After receiving your cannabis licence, you must notify Health Canada of any changes to your company structure, key employees, licenced activities, or licenced operations areas by submitting a licence amendment application or change request through your CTLS licence holder account. Some of these changes will only require a simple notification to Health Canada, while others will need to be submitted for approval before being put into effect. Other changes may not require any notification at all.
Situations where a license amendment requires a request for approval prior to implementing the change include:
- Change in the Quality Assurance Person (QAP) – applicable to cannabis processors (standard or micro)
- Change in License Holder name or site address – note that cannabis licenses are site-specific and cannot be moved. A site location change requires a new license application to be submitted.
- Adding cannabis possession to a building – if you want to add the activity to possess cannabis in an approved building
- Adding sales activities for processing licenses – this is also known as a “sales amendment” application. Processors initially have conditions on their license which restrict the sale of cannabis extracts. cannabis topicals and edible cannabis.
- Therefore, a cannabis license amendment must be filed to add the activity of sales.
- Change in the Site Plan – some changes made to the site plan require approval by Health Canada. This includes changing the site perimeter, adding a new building to the licensed site, adding/changing a storage area, adding an outdoor grow area, or modifying an approved building to include possession of cannabis
- Change in license class or subclass – Health Canada will need to provide approval in order for you to add, change or remove a license class or subclass from your cannabis license
Situations where a license amendment requires only notification to Health Canada and no approval is needed are:
- Changing the Responsible Person or Adding/Changing/Removing the Alternate Responsible Person
- Changing the Head of Security/Master Grower or Adding/Changing/Removing the Alternate Head of Security/Master Grower
- Adding, changing, or removing Directors and Officers of the corporation that holds the cannabis license
- Changing the Site Plan in a way that does not affect the site perimeter or physical barrier surrounding the site or changing an approved outdoor grow area’s size
- Updating or changing your Organizational Security Plan (OSP)
- Changes to administrative information such as mailing address, phone number, email address or fax number
- Ceasing license activities – You need to tell Health Canada if you plan to cease authorized activities on your license and the notification should be submitted 30 calendar days before stopping activities.
Finally, some situations do not require approval or notification to Health Canada. For example, adding an operations area (including a growing area) within an approved building that is already authorized for the possession of cannabis on your license does not require approval or notification. Keep in mind that you still need to meet applicable physical security requirements and Health Canada can verify compliance at any time.
It’s crucial to keep in mind that compliance is still key; as a result, you must maintain records and update your internal documentation whenever a change—no matter how little or significant—is made. Standard Operating Procedures, the Good Production Practices report, the organisational security plan, etc. are examples of this. Assessing whether local authorities need to be informed of the changes is also necessary. Within 30 days following these incidents, the local authorities must receive a written notification, and a copy of each notice must be forwarded to Health Canada as well:
- issuance of a license
- amendment of a license
- reinstatement of a license
- suspension or revocation of a license
As always, Health Canada may inspect your site to verify compliance with the regulations.
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