Language selection

Government of Canada / Gouvernement du Canada

Search

Mandatory cannabis testing for pesticide active ingredients: Requirements

On this page

Disclaimer: Licence holders must use this page with the List and limits of the Mandatory cannabis testing for pesticide active ingredients. The List and limits lists pesticide active ingredients subject to the mandatory testing and their limits of quantification.

1.0 Who this is for and purpose

The requirements in this page apply to the following licence holders:

This page outlines the requirements for mandatory testing for pesticide active ingredients in cannabis, with details on the regulatory requirements under the Cannabis Regulations (the Regulations) and requirements related to:

It also includes Best practices related to pest management and pest control product use for holders of a licence under the Cannabis Act.

The objective of the mandatory testing is to assist licence holders under the Cannabis Act (the Act) to ensure that:

To meet these mandatory testing requirements, licence holders under the Act must show that none of the pesticide active ingredients listed in the List and limits are the result of unauthorized treatments on cannabis or have contaminated it. These requirements are in addition to the other analytical testing requirements under the Regulations that have been set out to protect the health and safety of Canadians.

Health Canada will use this page to assess licence holders' compliance with:

Licence holders should read this page with the requirements set out in the Act and the Regulations and those shown on individual licences.

2.0 Background

In February 2017, following three recalls of cannabis for medical purposes due to unauthorized use of pest control products, Health Canada began a series of unannounced inspections and targeted testing of cannabis products from licence holders to ensure that only authorized pest control products were used during the production of cannabis. These actions demonstrated that certain licence holders used unauthorized pest control products. Health Canada recognized the need to strengthen the monitoring of pest control product use and reduce the risk to public health.

Health Canada developed mandatory testing requirements and consulted with regulated parties and stakeholders in 2017 and 2018. In April 2018, the peer-reviewed methodology for analyzing pesticide active ingredients in cannabis was distributed to laboratories. The method was published in an article by Moulins et al. (2018) entitled Multiresidue Method of Analysis of Pesticides in Medical Cannabis.

Mandatory testing for the presence of pesticide active ingredients took effect on January 2, 2019.

On December 2, 2022, Health Canada amended the Cannabis Regulations. These amendments exempted NTRC from the clinical trial requirements under the Food and Drugs Regulations, resulting in such research being conducted solely with a research licence issued under the Regulations. The amendments pertaining to NTRC also introduced appropriate health and safety requirements, including compliance with good production practices (GPP), such as those related to pest control products under section 81.

3.0 Regulatory requirements

The Regulations outline regulatory requirements that licence holders are required to follow when conducting activities with cannabis.

For this page:

Part 5 of the Regulations lists the GPP related to cannabis.

Licence holders cannot sell, distribute or export cannabis unless it meets the applicable requirements set out in sections 80 to 88.94 of the Regulations.

Especially, subsection 81(1) sets out that licence holders cannot treat cannabis with a pest control product unless the product is registered for use on cannabis under the Pest Control Products Act or is otherwise authorized for use under that Act.

Part 6 of the Regulations lists the general rules for cannabis products. It sets limits on the residues of pest control products for plants, seeds, fresh and dried cannabis. For extracts, topicals and edible cannabis, the limits on the residues of pest control products are set for the cannabis used to make the cannabis product.

Also, the requirements in Part 6 of the Regulations establish acceptable limits for microbial and chemical contaminants in:

Publications referred to in Schedule B to the Food and Drugs Act establish the tolerance limits for these contaminants. They include limits on certain pesticide active ingredients. The tolerance limits for the pesticide active ingredient must be appropriate for:

The Pesticides Regulatory Directorate's online pesticide label search tool can be used to determine which pest control products are registered or authorized for use on cannabis. All other pest control products are prohibited from being used on cannabis or industrial hemp.

The Pest Control Products Act prohibits the use of unregistered pest control products on cannabis or industrial hemp, and requires that authorized pest control products be used in accordance with label directions.

4.0 Licence conditions

Under section 40 of the Act, licence holders must comply with the terms and conditions set out by their licences. As such, licence holders must meet the requirements set out in this page in the manner specified by the term and condition listed in their licence, depending on their class, and as described below.

