Canadian CANNAINVESTOR Magazine October 2018 | Page 41

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Third Party Possession of Cannabis Excise Stamps

The Government recognizes that LPs, retailers, and others licensed to operate in the legal cannabis arena may utilize third parties to assist with packaging logistics. One part of this would be the addition of adhesives to the excise stamps so that they can be applied to packaged products.

The proposal, therefore, is to allow these third parties to possess cannabis excise stamps for the purpose of applying adhesives for LPs. The liability/responsibility for the stamps would remain with the LP while the stamps were in possession of the third party.

Exemption for Test Kits and Reference Standards

The Government recognizes that certain cannabis-based products are not intended for human consumption. These products are test kits and reference standards.

“Test kits” are used to confirm the presence or concentration of a drug. Test kits are captured by the definition contained in the Cannabis Regulations. For any such test kit, a registration number will be issued under the Cannabis Regulations. If a registration number has been issued for a test kit, it is proposed that such a kit be exempt from the proposed excise duty framework.

Similarly, “reference standards” are designed for research purposes and not for human consumption. The idea is that the cannabis reference standard is a form of cannabis used as a measurement base to confirm the identity, strength, quality or purity of a substance. Given that reference standards are not likely to leave a laboratory or research facility, the proposal is that they too be exempt from the proposed excise duty framework.

The Government is seeking input on the Draft Proposals detailed above. The public consultation will remain open until October 17, 2018.

*Portions of this article were previously published on Canada Cannabis Legal, www.canadacannabislegal.com

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