The primacy of fabrication
This month, CCI attended a cannabis diploma at Corporación Colombia Internacional, a non-profit with experience in Colombian agriculture, to understand the best strategies to overcome challenges.
By: Juliana Salazar
With perfect growing conditions, 44% of the International Narcotic’s Control Board’s quota for authorized world use and the region’s most developed medicinal marijuana regulations, it’s little wonder that local and international firms are thirsty for Colombian cannabis licenses. However, cross-compliance requirements between the four types of licenses (psychoactive cannabis cultivation, non-psychoactive cannabis cultivation, seeds and fabrication) means that companies need to think clearly about their strategy for license acquisition.
In July, a three-day training course run by Corporación Colombia Internacional, a local non-profit, the potential pitfalls were made clear to attendees. It’s relatively well known that the export of dry flowers is not permitted under Colombian law, no matter how much the Canadian recreational market may cry out for Cripy. What is less known is that cultivation licenses can only be awarded to companies that already hold fabrication licenses or who have an assured buyer. You can’t set up a cultivation project and then try to sell to a fabrication plant after the harvest.
What is less known is that cultivation licenses can only be awarded to companies that already hold fabrication licenses or who have an assured buyer. You can’t set up a cultivation project and then try to sell to a fabrication plant after the harvest.
For vertically integrated companies, this shouldn’t be a problem. Experienced producers suggest the best way to proceed is to request several licenses at once but with a prime focus on fabrication. Once you have that license from the Ministry of Health, the certificate is enough proof to determine the company will produce cannabis extracts, which allows it to request cultivation licenses. If, on the other hand, companies are interested in selling their flower harvest to a Colombian fabricator, they are required to submit a proof of the contract with the fabricator. During the licensing process companies also have to decide on their preferred modality, and specific requirements apply for fabrication licenses in the Ministry of Health. Vertically integrated and fabrication companies may request the license for exports, national use or scientific research, in most cases all at the same time to avoid repeating the process. Exports licenses require an exports plan and a prospect of purchase with a medicinal cannabis clause, while scientific research purposes require a detailed plan of research and documentation from ColCiencias.
Lastly, experienced entrepreneurs and experts in the cannabis sector suggest companies to provide all the required paperwork, including a current and future statement of income and an employment contract with an agronomic engineer, as well as being patient since licenses are taking around 3 months to be issued and the Ministry of Heath tends to work quicker than the Ministry of Justice.