Holders of a licence for cultivation and holders of a licence for processing have the following condition on their licence:

"The licence holder must meet the requirements set out in the Health Canada document entitled "Mandatory cannabis testing for pesticide active ingredients: Requirements."

Holders of a licence for analytical testing have the following condition on their licence:

"Any pesticide testing activities conducted under the scope of Health Canada's Mandatory cannabis testing for pesticide active ingredients: Requirements must meet the requirements set out in that document."

Holders of a licence for research who are conducting NTRC have the following condition on their licence:

"With respect to non-therapeutic research on cannabis involving the administration or distribution of cannabis, that is not a cannabis product, to human participants, the holder of the licence must meet the requirements outlined in section 5.0 of the document entitled, "Mandatory cannabis testing for pesticide active ingredients: Requirements", as if the holder of the licence for research was the holder of a licence for processing in respect of any lot or batch of cannabis that will be administered or distributed to human participants. In the case of a holder of a licence for research that cultivates, harvests, or propagates cannabis, they must meet the applicable requirements in section 5.0 of the document as if they were a holder of both a licence for processing and cultivation. In respect of section 5.2 of this document, a portion of the representative sample of each lot or batch of the cannabis that is administered or distributed must only be retained for at least until the date after which any research that involves administration or distribution of that lot or batch of cannabis to a human participant is complete."

Holders of a licence for industrial hemp under the Industrial Hemp Regulations do not have a condition on their licence to conduct mandatory testing for pesticide active ingredient residues. However, any industrial hemp (for example, heads, leaves, branches) that is used in the production of cannabis products is subject to the mandatory pesticide testing requirements by virtue of the conditions noted above on the other licences.

5.0 Testing, reporting, and record keeping requirements

The requirements outlined in this section are in addition to other requirements set out in Part 5 and Part 6 of the Regulations.

Licence holders must produce, distribute, store, sample and test cannabis for pesticide active ingredient residues according to standard operating procedures designed to ensure compliance with the requirements outlined on this page.

5.1 General requirements

5.1.1 To meet requirements

A cannabis lot or batch is considered to have met the mandatory pesticide testing requirements once it has been tested according to the requirements outlined on this page and it has either:

Once the cannabis lot or batch has met the requirements above, there is no need to retest the lot or batch at later stages of production or distribution for the purposes of these requirements. If cannabis is retested, licence holders must:

5.1.2 Cultivation licence holders

A cultivation licence holder must not sell, distribute or export a lot or batch of cannabis plants or seeds that is a cannabis product unless it has met the requirements on this page.

This means:

5.1.3 Processing licence holders

A processing licence holder must not use, sell, distribute, or export a lot or batch of cannabis that they have received, unless it has first met the requirements outlined on this page. For example, they cannot extract, formulate, package or label the cannabis. However, the processing licence holder may conduct activities necessary to determine whether the lot or batch meets the applicable requirements, including storage, sampling and testing for pesticide active ingredients.

If a processing licence holder also has a cultivation licence, they must not use, sell, distribute, or export a lot or batch of cannabis that they have harvested under their cultivation licence, unless it has first met the requirements outlined on this page. However, they may conduct ancillary post-harvest activities prior to testing such as drying, trimming and milling. Further, seeds, plants, or other propagation material that they receive or otherwise obtain for their own cultivation do not need to meet the requirement outlined on this page before being used.

Meeting the requirement outlined on this page means:

5.1.4 Research licence holder conducting NTRC

A research licence holder conducting NTRC must ensure that a lot or batch of cannabis meets the requirements outlined on this page before administering or distributing it to human participants.

When authorized to cultivate, propagate or harvest cannabis, licence holders must:

When receiving cannabis from another licence holder, licence holders must:

5.1.5 Research and development activities

Licence holders must not sell, distribute, export, or administer cannabis obtained from research and development (R&D) activities unless it meets the requirements on this page.

R&D activities need to meet the requirements of subsection 237(1) of the Regulations. Health Canada could verify this information during an inspection. Also, note that any R&D with a pesticide may require a research authorization from the Pesticides Regulatory Directorate.

