CAVCM Response - Consultation on Potential Amendments to the Industrial Hemp Regulations - 2026-06-17

June 17, 2026

cannabis.consultation@hc-sc.gc.ca

Response to Health Canada:Consultation on Potential Amendments to the Industrial Hemp Regulations

The Canadian Association of Veterinary Cannabinoid Medicine (CAVCM) appreciates the opportunity to provide feedback regarding potential amendments to the Industrial Hemp Regulations (IHR).

The CAVCM is a national professional organization dedicated to advancing evidence-informed cannabinoid medicine through veterinary education, professional collaboration, research awareness, and knowledge translation.

While this consultation is primarily focused on industrial hemp regulation, the proposed changes may have important implications for veterinary medicine, animal health research, veterinary product development, and public health.

In particular, the regulatory framework governing industrial hemp influences the availability, development, research, and oversight of non-intoxicating cannabinoid products that may have future applications in veterinary medicine. 

The veterinary profession currently operates within a challenging regulatory environment where:

• veterinarians may discuss legally available cannabis products with clients;

• emerging evidence supports potential therapeutic applications of cannabidiol (CBD) and other non-intoxicating cannabinoids in animals;

• yet regulated veterinary cannabinoid products and veterinary-supervised access pathways remain extremely limited.

The CAVCM supports a risk-based regulatory approach that distinguishes non-intoxicating, low-THC hemp-derived cannabinoids from higher-risk intoxicating cannabis products, while maintaining meaningful safeguards around product quality, labelling, therapeutic claims, distribution, and post-market oversight.

In response to the questions outlined in the Notice of Intent, the CAVCM offers the following comments and recommendations.

1. What are the regulatory requirements under the IHR that impose an unnecessary burden?

The CAVCM believes that current restrictions surrounding industrial hemp flowering heads, leaves, and branches may unintentionally limit the development of regulated veterinary cannabinoid products and discourage evidence-based veterinary oversight.

At present, extraction and concentration of cannabinoids from industrial hemp flowering material generally falls within the cannabis processing framework, even where the resulting products are non-intoxicating and derived from low-THC industrial hemp.

As a result, veterinarians and animal owners have limited access to regulated cannabinoid products developed specifically for animal use, despite growing interest in non-intoxicating cannabinoids and emerging evidence supporting their potential therapeutic applications. 

This creates substantial barriers to:

• veterinary cannabinoid research;

• development of regulated veterinary cannabinoid products;

• investment in veterinary-focused cannabinoid innovation; and

• creation of veterinary-supervised access pathways.

The current framework may also unintentionally encourage consumers to seek products through unregulated or recreational channels rather than through veterinary guidance and regulated healthcare frameworks.

The CAVCM supports consideration of reduced regulatory barriers for non-intoxicating hemp-derived cannabinoids, particularly where products are intended for veterinary or healthcare use and appropriate safeguards are maintained.

The CAVCM also encourages Health Canada to consider pathways that would:

• permit the development of regulated Veterinary Health Products (VHPs) containing non-intoxicating cannabinoids;

• reconsider the inclusion of non-intoxicating cannabinoids on the Prescription Drug List where appropriate;

• consider inclusion of non-intoxicating cannabinoids within the VHP framework; and/or

• explore the development of a separate regulatory pathway for Veterinary Drugs Containing Cannabis (VDCCs).

2. What are the most important control measures to ensure industrial hemp is distinguishable from cannabis, and to prevent the illegal cultivation and diversion of cannabis?

The CAVCM supports maintaining appropriate controls to prevent diversion and to ensure that intoxicating cannabis products are not produced or marketed under the guise of industrial hemp.

Important safeguards include:

• maintaining THC concentration limits for industrial hemp plant material;

• mandatory testing and quality assurance standards;

• contaminant screening;

• accurate cannabinoid labelling;

• batch traceability;

• restrictions on unsupported therapeutic claims; and

• regulatory oversight of downstream processing and concentration activities.

The CAVCM does not support an unregulated marketplace for animal cannabinoid products.

Products intended for animal use should remain subject to meaningful quality, safety, and manufacturing standards.

3. What changes would you suggest to streamline the IHR?

The CAVCM supports a more proportionate, risk-based framework that recognizes the differing risk profiles of: 

• intoxicating cannabis products; and

• non-intoxicating hemp-derived cannabinoid products.

