INSIGHTS ON THE CANNABIS INDUSTRY FROM REGULATORY BARRISTER MATTHEW (MATT) LAWSON
Matthew (Matt) Lawson, a UK Regulatory Barrister has penned a series of discussion pieces under the rubric “Insights on the Cannabis Industry”.
In the infancy of the legal cannabis industry, the hot area was cultivation, with the key topics being improving yields and maintaining consistency. As the industry matures, the key area will be extraction – improving the science and ensuring innovation. Part 1 of barrister Matthew (Matt) Lawson’s insight into the industry looked at the Stages of Extraction, Part 2 looked at Methods of Extraction. In this Part 3 of barrister Matthew (Matt) Lawson’s insight into the industry looks at the Certification for Extraction.
The cannabis industry is still in its early stages and lacks specific regulations which market participants can adhere to. Regulations are developing within specific jurisdictions, but there is still no single, harmonious set of regulations.
Certifications required for operating extraction facilities vary depending on (a) the intended use of the product and (b) the jurisdiction within which the extracts are produced and/or sold. In some cases no certification is required, however, this is often because legal systems are still catching up with the progress of the industry. In the absence of enforced regulation, there is a growing trend of companies gaining certifications in order to evidence quality assurance.
The most important certifications in extraction are: EU GMP (EU Good Manufacturing Practice), which have established a common set of manufacturing standards at the European level. The standards and guidelines ensure quality, standardisation and safety in the manufacturing and production process. Different aspects of EU GMP apply to different industries (e.g. medical/pharmaceutical, food processing or cosmetics etc.). In addition, different jurisdictions have their own GMP guidelines and standards, which may or may not be held as equivalent to the GMP standards of other jurisdictions.
Certification of compliance to GMP standards are awarded after inspection of facilities by licensed inspectors, and compliance must be maintained by means of proper processes, staff training, equipment sourcing and maintenance, record-keeping, safety checks and product standardisation tests. Within this structure, national regulatory authorities have a level of control over where EU GMP applies in their own jurisdictions, and have the power to award certification via inspection.
The medical and pharmaceutical GMP standards are the most stringent compared to GMP standards for consumer packaged goods. Cannabis extracts used for medicinal purposes in Europe must be produced in EU GMP-certified facilities, while extracts used for the consumer market do not. Current Good Manufacturing Practice (cGMP) is similar to EU GMP but it is the GMP standard enforced by the Food and Drug Administration in the United States.
Matthew (Matt) Lawson is a UK Barrister who has advised Governments and Corporations for over 25 years in respect of human impactors – Food & Ingestibles, Medicines, Medical Devices and inhalation mediums. He provides worldwide Cannabis advice to clients who stem from Governments, to some of the largest multinational CPG corporations, to pharmaceutical giants, through to niche pre-IPO Start-Ups in the CPG and medical fields.