5.1.6 Timing for required pesticide testing

Figure 1 illustrates when testing by licence holders for pesticide active ingredients is intended to occur depending on the different classes of cannabis.

Figure 1: Summary of timing for required pesticide testing
Figure 1
Figure 1: Summary of timing for required pesticide testing

Fresh or dried cannabis is intended to have pesticide testing completed by either the cultivation, processing or NTRC licence holder before it goes to consumers either as a fresh or dried cannabis product, or before it becomes a cannabis extract, topical or edible cannabis.

Cannabis plants and seeds are intended to have pesticide testing completed by the cultivation licence holder before it goes to consumers.

5.2 Testing requirements

Testing must be conducted for all pesticide active ingredients listed in the List and limits.

Testing must be conducted on a representative sample of each lot or batch of cannabis.

To be representative, the quantity and quality of a sample should be proportional to and reflective of the total lot or batch. Composite samples, where subsamples of multiple and distinct lots or batches are blended and analyzed together as 1 sample, are not considered representative.

A representative sample of cannabis seeds may be a sample of the cannabis plants from which the seeds were taken.

Additional guidance on sampling procedures may be obtained in pharmacopeias (for example, Herbal Drugs: Sampling and Sample Preparation of the British Pharmacopeia).

A licence holder who requests an analysis must keep a portion of the analysed sample for at least 1 year after the date of the last sale of any portion of the tested cannabis lot or batch.

The retained portion of the sample must be of sufficient quantity to enable a test of the sample for pesticide analysis by Health Canada.

A processing licence holder who receives cannabis from an industrial hemp licence holder must retain a representative sample of the lot or batch of cannabis.

5.2.1 Laboratory testing

A third-party laboratory that holds an analytical testing licence under the Regulations must conduct the mandatory pesticide testing.

The laboratory must be a distinct entity that functions and reports independently of the requester of the analysis.

Independence is crucial. Although the requester and the laboratory aim for quality-controlled cannabis, their interests may conflict, as the laboratory's report can impact production outcomes.

The laboratory must have separate facilities, equipment and trained employees to fulfill its duties and responsibilities.

Before selecting a laboratory, the person requesting the analysis must:

The laboratory must issue a certificate of analysis for each lot or batch of cannabis that they analyze.

The certificate must contain:

5.2.2 Method validation

The laboratory must ensure its methods have been validated before using them.

The methods must be able to quantify pesticide active ingredients against the background of the naturally occurring chemicals in the samples.

Licence holders can obtain guidance for validation in publications such as the Q2(R2) Revision of Analytical Validation or a standard listed in Schedule B to the Food and Drugs Act

The laboratory must produce and keep records documenting the results of validation studies.

Similarly to subsection 92(1) of the Regulations, all licence holders involved in the testing share a responsibility to ensure that it is conducted using validated methods. As such, cultivation, processing or NTRC licence holders are expected to take meaningful steps to ensure that the laboratory they are hiring under these requirements uses properly validated methods. Health Canada may verify records relevant to the method validation during inspections of licence holders.

The laboratory's LoQ must be equal to or lower than the LoQ set in the List and limits. For example, Health Canada sets an LoQ for abamectin of 0.1 ppm. This means the analytical method used by the laboratory must be able to reliably quantify residues of abamectin as low as 0.1 ppm or better. The limits developed by Health Canada are not reporting limits but minimum standards of performance for testing laboratories.

5.3 Reporting requirements

The requester of the analysis must notify Health Canada of any positive test result.

A positive result includes any result that is equal to or above the testing laboratory's LoQ. The requirement to report applies to all positive test results from testing mandated in the General requirements section, including:

Preliminary information generated before completion of the laboratory's review and quality-control procedures does not constitute a positive or negative test result for the purposes of reporting. A test result becomes subject to the reporting requirements once the laboratory has determined its outcome. The reporting obligation applies even if the result is later re-tested, contradicted, or determined to be a false positive.

Table 1 contains examples of the test results licence holders are required to report to Health Canada.

