With the legalization of recreational cannabis imminent in Canada, there has been a lot of news circulating regarding cannabis and the many compounds that are produced by the cannabis plant. Interestingly, the cannabis plant is capable of producing more than 400 different chemical compounds. Not all of these compounds are produced only by cannabis, however. There are a number of special compounds, including CBD, that the plant produces that are unique to the plant genus Cannabis. These compounds are known collectively as Phytocanabinoids, and include what was hoped to become Canada’s next biggest natural health product: CBD.
Phytocanabinoids are the chemical compounds secreted by the cannabis flower that are intended to provide relief to a number of different symptoms and conditions such as pain, nausea, anxiety and inflammation. Although the cannabis plant produces a number of different phytocanabinoids, the two compounds that are most often talked about and sought after are tetrahydrocannabinol (also known as THC) and cannabidiol (also known as CBD). THC is the principal psychoactive compound (a substance that has an effect on brain function) that produces the sensation of feeling “high”. CBD, on the other hand, is not psychoactive and does not produce the same sensation of feeling “high” that THC does. Although CBD does not produce the “high” that recreational cannabis users are often looking for, this phytocanabinoid is highly sought after because of its therapeutic potential. A simple Google search for CBD yields a number of therapeutic benefits that this cannabinoid are suggested to provide its users. These therapeutic benefits play a large role in why CBD is often used illicitly by those seeking relief from a number of ailments they may be suffering from.
In December of 2017, the World Health Organization’s (WHO) Expert Committee on Drug Dependence (ECDD) released a report from an initial review they conducted on the use of naturally occurring CBD. To summarize, the ECDD concluded in their report that “In humans, CBD exhibits no effects indicative of any abuse or dependence potential” that “CBD has been demonstrated as an effective treatment of epilepsy in several clinical trials” and that “CBD is generally well tolerated with a good safety profile.” Furthermore, the ECDD also noted that “To date, there is no evidence of recreational use of CBD or any public health related problems associated with the use of pure CBD.” Knowing this, it is difficult to imagine Health Canada’s categorization of CBD as a drug and not as a natural health product (NHP).
Will CBD be Categorized as a Natural Health Product (NHP)?
Knowing what we know about CBD to date, one could speculate that since CBD does not have the same “high” causing effects that THC does when it is consumed (e.g. smoked, ingested, vaporized) that the individuals seeking to use it would be doing so because of its therapeutic potential. It has been speculated (and hoped by many currently in industry) that CBD would be regulated as an NHP (natural health product) in Canada once Bill C-45 (the proposed Cannabis Act) comes into force later this year (October 17). With the amount of research currently being undertaken on CBD and a number of other different phytocanabinoids as documented by the Canadian Consortium for the Investigation of Cannabinoids, along with legalization of cannabis and the removal of cannabis and its preparations and derivatives from Schedule II of the Controlled Drugs and Substances Act (CDSA), it was common to assume Canada’s next biggest NHP may be taking over the shelves of health food stores by the end of this year. However, since the Cannabis Act has received Royal Assent it has been communicated that Health Canada intends to add Cannabis Phytocanabinoids such as CBD to the prescription drug list ending the speculation, that for the time being at least, this ingredient will not be a Natural Health Product.
Selling CBD in Canada
With this in mind, it is important to note what would be required for you to sell CBD-containing products. Depending on your product type and source of CBD the requirements and steps to legally sell vary significantly. In some cases, a substantial amount of scientific evidence would need to be provided to Health Canada to change the prescription status of a phytocannabinoid such as CBD. This would include information on the safety, efficacy and quality of the ingredient proving it can be used safely and effectively in a self-care environment such as in natural health products (NHPs).
dicentra is a professional consulting firm that specializes in addressing all matters related to safety, quality and compliance for all product categories in the life sciences, cannabis and food industries.
1What is CBD (Cannabidiol) And What Does It Do?
2 Cannabinoids 101: What Makes Cannabis Medicine?
3 WHO recommends the most stringent level of international control for synthetic opioid carfentanil
4 CANNABIDIOL (CBD) Pre-Review Report Agenda Item 5.2
5 Site Licensing Guidance Document