Health Canada has released guidance for cannabis producers on cannabis products with intoxicating cannabinoids other than delta-9-THC, including CBN.
Health Canada recommends that licensed producers apply the regulatory controls applicable to Delta-9-THC to all other intoxicating cannabinoids in their cannabis products.
This decision comes out of the lack of evidence on the effect of these other cannabinoids relative to Delta-9-THC, either alone, or in combination with others.
Intoxicating Cannabinoids
Health Canada uses ‘intoxicating cannabinoid’ to refer to cannabinoids that bind to and activate the type 1 cannabinoid receptor. Delta-9-THC is the most researched intoxicating cannabinoid and causes the ‘high’ of cannabis. The data on the effects of other intoxicating cannabinoids is limited.
These other intoxicating cannabinoids include:
- Delta-8-THC
- Delta-10-THC
- Delta-6a-10a-THC
- THC-O-acetate (THC-O)
- Cannabinol (CBN)
- Hexahydrocannabinol (HHC)
- Tetrahydrocannabivarin (THCV)
- Tetrahydrocannabiphorol (THCP)
- Tetrahydrocannabutol (THCB)
Some cannabis producers have made cannabis products with these intoxicating cannabinoids either instead of Delta-9-THC or in addition to it. There is not enough evidence to fully understand the effect of these other cannabinoids relative to Delta-9-THC, either alone, or in combination with others.
Deliberately including intoxicating cannabinoids to cannabis products circumvents regulatory controls on Delta-9-THC and could increase risks to public health and public safety. Health Canada is also concerned that consumers aren’t aware of these products and their potential risks.
Guidance on Intoxicating Cannabinoids
The existing Cannabis Regulations set out requirements specific to Delta-9-THC, including the maximum quantity allowed in a cannabis product. For example, cannabis topicals or extracts can’t contain more than 1000 mg of Delta-9-THC and edible cannabis can’t contain more than 10 mg.
The current regulations also include testing and packaging requirements intended to reduce the risks of accidental consumption and overconsumption of cannabis, and provide consumers with information to make informed decisions.
The new Health Canada guidance recommends that licensed producers apply these regulations to all cannabis products made to deliberately contain intoxicating cannabinoids other than Delta-9-THC. This includes: THC limit, validating the quantity or concentration of intoxicating cannabinoids, and accurate labelling.
This means the total amount of all intoxicating cannabinoids including Delta-9-THC shouldn’t exceed the regulatory limits for total THC per container. For example, an edible cannabis product containing 2 mg of CBN and 8 mg of delta-9-THC would align with the recommendations.
Banning Delta-8-THC
Delta-8-THC has been on the rise in cannabis products across North America. But despite its rise in popularity, some major provincial distributors, including those in Ontario and BC, stopped stocking Delta-8-THC until they understand it more. Products with CBN are still available in these provinces.
This change happened after the United States Food & Drug Administration continued to issue public health warnings about the serious health risks of Delta-8-THC. BC and Ontario turned to Health Canada for more guidance.
Also earlier this year, the Alberta Gaming and Liquor Corporation told some cannabis producers that it was including CBN within the federal 10 mg THC limit for edibles. This was based on guidance from Health Canada, however, they quickly reversed that decision.