The number of people registering to access medical cannabis in Canada continues to decline according to Health Canada’s most recent quarterly report. In contrast, those registering for personal and designated cultivation of cannabis for their own medical purposes showed a reverse of this trend.

Medical client registrations with federally licensed sellers fell 2% from 183,909 in December 2023 to 180,878 in March 2024. Such registrations have been on a downward trend since late 2019, followed by a brief spike in 2020 related to the COVID-19 pandemic and brief restrictions on accessing brick-and-mortar stores. 

Those declines have been most pronounced in Ontario, Manitoba, Saskatchewan, and Alberta. Other provinces have shown a relative levelling off for the past two years following the brief spike in new registrations in 2020. 

Personal and designated production licences 

Similarly, active personal/designated production registrations have declined since a peak in September 2021. That trend began to reverse in November 2023 and increased month-over-month through March 2024. The number of individuals registered with Health Canada for personal and designated cultivation of cannabis for their own medical purposes increased 15% from 13,672 in December 2023 to 15,726 in March 2024.

Interestingly, this trend is seen in each province and territory as well, although increases were most pronounced in BC (696), Quebec (671), and Ontario (470).

Health Canada also continues to note that the number of grams per day associated with these personal and designated production licences continues to trend much higher than the average gram per day associated with those registered to access cannabis for medical purposes from a licensed producer. 

The average daily amount authorized by healthcare practitioners for those accessing medical cannabis from an LP has been between 2.0 and 2.4 grams per day since legalization began in October 2018.

Participants in the designated or personal production program have an average daily authorized amount of 34.4 grams, about 15 times higher than the average daily amount authorized by healthcare practitioners.

Authorized amounts by healthcare practitioners

While there were 4,728 healthcare practitioners associated with registrations made in the previous twelve months with federally licensed sellers, there were 1,015 healthcare practitioners associated with active personal/designated production registrations.

Of those 1,015, there were 233 healthcare practitioners associated with authorizing amounts equal to or above 25 grams per day, and just ten authorized amounts equal to or above 100 grams per day.

Most (78%) healthcare practitioners who authorized more than 25 grams a day were in BC or Ontario. All who authorized more than 100 grams a day were in BC and Ontario. An authorization of 100 grams a day would equate to a limit of 487 plants at any given time. Such licences can also be combined to up to four per location, meaning a designated grower with several authorizations could be growing hundreds or even thousands of cannabis plants with the potential to produce in the hundreds of kilograms of cannabis a year. 

Health Canada inspections ramped up

There have long been concerns from different levels of government over the potential for misuse and diversion of cannabis from these types of licences associated with high gram totals. 

Health Canada has ramped up inspections of such licences, more than 300 in the last two years. The most recent annual report also included 20 compliance and enforcement activities (other than inspection) for registered personal and designated production of cannabis for medical purposes, such as conducting seizures and destructions.

Of the 160 inspections of registered personal and designated production of cannabis for medical purposes locations in 2023-2024, 74 were in British Columbia, 63 in Ontario, 18 in Quebec, and five in New Brunswick. In the previous year, the majority of such inspections (115 out of 170) were in Ontario. In the previous year, the majority of such inspections were conducted in Ontario. 

The federal agency also sends notices to provincial colleges of physicians informing them of those health care practitioners connected to numerous high gram-a-day authorizations. In 2020, the Saskatchewan College of Physicians and Surgeons levied a $15,000 disciplinary action against a Saskatchewan doctor found to be profiting from issuing medical cannabis licences in 2018. 

In 2021, a medical cannabis patient who had been authorized 100 grams a day had a court reject an allowance for the patient to possess up to 1000 grams in public at a time.

In a memo from October 2022, Health Canada said that since it began a new processes to address high authorization amounts through the medical cannabis program, the agency had observed a decrease of more than 50% in the number of individuals registering to produce cannabis for medical purposes.

In September 2021, continued the memo, there were approximately 47,000 individuals registered with Health Canada. As of September 30, 2022, the number of registered individuals has dropped to approximately 21,700.

Health Canada says it has also refused or revoked more than 1,400 registrations, including over 700 for reasons of public health and safety. This represents a 113% increase in refusals and revocations, and a 423% increase in the number of refusals and revocations made on the grounds of public health and public safety since March 2022.

Canadian cannabis imports and exports

Exports of cannabis products from Canada continue to increase, with the last month in the most recent quarter, March 2024, showing a record amount of dried cannabis flower exported: more than 12,000 kilograms. 

Monthly exports of cannabis oil have also shown annual increases, although not as pronounced as for dried flower. January 2024 showed a record number of litres exported, several times higher than the average at more than 3200 litres.

Imports and exports of cannabis to and from Canada are only allowed for medical or scientific purposes. Imports are very restricted, with only a small amount of dried flower and cannabis oil ever making its way into Canada from abroad. Only 28.84 litres of cannabis oil and 28.76 kilograms of dried cannabis have been imported into Canada since October 2018.

This compares to 45,286.94 litres of cannabis oil exported and 21,2534.42 kilograms of dried flower exported. 

The increasing amount of cannabis being exported from Canada, combined with an overall decline in the amount of cannabis being produced in Canada, has led to the wholesale cannabis market finally beginning to move from a buyer’s market to a seller’s. 

This means a slight increase in how much the average cannabis grower will get for their cannabis on the B2B market. At the same time, price compression at the retail level continues to increase, with consumers paying less and less for the average gram of cannabis at the retail level.

Retail sales have also shown some levelling off and even declines in total dollars spent on cannabis in some provinces in the past year, potentially reflecting not only continued price compression but also declining volume or at least a levelling off of sales in some markets following years of year-over-year growth. 

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