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Let's say you're making the transition from growing cannabis in the legacy market to growing cannabis in the new legal market, and after an infuriatingly long wait, you finally got your license!
But what about your plants?
Those beautiful plants that you grew and cared for while still in the legacy market?
Health Canada and the CRA do allow you to bring your plants into your legal facility, with a couple of important caveats.
You must declare EVERYTHING.
However many plants and/or seeds you’re bringing, make sure every item is declared. They don’t care about the strains or batches – they just want the total.
Be wary of bringing in flowering plants! Technically, there are no regulations stopping you from doing this. However, the CRA has been known to fine people in the past for doing so. While various representatives at both the CRA and Health Canada have verbally told people that they can bring in flowering plants, neither organization has been willing to confirm this in writing. If you want to bring in your own flowering plants - do so at your own risk!
If something changes after you declare it, you also must have a record of it. Let’s say, for example, that you declared 300 plants. But you end up only bringing 295 because 5 of them weren’t looking healthy. If you get audited, and they see 5 missing plants, they’re going to assume the worst! Make sure you can prove what happened to them and when. Telling them during that audit is not going to be enough; you need to have a record from when it happened!
It’s also important to note that when you get your license and move into your new facility, you only have until midnight the day that you get your license to bring those plants into the facility. That’s not much time. But after that window closes, you can’t bring anything else in (unless you purchase it from another licensed producer).
CertiCraft makes it easy to create a record of your starting inventory by providing a form to enter all of your starting material.
In summary, 4 tips for your starting materials:
1. Declare everything
2. Bring in flowering plants at your own risk
3. Keep a record of any changes from what you declared
4. Bring in declared plants the same day you get your license
This article was written in tandem with Mike F.