Canada Gazette, Part I, Volume 159, Number 35: GOVERNMENT NOTICES

August 30, 2025

DEPARTMENT OF INDUSTRY

OFFICE OF THE REGISTRAR GENERAL

Appointments

August 22, 2025

Rachida Lagmiri
Official Documents Registrar

DEPARTMENT OF HEALTH

CANNABIS ACT

Notice of Intent — Consultation on potential amendments to the Cannabis Tracking System Order

Purpose of notice

This Notice of Intent is to inform Canadians and interested parties that Health Canada is seeking feedback on potential amendments to the Cannabis Tracking System Order (CTSO). These changes would support the Government of Canada’s goal of reducing regulatory red tape while continuing to monitor the high-level movement of cannabis through the supply chain.

Amendments would focus on collecting only data essential to fulfilling the objectives of the CTSO, reducing or harmonizing reporting requirements where overlap exists, and improving operational efficiency.

Background

The Cannabis Act (the Act) established a legal framework to control the production, distribution, sale, import, export, and possession of cannabis in Canada, in a manner that protects public health and public safety. The Act’s purpose includes, among other things, providing adults with access to a quality-controlled supply of cannabis and deterring illegal activities related to cannabis through enforcement, sanctions, and robust monitoring of the legal supply chain.

Oversight is shared between federal, provincial and territorial governments. The federal government regulates production, while provinces and territories are primarily responsible for distribution and retail sales. Together, federal licence holders and provincial and territorial distributors and retailers ensure that adults across Canada have access to a legal, regulated supply of cannabis.

The purpose of the CTSO, as outlined in the Act, is to track cannabis to prevent it from being diverted to an illicit market or activity and to prevent illicit cannabis from being a source of supply in the legal market. Health Canada monitors the movement of cannabis across the supply chain through mandatory reporting requirements set out in the CTSO. Under the CTSO, reporting bodies include federally licensed cultivators, processors and medical sale licence holders authorized to possess cannabis, as well as provincially and territorially authorized distributors and retailers. These reporting bodies must submit monthly reports detailing cannabis production, inventory, distribution and sales. These reports are submitted electronically to Health Canada via the Cannabis Tracking System — a web-based application designed for the submission of this information. The CTSO works in an integrated way with other regulatory measures designed to help prevent the inversion of illegal cannabis into, and diversion of cannabis out of, the legal market. These other regulatory measures include rigorous physical and personnel security standards, record-keeping obligations, regular inspections and other compliance and enforcement tools, as well as other requirements set out in federal and provincial/territorial legislation.

Proposal

Since the implementation of the CTSO, stakeholders have raised concerns regarding the complexity and administrative burden of reporting, including duplicative reporting requirements with other federal departments, particularly for small and medium-sized federal licence holders. In light of this, Health Canada is conducting a review to explore opportunities to streamline the CTSO. This includes evaluating potential changes that could reduce administrative effort and improve data accuracy while maintaining regulatory oversight.

In providing your feedback to the questions below, you can include any data and information outlining your experience or any issues related to how the CTSO or the Cannabis Tracking System currently function (how long it takes to complete the data submission process each month, error messages or other system issues, concerns with how the information is requested, etc.). Any information submitted will be kept confidential and may be used in the development of potential amendments.

In addition to this Notice of Intent, Health Canada will be collecting different information through a separate voluntary cost-benefit analysis survey sent to reporting bodies only. The survey will collect specific information to understand the costs and benefits of proposed changes to the CTSO on reporting bodies. The cost-benefit analysis would be included in a Regulatory Impact Analysis Statement (RIAS) and published in the Canada Gazette if regulatory changes are put forward. Health Canada encourages reporting bodies to provide responses to the questions in both this Notice of Intent and the cost-benefit analysis survey.

