December 8, 2025 · Good Production Practices
Good Production Practices (GPP) for Cannabis in Canada
By Mussarat Fatima

For every federally licensed cannabis producer in Canada, Good Production Practices, or GPP, are not optional. They are the legal foundation of your licence. Set out in Part 5 of the Cannabis Regulations, GPP requirements govern how cannabis is produced, packaged, labelled, stored, distributed, sampled, tested and sold. Get them right and you protect your licence, your customers and your path to market. Get them wrong and you risk inspection findings, product holds, recalls or, in serious cases, the suspension or revocation of your licence.
Yet GPP is still widely misunderstood. Many new applicants treat it as a paperwork exercise, and many established producers let their systems drift after licensing. This guide explains what GPP actually requires, how Health Canada enforces it, where producers most often slip, and what the 2025 streamlining amendments changed. It is written for licence holders, applicants, Quality Assurance Persons and operations leaders who want a clear, current and defensible picture of their obligations.
Executive Summary
Good Production Practices are the quality and safety rules that every holder of a federal cannabis licence must follow under Part 5 of the Cannabis Regulations. They cover the people, premises, equipment, processes and records used to produce cannabis. Here is what the rest of this guide covers.
- GPP is required by law for federal licence holders, with the specific requirements that apply depending on your licence class and the class of cannabis you handle.
- The main requirement areas are standard operating procedures, sanitation, pest control inputs, buildings and equipment, filtration and ventilation, water and lighting, storage and distribution, quality assurance, and testing.
- A Quality Assurance Person (QAP) must approve cannabis before it is made available for sale and is central to GPP compliance.
- GPP is the Canadian baseline. Exporting to the European Union and similar markets requires the higher EU-GMP standard.
- The March 2025 streamlining amendments (SOR/2025-43) eased some requirements, including allowing more alternate QAPs and raising micro-class production limits.
What Are Good Production Practices (GPP)?
Good Production Practices are the production and quality requirements in Part 5 of the Cannabis Regulations (SOR/2018-144) that licence holders must meet so cannabis is consistently produced to a quality appropriate for human use. In plain terms, GPP is how Health Canada makes sure the cannabis sold to Canadians is clean, accurately labelled and free of harmful contaminants.
Why it matters: GPP compliance is a condition of holding a licence, not a nice to have. Health Canada assesses it before granting a licence and verifies it through inspections afterward. Weak GPP systems are among the most common reasons producers receive inspection observations and enforcement action.
What to do: Treat GPP as a living quality system. Document your procedures, train your staff against them, keep records that prove what you did, and review the system regularly so it keeps pace with your operation and with regulatory change.
The role of Health Canada and the GPP Guide
Health Canada administers and enforces the Cannabis Act and the Cannabis Regulations. Its Good Production Practices Guide for Cannabis explains how the department interprets Part 5 and what licence holders need to demonstrate. Appendices A and B of that guide are especially useful, because they map which GPP requirements apply to each licence class and class of cannabis.
Not every requirement applies to every licence. For example, a holder of a licence for sale for medical purposes that does not handle the physical product is not expected to run a full sanitation program in the same way a processor would. Knowing exactly which GPP elements apply to your licence is the first step to building a system that is complete without being wasteful.
The Core GPP Requirements Under Part 5
Part 5 groups GPP into requirements covering procedures, inputs, premises, equipment, quality assurance and testing. The table below summarises the main requirement areas and what each one asks of a licence holder.
| GPP requirement area | What it covers |
|---|---|
| Standard operating procedures (SOPs) | Written, current procedures for every activity that can affect quality, from receiving to destruction. |
| Sanitation program | A documented program for cleaning premises and equipment, personal hygiene, and handling of contaminated material and waste. |
| Pest control products, sanitizers and inputs | Controls so only suitable products are used, applied correctly and recorded, to avoid contaminating cannabis. |
| Building or part of a building | Premises designed and maintained to prevent contamination, allow cleaning and separate incompatible activities. |
| Filtration, ventilation, water and lighting | Systems that control air quality and odour, supply clean water and provide lighting suitable for the activity. |
| Equipment | Equipment that is suitable, accessible for cleaning, maintained and calibrated where measurements matter. |
| Storage and distribution | Conditions that protect cannabis from contamination, deterioration and mix-ups through storage and transport. |
| Quality assurance and the QAP | A Quality Assurance Person who approves product for sale and oversees that GPP and testing requirements are met. |
| Testing | Testing for phytocannabinoids such as THC and CBD and for contaminants, plus mandatory pesticide testing, using validated methods. |
Standard operating procedures
SOPs are the written backbone of GPP. Health Canada expects licence holders to have current, approved procedures for every activity that can affect the quality of cannabis, and to actually follow them. Inspectors frequently ask to see an SOP, then watch whether staff perform the task the way the SOP describes. A clean binder of procedures that nobody follows is a finding waiting to happen.
