In response to the CSA Staff Notice, on October 16, 2017, the CSE stated in a press release that the CSA has provided “significant clarity for all stakeholders in [the cannabis] sector” and is “fully supportive” of the CSA’s Staff Notice.
Issuer Response to CSA and TSX Staff Notices
Several issuers have praised the CSA’s approach for providing a balanced framework for the Canadian capital markets that is a reflection of the current disclosure approach in the U.S.
By contrast, due to the broad nature of the TSX Staff Notice, concerns have been raised in that it is unclear what impact the execution of this notice could have on TSX-listed issuers, causing uncertainty as to how the TSX’s approach will affect investors and businesses in the cannabis sector.
Conclusion
U.S.-Related Cannabis Issuers should ensure that they meet all the CSA expectations regarding disclosure requirements while working to address concerns raised by the TSX’s Staff Notice. All cannabis issuers should continue to monitor the evolving legislation, regulations and regulatory notices impacting their business.
which includes preventing young persons from accessing cannabis, protecting public health and safety by establishing strict product safety and product quality requirements. industry participants a bit more certainty as to what is to come, and allows those who wish to be proactive to begin taking steps towards ensuring that they will be compliant once the Act becomes law.
The packaging will be able to contain a maximum amount of 30 grams of dried cannabis, or the equivalent amount for other classes of cannabis. The maximum packaging amounts will be consistent with the maximum amounts of cannabis that an individual may legally possess in public under the Act.
Additional labeling requirements may be required by the Minister of Finance and any additional regulations associated with the taxation of recreational cannabis.
Safeguards
The regulatory proposal include a suggestion that a standardized cannabis symbol be used to label products that contain more than 10 ppm of THC.
Colorado has implemented a similar standardized cannabis symbol, known as a “universal symbol” for all cannabis products in the State. Edible products sold in Colorado must display the universal symbol on each individual standardized serving, meaning, chocolate bars and candies are required to be imprinted with the symbol.
The proposal also includes health warning messages to be rotating and required on all product labels, similar to what we see in Canada on cigarette cartons.
Much of what is in the proposed regulatory framework comes as little surprise to those who are already familiar with the ACMPR, the Act and the policy considerations underlying both pieces of legislation. That said, gaining further insights as to packaging and labelling requirements under the proposed regulatory framework gives industry participants a bit more certainty as to what is to come, and allows those who wish to be proactive to begin taking steps towards ensuring that they will be compliant once the Act becomes law.
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