Our Submission to Health Canada: Why Tinctures Must Be Allowed

Although legalization has passed and will be enacted this year, the government of Canada still has some work to do on the regulation of cannabis as a legal industry. To prepare, Health Canada must put together a framework that lets them regulate production and set standards for health and safety. As part of the research, Health Canada requested consultation on their Proposed Approach to the Regulation of Cannabis.

We at Token participated in this consultation, submitting a paper with the intention of providing input on one piece of the Proposed Approach in particular: Part 5.4, the Ingredients and Composition of Cannabis Products.

We support a safe and sustainable system that will serve to protect Canada’s consumers while creating a functional market that eliminates the need for illegal purchases. While we don’t support the recreational mixing of cannabis and alcohol, we do think that licensed Canadian manufacturers should be able to use ethyl alcohol in tincture products.

Cannabis tinctures are solutions made by dissolving extracted cannabis in alcohol. Tinctures are commonly used for medicines and herbs. To draw from a more relatable example, bitters used in cocktails are a tincture. They contain small amounts of alcohol, but the alcohol is denatured – which means it wouldn’t be ingested for recreational alcohol consumption. In other words, it would be very difficult (and unpleasant) to drink enough bitters to result in a heightened blood alcohol level.

As demonstrated in existing markets such as Oregon, Colorado, and California, consumers like tinctures. They are a great way to consume cannabis, as they offer a more precise dose. Because of their benefits, we argued that regulatory provisions should create an exemption when it comes to alcohol and allow for ethyl alcohol based tinctures.

To read through our detailed submission, view the images here.