eby. Today, the letter was delivered and released publicly along with a press release.

“The combination of the federal government’s legislation and regulations, and BC’s direction are going to kill BC’s small, community-based craft cannabis,” says Ian Dawkins of the Cannabis Commerce Association of Canada in a press release.

“If that happens, it will devastate rural economies and take decades to rebuild, so we are asking both levels of government to take action now, before it is too late.”

Expanding on some of the detail released yesterday, we’ve included the recommendations below:

Provincial recommendations:

1. “We call on the Province of B.C. to drop their misguided plan to physically warehouse cannabis and to look at virtual distribution in the form of advanced seed-to-sale tracking systems that are already in use in jurisdictions like Colorado and Washington. By moving to virtual tracking, the Government can maximize tax revenues and compliance, minimize cost, and avoid the pitfalls of physical storage.”
2. “We ask that the Province of B.C. reaffirm that, as cannabis production will be a legal agricultural activity, it is in-line with Agricultural Land Reserve (ALR) usage and that cannabis projects will continue to be permitted on ALR-zoned land.”
3. “We call on the province to craft more reasonable regulations for so-called “tied house” and “farm-gate sale” provisions. These provisions would allow for regulated sale of cannabis product in an on-farm retail environment, as well as allowing the sale of cannabis products in a retailer which has a relationship to the micro-producer in question.”

Federal recommendations:

1. “Micro-producer and –processors should be allowed to immediately begin registering with Health Canada as producers, to begin the process of preparing for legalization. At present, craft producers are unable to sign supply agreements with Licensed Producers or provincial distribution bodies, or register their corporations for the numerous ancillary services they will legally require. This massively disadvantages craft producers versus Licensed Producers, who are unfairly leveraging their medical licenses to prepare for recreational sales.”
2. “B.C. must push back against proposals form Health Canada that micro-cultivators be capped at 200-square-metres. This regulation is particularly onerous because it includes the cannabis clones and non-budding cannabis plants that are part of cannabis’ natural agricultural cycle, meaning 200-square-metres is effectively far less than that. In public consultations with industry experts, numbers in the range of 500-1,000-square-metres were suggested, and we believe this number is a far more accurate reflection of a reasonable micro-production facility to ensure the economic viability of the craft cannabis industry. The federal government is also ignoring the more sustainable option of outdoor micro-cultivators. Health Canada should allow outdoor micro-cultivators up to one acre. We call on the Government of B.C. and federal MPs in B.C. to advocate for craft growers at the federal level and request a larger footprint for craft producers.”
3. “Finally, the near-blanket ban on advertising of any kind and the highly restrictive packaging regulations for cannabis products will unfairly disadvantage craft producers. The proposed regulations for packaging do not allow micro-producers to distinguish their product from cheaper, mass-produced cannabis. Producers will be unable to highlight unique and attractive qualities of their products, such as organic certification, sustainable practices or local origin if they are only given a small postage-stamp-sized corner of the package to work with. We call on Health Canada to work with producers on alternative packaging guidelines that are evidence-based and more in line with international norms, and to work collaboratively with the B.C. craft cannabis community on those guidelines.”

The letter closes with a plea to both levels of government to allow for Canadian craft cannabis producers to have an opportunity to compete in the global cannabis market.

“Our members have the expertise, the strains, the high-quality product, and they want to participate in the legal market,” says Rosy Mondin of the Cannabis Trade Alliance of Canada in the press release.

“If governments want the economic benefits created by the sector, they need to make it possible for it to thrive or stand idly by and watch it all collapse.”