What to know when exporting health-related marijuana to Germany


By now, every person knows that to export health-related cannabis to Germany, which is by far the biggest importer of health-related cannabis flower in the planet, attaining European Union Superior Manufacturing Practice (GMP) is a prerequisite.

But beyond finding that certification, particular high-quality specifications could have massive implications if they are not considered and integrated into a business’ strategy properly in advance of any exports taking location.

One particular instance is the microbiological high-quality of flower.

Acceptable microbial levels are defined in basic monographies of the European Pharmacopoeia, and producers may possibly comply with these levels either by increasing in an particularly clean atmosphere or by irradiating the flower to decontaminate it.

On the other hand, irradiation of the flower will have to be carried out in a laboratory that is compliant with stringent German specifications, and such facilities may not be readily offered in every single nation.

In addition, the German importer desires to apply for a unique permit to be in a position to distribute an irradiated medicinal item.

Irradiation of the items could have a large influence on organizations mainly because of the operational, economic and bureaucratic challenges it could represent for unprepared firms.

To irradiate or not?

Corporations that develop a item that is not compliant inside the acceptable microbial levels of the European Pharmacopoeia have no other choice than to irradiate their cannabis flower if they want to be in a position to export to Germany for pharmacy dispensing.

On the other hand, even firms that develop “clean” item may want to think about irradiation as element of a company selection involving security considerations. The firms may want the microbial count to be as close to zero as feasible in consideration of individuals with a depressed immune technique.

It is typically accepted that irradiation does not adjust the levels of THC or CBD, but it does decrease the presence of some terpenes. Some argue that much less terpene content material diminishes the therapeutic worth of the flower, which is an argument for not irradiating item.

Corporations that develop “clean” item and are in a position to pick out no matter if to irradiate will need to balance these two elements.

If irradiation is required – or wanted – locating a certified laboratory to do it could be a challenge in numerous of the nations now aiming to export to Germany.

A different choice could be that the producer transfers the burden of the irradiation course of action to the importer. Whilst carrying out so in Germany is feasible, this would certainly imply exporting at a lower cost per gram, as the importer will have to deal with burdensome economic and operational challenges.

Following procedures

Testing is vital to identify no matter if flower is compliant with acceptable microbial levels, even though it is feasible the final results could vary depending on how the testing is carried out.

That is why it is significant that testing is carried out in accordance with the German Pharmacopoeia (DAB) Monograph, which establishes a detailed testing methodology, as properly as procedures the European Pharmacopoeia describes for testing unique contaminants.

German paperwork

Irradiation is not just a trouble faced by producers.

German importers of irradiated health-related cannabis flower will have to submit an application to the Federal Institute for Drugs and Health-related Devices (BfArM) for every single range of flower they intend to distribute.

This is the case even if an additional importer currently submitted an application for the exact same item, as is generally the case for flower imported from the Netherlands by numerous distributors.

The BfArM charges a charge of four,500 euros ($four,951) per application. So, if an importer desires to distribute only 3 forms of flower – higher-THC, higher-CBD and balanced, respectively what numerous would think about “the minimum” present of items – the importer will have to strategy to spend 13,500 euros in charges to the BfArM to obtain authorization to distribute these irradiated items.

Not only is the direct economic burden important mainly because of the charges, but the paperwork and time involved, which could take numerous months, can also delay the product’s time to market place.

The BfArM demands a extended list of documents in which the irradiation course of action desires to be explained in detail.

Who irradiates?

Just about all the flower presently getting sold in Germany is imported from the Netherlands and Canada, with an inaugural shipment from Portugal occurring not too long ago.

The flower created in the Netherlands by Bedrocan is irradiated by a third-celebration laboratory in the nation of origin.

Marijuana Company Everyday reached out for comment to all the Canadian firms that presently export to Germany.

Canadian producers Aurora Cannabis in Alberta and Cronos Group and Wayland Group in Ontario have been clear they do not irradiate their flower items that currently are getting sold in the German market place.

A spokesperson for Ontario-primarily based Canopy Development told MJBizDaily that “the course of action is not generally applied, but if it ever have been, it would be carried out in Canada. It could be performed in-home by Canopy or by a third celebration.”

As for British Columbia-headquartered Tilray, a spokesperson stated:

“All shipments of health-related cannabis as completed goods from Tilray’s Canadian facility and (future) shipments from Tilray’s EU campus in Portugal, to be sold in pharmacies as Tilray items, are irradiated by a certified GMP-certified third celebration.”

A previous Tilray shipment from Portugal to Germany was carried out in bulk but not irradiated in Portugal. The importer, Cologne’s Cannamedical, confirmed it will not irradiate the item prior to it is distributed.

Alfredo Pascual can be reached at [email protected]


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