Reading the Tea Leaves in the New ACMPR

Article by Lift

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In the wake of Health Canada’s announcement of the new ACMPR rules last week, several questions have been coming up from patients in regard to personal production licenses and access to cannabis from licensed producers: namely, how can patients go about registering to grow cannabis for themselves or via a Designated Grower, as well as how to access finished product from Licensed Producers in the interim.

Although Health Canada’s rules leave some room for interpretation, we’ve attempted to read the tea leaves, so to speak, as well as get some clarity from Health Canada. Below is our our QA with Health Canada last week, followed by some interpretations of the rules thus far.

Q: If a patient with an existing registration with a Licensed Producer wishes to grow cannabis, are they required to submit a new medical document to their LP, in addition to registration with Health Canada? Or does an existing medical document registered with a licensed producer suffice?

HC: Individuals who are already a registered client of a licensed producer (i.e. they registered with them under the Marihuana for Medical Purposes Regulations) are not required to submit a new medical document to their licensed producer. However, those who want to apply to Health Canada to produce a limited quantity for their own medical purposes under the Access to Cannabis for Medical Purposes Regulations, will need to obtain a new medical document from their health care practitioner to register with Health Canada.

Our Interpretation: Health Canada’s rules state that in order to produce cannabis for yourself, or as a designated grower, one needs to first obtain a new medical document from their health care practitioner to register with Health Canada. A copy of this registration certificate issued by the Minister can then be used to register with a Licensed Producer. This would appear to mean, in essence, that one cannot register to grow their own without first getting a new medical document and registering with Health Canada.

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