On October 17, 2018, the Cannabis Act[1] came into force and introduced a federal regulatory regime to control the licensing and production of cannabis. However, the Act is largely silent as to the environmental obligations of licensed cultivators and processors (“licensees”). Environment and Climate Change Canada has since indicated that it is not planning to implement cannabis-specific regulations, and as such, licensees will be left to fend for themselves in navigating a complex web of federal, provincial, and municipal environmental laws.
Cannabis Waste Management
The Canadian cannabis market is expected to exceed $7 billion in its first full year of legalization, and with growth projected beyond 2019, regulators and licensees will soon face a new challenge: cannabis waste management. Industry projections provided to the Senate of Canada suggest that cannabis facilities will generate over 6,000 metric tonnes of waste in 2020. Cannabis waste can come in several different forms, including:
- Waste from cannabis flowers, trim, and solid plant materials;
- Contaminants from solvents and chemicals used during production; and
- By-products from production, such as greenhouse feedwater.
Given that a vast amount of production will be needed to satisfy industry demands, licensees must ensure that they comply with all applicable environmental laws and regulations when dealing with the ensuing waste and by-products. This article provides an overview of a licensee’s key obligations in this regard.
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