Questions to guide feedback from interested parties

Health Canada is interested in receiving feedback on potential changes to reporting requirements that may be duplicative, redundant, or onerous, and where there are opportunities to promote efficiencies under the CTSO. Below are key questions for which Health Canada is particularly interested in receiving input, recognizing that these questions are geared towards obtaining feedback from reporting bodies. However, all feedback from interested stakeholders is welcome and should not be limited to responses to these questions. Please provide a rationale and/or evidence wherever possible, which could include the anticipated impact on the legal cannabis industry, consumers, and public health and public safety.

Health Canada would like to hear your feedback on the following questions.

General questions:

  1. What is the most important information that is required to be reported under the CTSO to track inversion/diversion? Is there different information that should be reported to help detect inversion or diversion? Why?
  2. How can Health Canada improve the CTSO to simplify reporting requirements while ensuring the CTSO meets its objective of tracking cannabis to prevent inversion into, and diversion from, the legal market? For example, Health Canada recently removed the requirement to report on the weight of plant trimmings pruned from whole cannabis plants each month, as it was determined that this did not provide relevant information for tracking purposes. Are there other reporting requirements that should be simplified or removed? Please include a rationale with any suggestions.
  3. The cannabis industry is evolving. Based on your experience, what changes would you suggest to track the movement of cannabis through the various stages of production? How could the CTSO requirements be modified to best capture processing innovations while not creating a significant reporting burden on reporting bodies?
  4. Are there any other reporting requirements related to cannabis that you find duplicative, redundant or particularly burdensome? Please describe them and share any suggestions you may have for improving regulatory efficiency.

The following are specific questions related to CTSO reporting requirements and are intended for reporting bodies and those who have experience with the CTSO. If you do not have experience or a perspective on the question asked, please put “not applicable” in your response.

  1. The CTSO allows reporting bodies to use “other” categories when reporting cannabis inventory. How do you use the “other” class of cannabis products, “other” class of unpackaged cannabis, “other additions to inventory,” and “other reductions to inventory” categories in your CTSO reporting? Please provide detailed examples of what you include in these categories.
  2. Should vegetative and whole plants remain as separate sub-classes in the CTS, or should they be combined into one class? What are the advantages and disadvantages of this suggestion? Are there other similar changes that you would recommend?
  3. Are there financial transactions that are difficult to account for in the current reporting requirements? Please provide details and examples. What changes would you make to simplify the reporting?

Provinces and territories are key partners in tracking cannabis through the distribution and retail cannabis frameworks they have established. Similar to federal licence holders, provinces and territories also report monthly through Health Canada’s tracking system on behalf of retailers and the wholesaler. Health Canada has received feedback that providing the information required under the CTSO is time-intensive and duplicative. Health Canada is considering streamlining provincial and territorial reporting requirements and would appreciate the perspectives of these partners on the following question:

  1. Please identify any specific reporting requirements that your province or territory would like to see reduced or eliminated. Please explain why. Additionally, please identify any reporting requirements that you consider essential to maintain, along with a rationale.
  2. If CTSO reporting requirements that apply to the provinces/territories (i.e. CTSO section 4) and retailers/distributors (i.e. CTSO section 5) were reduced, how would this impact your government and the administration of your provincial/territorial cannabis regulatory framework?

Next steps

Health Canada will consider the input received following the publication of this Notice of Intent to inform next steps. Any future regulatory proposal developed as a result of this consultation would be pre-published in the Canada Gazette, Part I, for public consultation.

Public comments

The publication of this Notice of Intent initiates a 60-day public comment period. Health Canada is seeking feedback on potential amendments to the CTSO. Input received will ensure that any regulatory amendments are informed by and responsive to the cannabis industry, reporting bodies, other interested stakeholders and the public. Health Canada welcomes input until October 29, 2025.

Contact information

Please submit your input by email to cannabis.consultation@canada.ca with the following title in the subject line: “Notice of Intent — Consultation on Potential Amendments to the Cannabis Tracking System Order”.

John Clare 
Director General
Strategic Policy, Cannabis
Controlled Substances and Cannabis Branch