The Canadian Medical Cannabis (CMCC) was pleased to see the federal government release an ambitious set of regulatory recommendations concerning both recreational and medical cannabis in Canada, and we look forward to the opportunity to consult with the government on this important issue in the coming weeks.

CMCC supports recommendations which lead to better access to high-quality, tested and diverse cannabis products for patients. This paper takes a number of steps towards increasing that access, including allowing patients to more easily transfer between LPs, and removing the 30 day limit on purchases.

However, CMCC is concerned about recommendations relating to branding and plain packaging. These recommendation open the door to brand prohibition which would limit the ability of patients to compare products and work with physicians to choose those best suited to their therapeutic needs.

Further, CMCC remains extremely concerned and disappointed with the government’s recommended approach to medical cannabis taxation. If medical and recreational cannabis are taxed at the same rate and an excise tax is applied to medical cannabis, no amount of thoughtful regulations will serve to preserve the distinct, successful medical cannabis system patients experience in Canada today.

Canada is about to take a welcome step towards the regulation and taxation of adult recreational use of cannabis, but this shouldn’t come at the expense of the hundreds of thousands of critically and chronically ill Canadians who currently benefit from the use of medical cannabis.