Potential approaches could include:

• streamlined authorization pathways for non-intoxicating cannabinoid products derived from compliant industrial hemp;

• reduced barriers for veterinary and scientific research;

• simplified pathways for regulated veterinary product development; and

• alignment with healthcare and veterinary oversight frameworks where appropriate.

The CAVCM believes that a regulated healthcare-oriented framework would better support public health and animal safety than the current environment, where many pet owners independently access products with limited veterinary oversight.

4. What requirements would you eliminate or reduce, and why?

The CAVCM supports reducing regulatory requirements that may not be proportionate to the risks associated with non-intoxicating hemp-derived cannabinoids.

Potential areas for consideration include:

• reducing restrictions that limit the sale or transfer of compliant industrial hemp flowering material solely to cannabis processors;

• simplifying licensing requirements for low-risk activities involving compliant industrial hemp;

• reducing administrative duplication between industrial hemp and cannabis processing frameworks where products remain non-intoxicating and low-THC; and

• streamlining research and product development pathways for veterinary and healthcare applications.

However, the CAVCM supports maintaining appropriate oversight related to:

• THC concentration;

• product quality;

• manufacturing standards;

• contaminant testing; and

• marketing claims.

These changes could support innovation, facilitate research, encourage development of regulated veterinary products, and improve access to veterinary-supervised cannabinoid therapies while maintaining appropriate public health safeguards. 

5. How would you decrease the administrative burden for industrial hemp licence holders?

The CAVCM does not have specific expertise regarding the day-to-day administrative requirements imposed on industrial hemp licence holders and therefore defers to industrial hemp producers and industry organizations on this question.

However, the CAVCM supports efforts to reduce administrative burden where such reductions do not compromise product quality, public safety, research opportunities, or appropriate regulatory oversight.

6. Would you modify the current definition of industrial hemp and, if so, how and why?

The CAVCM does not currently recommend changing the THC concentration threshold used to define industrial hemp.

The current threshold is internationally recognized and reasonably understood within existing agricultural and regulatory systems.

However, the CAVCM believes it is important that downstream processing and finished products remain subject to safeguards that prevent the concentration and commercialization of intoxicating THC products under the designation of "hemp."

The CAVCM encourages Health Canada to continue distinguishing regulatory oversight based on intoxicating potential and overall public health risk rather than solely on the presence of cannabinoids.

7. What changes would you suggest to streamline the management of the List of Approved Cultivars (LOAC)?

The CAVCM has no specific recommendations regarding the operational administration of the List of Approved Cultivars (LOAC), as this falls outside the organization's primary expertise in veterinary medicine and animal health.

However, the CAVCM encourages Health Canada to ensure that any cultivar approval framework remains sufficiently flexible to support the development, evaluation, and commercialization of new industrial hemp cultivars with diverse cannabinoid and terpene profiles, provided they continue to meet established THC limits and public safety requirements.

As scientific understanding of cannabinoids continues to evolve, emerging evidence suggests that both major and minor cannabinoids, as well as terpene profiles, may have differing therapeutic applications.

Maintaining a pathway for the development and evaluation of new industrial hemp cultivars may support future research and innovation in both human and veterinary medicine.

The availability of diverse industrial hemp cultivars may also facilitate future investigation into the safety, efficacy, and therapeutic potential of cannabinoid-based products while maintaining appropriate safeguards against diversion and intoxication risks.

8. Are there public health or public safety harms related to reducing the regulatory burden?

The CAVCM acknowledges that reducing regulatory burden without maintaining appropriate safeguards could create risks, including:

• inaccurate cannabinoid concentrations;

• contamination;

• excessive THC exposure;

• unsupported health claims;

• adverse drug interactions;

• species-specific toxicity concerns; and

• consumer confusion.

The veterinary profession regularly encounters situations where pet owners independently access cannabinoid products with limited understanding of cannabinoid content, formulation, dosing, or safety.

The CAVCM believes that a regulated framework that supports veterinary oversight, product quality standards, evidence-informed healthcare access, and appropriate post-market surveillance would better protect animal welfare and public health than the current fragmented marketplace. 

Thank you for the opportunity to provide feedback regarding potential amendments to the Industrial Hemp Regulations.

Respectfully submitted on behalf of the Canadian Association of Veterinary Cannabinoid Medicine (CAVCM),

Dr. Sarah Silcox, DVM

PresidentCanadian Association of Veterinary Cannabinoid Medicine (CAVCM)

www.CAVCM.com