Table 1: Examples to clarify when test results need to be reported to Health Canada
Example Lab LoQ (ppm) Health Canada LoQ (ppm) Test result (ppm) Report to Health Canada
1 0.1 0.1 0.163 Yes – above lab LoQ
2 0.05 0.1 0.087 Yes – above lab LoQ (even if less than Health Canada LoQ)
3 0.1 0.1 0.067 No – result is below lab LoQ (estimated value)
4 0.05 0.1 <0.05 No – result is below lab LoQ

Licence holders must email the notification, including the certificate of analysis for the affected lots or batches, to compliance-cannabis-conformite@hc-sc.gc.ca no later than 7 calendar days after receipt of the results.

Despite the above, holders of a processing licence are exempt from the requirements in this section if the positive-testing lot or batch of cannabis is a cannabis extract that was produced solely from lots or batches of dried or fresh cannabis that all met the requirements outlined on this page, including any applicable testing, reporting, and record keeping requirements.

Even in cases where reporting is not required, licence holders must still ensure that the pesticide residues comply with the applicable regulations. In particular, pesticide residues are chemical substances that should be managed by their Preventive Control Plan under Part 5 of the Regulations and comply with the tolerance limits prescribed by Part 6.

5.3.1 Received lots or batches of cannabis

A licence holder who receives a lot or batch of cannabis that was previously tested for unauthorized pesticide active ingredients must ensure that any positive test results were reported to Health Canada.

Previous testing may be confirmed by requesting a copy of the applicable certificates of analysis for the received lot or batch, or by obtaining a signed attestation from the supplying licence holder. If another licence holder has already reported the positive results, the receiving licence holder must retain a document confirming Health Canada's decision.

If positive results were not previously reported, the licence holder receiving the cannabis must report the test results to Health Canada no later than 7 calendar days after receipt of the cannabis.

Mandatory testing is designed to prevent the need for product recalls related to the unauthorized use of pest control products on cannabis. If a cannabis product that has been treated or contaminated with any unauthorized pest control product has been sold, distributed or exported, licence holders must immediately:

If a cannabis product needs to be recalled, licence holders must submit the information listed in subsection 247(1) of the Regulations. The Cannabis voluntary recall guide helps licence holders understand their role in a voluntary recall and comply with its requirements.

Health Canada publishes all product recalls on its Recalls and safety alerts.

5.3.2 Product quarantine and root cause analysis

A licence holder must not sell, distribute, or export any lot or batch of cannabis that has been sent for pesticide active ingredients testing until they receive:

When reporting a positive test result to Health Canada, licence holders must quarantine the affected lot or batch of cannabis until otherwise instructed by Health Canada. The licence holder must do a root cause analysis to identify the source of contamination and submit it to Health Canada for review.

Health Canada will not allow the sale, distribution, or export of the affected lot or batch if:

5.3.3 Corrective and preventive action plan

Health Canada may require the licence holder to take corrective actions regarding the affected lots or batches of cannabis and preventive actions, as applicable.

Health Canada may take additional actions necessary to protect the health and safety of Canadians, including compliance and enforcement actions, if warranted.

5.3.4 Issuance of decision by Health Canada

The cannabis must remain in quarantine until instructed by Health Canada.

After reporting positive results as required by this section, licence holders must submit information upon request from Health Canada, as outlined in the:

Health Canada will review the requested information and will decide on the release of the affected cannabis.

Health Canada will assess reports of cannabis that has tested positive for pesticide active ingredients. As shown on Figure 2, this assessment is based on the root cause analysis provided by the licence holder and other information available to Health Canada. The assessment also takes into consideration the risk to health posed by the measured concentration of pesticide active ingredients. Following this assessment, Health Canada will share its decision with the licence holder, with potential outcomes including:

Figure 2: General process flow of actions taken by licence holders and by Health Canada in a positive pesticide results case
Figure 2
Figure 2: General process flow of actions taken by licence holders and by Health Canada in a positive pesticide results case

This figure illustrates the process followed when a cannabis product tests positive for pesticides.

