COVID-19 update: Cannabis licence holders

The page below was originally sent as an email to cannabis licence holders and applicants. No changes have been made to the original text.

COVID-19 update: Cannabis licence holders
Date: 2023-05-04

This email is an update on the status of the measures Health Canada has taken to support cannabis licence holders during the COVID-19 pandemic.

As you will recall, Health Canada temporarily adjusted its administration and enforcement priorities related to the Cannabis Act and its regulations in response to the COVID-19 pandemic. This was to provide greater flexibility to licence holders to operate while adhering to public health measures. The most recent communication sent by Health Canada on this issue was provided in March 2022, which extended the measures until September 30, 2023.

Health Canada has reviewed these measures, taking into consideration:

  • their use
  • rate of compliance
  • stakeholder feedback received

As a result, the following measures will remain in effect beyond September 30, 2023, until further notice:

1. Allowing licence holders to submit additional security clearance applications to fill key positions provided that a rationale for the additional clearances is provided. Key positions are:

  • master grower
  • head of security
  • responsible person
  • quality assurance person
  • alternates to these positions

2. Activities that do not require physical possession of cannabis can be conducted off-site by licence holders, provided that:

  • all requirements of the Cannabis Act its regulations are complied with, and
  • records are kept and made available to Health Canada upon request

Specifically, the activities that can be conducted off-site are:

Activities that can be conducted off-site
Activity Examples
Quality assurance
  • Investigating complaints received in respect of the quality of the cannabis, provided that a complete investigation can be conducted offsite.
  • Batch record approval by the quality assurance person from a remote location. This is provided the quality of the cannabis can be adequately assessed without physical possession of cannabis before it is made available.
Facilitating sale of cannabis
  • Answering phone calls
  • Registering medical patients
  • Helping individuals to navigate a website
  • Providing product information
  • Taking orders
Fulfilling recordkeeping and reporting requirements
  • Entering data and information to comply with monthly reporting requirements for the cannabis tracking system

3. Witnessing the on-site destruction of cannabis by licence holders can be done virtually (using a camera or another device). This is provided that a copy of the video is retained and is included in the destruction records required to be maintained under the Cannabis Regulations.

4. Permitting holders of an import or export permit to use different ports of entry or exit than those indicated on their permits. This is provided that all other requirements of the permit are respected.

5. There may be situations in which a security clearance holder must accompany cannabis for off-site antimicrobial treatment or destruction in a facility authorized to possess and produce cannabis as per the regulations. In these cases, they do not need to enter the facility, but must otherwise accompany the cannabis before it enters and, if applicable, after it exits the off-site facility.

6. Permitting a packaging date on cannabis products that is plus or minus 4 days of the printed packaging date on the label. This is provided records of the actual packaging date are kept alongside other required packaging and labelling records as stated in Cannabis Regulations paragraphs 224(2)(b) and 225(2)(b).

For more information on Packaging and Labelling requirements please consult the Packaging and Labelling Guide.

Note: Should Health Canada's priorities with respect to administration and enforcement of these provisions change, licence holders will be provided ample advance notice.

Measure that will end September 30, 2023

As part of the COVID measures, Health Canada has allowed sale for medical purposes licence holders to receive verbal attestations from patients when filling out their registration application to become a client for medical purposes. This is rather than requiring patients to provide a signature when they are not able to do so. Health Canada has reviewed the measure on receiving verbal attestation from patients. As the circumstances that led to this flexibility no longer apply, the measure will be phased out with an end date of September 30, 2023.

Next steps

Health Canada will be considering these measures for future regulatory changes where required.


Health Canada has published a Notice of Intent – public consultation on potential amendments to the Cannabis Regulations (Notice). Through the publication of this Notice, Health Canada is seeking feedback and comments on potential amendments to the Cannabis Regulations that aim to:

  1. streamline and clarify existing requirements
  2. eliminate inefficiencies in the regulations such as duplication between requirements
  3. reduce administrative and regulatory burden where possible, while continuing to meet the public health and public safety objectives in the Cannabis Act

The publication of this notice initiated a 60-day public comment period. To provide input on the measures or any other issue identified in the notice, please submit your input by email to by May 24, 2023.

Any future regulatory proposals based on the input received from this notice would be pre-published in the Canada Gazette, Part I for further consultation before any regulatory amendments are made final.

Health Canada's priority continues to be the public health and safety of people in Canada, including the risk of cannabis being diverted to an illicit market or activity. Note that licence holders are expected to continue to:

  • maintain quality control requirements
  • maintain testing, recall capacity and security controls
  • comply with the Cannabis Act and its regulations

Should any non-compliance with the Cannabis Act or its regulations be identified, the department will not hesitate to take further compliance and enforcement action, if warranted.

In closing, we trust that the measures we have outlined will enable you to focus your resources in the areas most required to manage your operations.

Contact us

Contact us if you have any questions.


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