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PRODUCERS OF BASE CANNABINOID MATERIAL

Mandatory Requirements

The Cannabinoid industry is an environment where the accuracy of regulatory interpretation can leave market participants with a significant exposure to multiple liabilities.

Where clear mandatory requirements exist in your operational jurisdictions, we assist in the identification and implementation of remedial action in order that you can achieve regulatory compliance, removing your exposure to liability. Where there is a conflict of opinion or interpretation, we will work with the jurisdictional regulators to clarify the interpretations and implementation parameters and assist you to achieve regulatory compliance, removing your exposure to liability.

In certain jurisdictions the mandatory requirements are lower than you might wish to implement, and certainly lower than many discerning consumers will expect and demand. For those market participants wishing to stand above the minimum, and above the competition, we will advise you on achieving our vision of “Best Practice”.

This is a vision shared with major manufacturing and infrastructure participants, whose reach spans the globe. They share our vision, and clients who have achieved The Canna Consultants “Best Practice” standard can share in that market access – if we stand by you, so will they, throughout the globe.
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REGULATORY COMPLIANCE CHECK (RCC)

We will engage with you in a holistic manner so as to have a complete and detailed understanding of your business structure, processes, aims and future aspirations for your enterprise.

We will liaise with you in order to compile a comprehensive dossier which represents a complete record of your entire business and supply chain – absolutely everything from seed to shelf, from manufacture to marketing.

The Canna Consultants does not provide any legal advice or any legal services. We believe that such advice should only come from an identified, independent and professionally regulated individual. In this manner there is absolutely no question about who has provided legal advice, what legal advice they have provided (because it will always and only be in writing), all in a regulated relationship between you and a self-employed barrister in independent practice.

Acting as your intermediary, we will facilitate the instruction of a self-employed barrister in independent practice with expertise in regulatory issues. The barrister will be specially qualified to provide legal advice to receive their instructions directly from you, without the need for the instruction of a solicitor – saving you the dual costs usually associated with the instruction of a solicitor, and then a specialist independent barrister.

The Opinion provided will identify those aspects of your business which the independent, self-employed barrister believes comply with the UK regulatory requirements, plus those areas where there is a need for improvement before Regulatory Compliance would be achieved, all explained in an understandable format which you can thereafter use as a blueprint to work towards compliance.

The barrister will also be asked to comment upon aspects of the business which, while not in breach of any legal requirement, could be improved so as to bring the business up to what might be considered to be the “Best Regulatory Practice”.

Upon receipt of the Opinion from the independent, self-employed barrister, and in the event that it is necessary, The Canna Consultants will provide you with structured proposals for how Regulatory Compliance and Best Regulatory Practice could be achieved and the cost options of the same through the Achieving Regulatory Compliance (ARC) and Achieving Best Regulatory Practice (BRP) services.

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ACHIEVING REGULATORY COMPLIANCE (ARC)

The Canna Consultants will work with you in order to assist in the implementation of new processes, structures or operational standards necessary in order to achieve compliance with any (compulsory) Regulatory Compliance requirements that were felt to be lacking, as identified by the independent, self-employed barrister in the written Opinion provided to you.

Once compliant, you will then be eligible for:

  • The Canna Consultants’ continued Future Regulatory Liaison Service (FRL);
  • Advancement to the Accelerated Membership Scheme (AMS);
  • Advancement to the Retailers Placement Scheme (RPS);
  • Advancement to the Manufacturers Placement Scheme (MPS).

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ACHIEVING BEST PRACTICE (ABP)

The Canna Consultants will work with you in order to assist in the implementation of new processes, structures or operational standards necessary in order to achieve compliance with any (voluntary) Best Regulatory Practice requirements that were felt to be lacking, as identified by the independent, self-employed barrister in the written Opinion provided to you.

Once compliant, you will then be eligible for:

  • The Canna Consultants’ continued Future Regulatory Liaison Service (FRL);
  • Advancement to the Accelerated Membership Scheme (AMS);
  • Advancement to the Retailers Placement Scheme (RPS);
  • Advancement to the Manufacturers Placement Scheme (MPS).

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FUTURE REGULATORY LIAISON (FRL)

For the duration of your subscription (via a monthly fee) you, as an FRL client, will receive liaison assistance in respect of any regulatory enforcement action or enquiry by the FSA, MHRA, Trading Standards or ASA.

If, during your subscription period, you are the subject of any regulatory enforcement action or enquiry The Canna Consultants will discuss with you the subject matter of the action/enquiry and agree with you how you would like to proceed.

In the first instance this is likely to be contacting the enforcement authority on your behalf and discussing with them their concerns and your position in respect of the matter, seeking to identify whether there is any means for a swift and simple resolution that is satisfactory to both parties.

In addition to any specific regulatory liaison, all subscribers to the FRL service will be notified of any changes to any applicable food/cannabidiol-centric (but not general business) regulations or their interpretation, and advised how to achieve compliance with those new changes.

The service is subject to a maximum number of hours engaged per calendar month and the applicable subscription is bespoke to each applicant because, firstly, no two product repertoires are the same and, secondly, different applicants will have differing appetites for the number of hours to be included within the subscription. However, as an FRL client you will receive a discount from our standard chargeable rate for instructed work which exceeds that included within their subscription.

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PRODUCTION CERTIFICATION ASSESSMENT (PCA)

The Production Certification Assessment Service is targeted for the benefit of manufacturers of base Cannabinoid material which is utilised in the production of Cannabinoid-containing end products.

Following the provision of your in-house product Certification documentation, The Canna Consultants will organise the quarterly testing of each of your product lines in order to verify the consistency between your in-house certification results and those from an independent lab commissioned by The Canna Consultants.

The benefits which flow to you from this service are your ability to trade on the back of the consistency of your in-house certification.

In addition, for any retailer/wholesaler client (who could be the subject of a future compliance investigation or enforcement action), it would afford them a further level of comfort in that they had secured their product from a manufacturer which voluntarily subjected itself to independent verification and analysis of products, rather than utilised only its own in-house results.

In addition, a consistent history of satisfactory independent verification of in-house certification results would allow those products which have satisfactorily undergone verification assessment to be eligible for advancement to the Manufacturers Placement Scheme (MPS).

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COMPANY INFORMATION
MAST CONSULTING LTD
Company Number: 12191810
ico. Reg. Number: ZA547887
VAT Reg. Number: 334 8110 23
COMPANY ADDRESS

20-22 Wenlock Road
London, N1 7GU
ENGLAND

THE CANNA CONSULTANTS
COMPANY INFORMATION
MAST CONSULTING LTD
Company Number: 12191810
ico. Reg. Number: ZA547887
VAT Reg. Number: 334 8110 23
COMPANY ADDRESS

20-22 Wenlock Road
London, N1 7GU
ENGLAND

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