  • Licence holder receives positive results
    • Places cannabis in quarantine
    • Reports positive results
    • Initiates root cause analysis (RCA)
  • Health Canada receives notification and opens case
  • Licence holder submits RCA
  • Health Canada reviews RCA
  • More information needed?
    • No: Go to next step
    • Yes:
      • Health Canada requests more information
      • Licence holder submits more information
      • Health Canada reviews RCA
  • Corrective and preventive action plan (CAPA) required?
    • Yes:
      • Licence holder proposes CAPA
      • Health Canada reviews CAPA
    • No: Go to next step
  • More information needed?
    • No: Go to next step
    • Yes:
      • Health Canada requests more information
      • Licence holder submits more information
      • Health Canada reviews CAPA
  • Health Canada issues closing communication

Licence holders who choose to voluntarily destroy the affected lot or batch may only do so after receiving authorization from Health Canada to release the cannabis from quarantine. This means maintaining quarantine of the affected lot upon receipt of the positive results, until Health Canada provides instruction concerning the quarantine.

5.4 Record keeping requirements

All licence holders who requested or conducted the analysis, and all licence holders who received a previously tested lot or batch of cannabis, must maintain all records relevant to the mandatory testing requirements at the licensed site for a period of 2 years after the day on which the information is recorded.

This includes results that were reported to Health Canada and those that were not, as well as those related to lots or batches of cannabis that were destroyed. These records must be made available for review in a timely manner during inspections.

These record keeping requirements are in addition to those in section 231 of the Regulations.

Licence holders for processing that received a lot or batch of cannabis that was previously tested for pesticide active ingredients must keep a record demonstrating how they ensured that the lot or batch meets all requirements outlined in the Testing, Reporting, and Record keeping sections.

This record may include:

6.0 Focus of inspections

Inspections conducted at licence holder sites to ensure compliance with the mandatory testing requirements may include the verification of records and activities. For example, inspectors may ask to review:

Inspectors may collect samples of cannabis and cannabis products from the licence holder's site for testing at Health Canada's laboratory. In addition, samples collected may include inputs used at the site, such as soil, fertilizer, ingredients or pest control products.

Inspectors may also assess compliance with the relevant sections of the Regulations.

Under Part 5 of the Regulations, licence holders are expected to assess possible sources of contamination and adopt precautionary measures to prevent the contamination of the cannabis they produce. Sources of contaminants may include:

To help assess these sources, licence holders may consider:

Health Canada has the authority to take compliance and enforcement actions if an unauthorized pest control product is used by a licence holder, whether or not that product is listed in the List and limits.

Health Canada provides an inspection report to the licence holder and may also share the test results of samples taken during inspections with the relevant licence holder. Finally, Health Canada publishes a summary of its inspection data on a yearly basis.

Licence holders may consider publishing their test results for cannabis to promote transparency and openness.

7.0 Best practices related to pest management and pest control product use for holders of a licence under the Cannabis Act

This section outlines best practices for pest management, to reduce the need for pest control products in cannabis production, and best practices for pest control product use for licence holders under the Cannabis Act.

Pest control products are important tools to control insect, weed and disease populations. The use of pest control products during the production of cannabis has a direct impact on cannabis plant health and final cannabis products. Pest control products are regulated in Canada through a program of pre-market scientific assessment, enforcement, education and information dissemination. These activities are shared among federal, provincial or territorial and municipal governments and are governed by various acts, regulations, guidelines, directives and by-laws.

The Pesticides Regulatory Directorate is the federal authority responsible for pesticide registration and re-evaluation. The Regulatory Operations and Enforcement Branch is responsible for compliance and enforcement of the Pest Control Product Act and its Regulations. Provincial and territorial responsibilities may include:

The role of municipalities is to enact by-laws, which may set further conditions on the use of pesticides.

7.1 Best practices

Implementing an integrated pest management program to reduce the reliance on pest control products for pest control during cannabis production.

An integrated pest management program, as part of GPP, is an approach to effectively and sustainably reduce pest populations. An integrated pest management program coordinates many measures against a target pest. These measures could be biological, chemical, cultural or mechanical and may also include pest behavioural methods to reduce pest populations to acceptable levels.

Aspects of an integrated pest management program are:

When using pest control products during cannabis production

8.0 Contact us

For more information about or to comment on the mandatory testing requirements, email compliance-cannabis-conformite@hc-sc.gc.ca.

For all other questions, refer to the Cannabis and industrial hemp contact information for licence holders, applicants and industry to find the appropriate email address.

Page details

2026-07-31