Good SOPs are specific, version controlled and accessible to the people who use them. They should cover receiving, production, sanitation, equipment use and maintenance, storage, distribution, recall, destruction and record keeping. Each SOP should make clear who is responsible, what records are generated and how often it is reviewed.
Sanitation, premises and contamination control
Contamination control is the heart of GPP. The regulations require premises and equipment that can be effectively cleaned, a documented sanitation program, personal hygiene controls for staff, and systems for water, air filtration and ventilation that protect the product. Producers must also control how pest control products, sanitizers and agronomic inputs are selected and applied, because the wrong input can introduce a residue that fails testing.
- Clean and sanitize on a defined schedule and record each cleaning.
- Keep clean and dirty equipment separated to prevent recontamination.
- Use only pest control products that are acceptable for use on cannabis, and record every application.
- Maintain and verify filtration and ventilation systems, and protect water supplies from backflow and contamination.
- Calibrate measuring equipment so that readings can be trusted.
Testing requirements
Before cannabis can be sold, it must meet the testing requirements in Part 5 and the related provisions of the regulations. This includes testing each lot or batch for phytocannabinoid content, so labels are accurate, and testing for contaminants such as microbial and chemical impurities. Health Canada also requires mandatory testing for pesticide active ingredients against a published list of compounds and limits. Testing must use validated methods, and an analytical testing licence is needed to perform the regulated tests.
The Quality Assurance Person (QAP)
The Quality Assurance Person is the individual a licence holder relies on to assure the quality of cannabis before it is made available for sale. Under the Cannabis Regulations, a processing licence holder must retain a QAP who has the training, experience and technical knowledge of the Part 5 and Part 6 requirements that apply to the activities being conducted.
Among other duties, the QAP ensures that the results of required tests, including the contaminant and pesticide testing, are reviewed and assessed against specifications before product is released. The QAP is also security cleared by Health Canada. In practice, the QAP is the person whose signature stands behind every batch, which is why their independence and authority inside the company matter.
Since March 2025, the regulations allow a processing licence holder to designate one or more alternate Quality Assurance Persons who are qualified to replace the QAP. This change, introduced through the streamlining amendments, gives producers more flexibility to cover absences and delegate specific duties without leaving a gap in quality oversight.
GPP vs GMP and EU-GMP
GPP and Good Manufacturing Practices (GMP) both aim at product quality and safety, but they are not the same standard. GPP is the mandatory Canadian baseline for domestic cannabis. GMP, and specifically EU-GMP, is the more demanding pharmaceutical grade standard required to export cannabis into the European Union and several other regulated markets.
| GPP (Canadian baseline) | GMP / EU-GMP (export standard) |
|---|---|
| Mandatory for Canadian federal cannabis licence holders under Part 5. | Not required to operate in Canada, but required to export cannabis to the EU and similar markets. |
| Focuses on a controlled, clean production environment and accurate, safe product. | Adds pharmaceutical grade controls such as deeper validation, qualification and batch documentation. |
| Enforced by Health Canada through licensing and inspection. | Assessed against EU-GMP requirements, often involving an EU competent authority and a Qualified Person. |
| A condition of your Canadian licence. | A commercial and regulatory key to international medical cannabis markets. |
| Sets the foundation for quality. | Builds on that foundation to meet importing-country expectations. |
For producers eyeing Germany and other European markets, EU-GMP certification is the gateway. Canada has become a leading supplier of medical cannabis to Germany, and that access depends on meeting EU-GMP, not GPP alone. Building strong GPP systems first makes the later step up to EU-GMP far less painful.
2025 Regulatory Update: Streamlining of Requirements
On 12 March 2025, the Regulations Amending Certain Regulations Concerning Cannabis (Streamlining of Requirements), known as SOR/2025-43, came into force. The amendments reduce regulatory burden across several priority areas while keeping the public health and safety goals of the Cannabis Act intact.
- Producers may now designate one or more alternate Quality Assurance Persons, easing coverage and delegation.
- Production thresholds for micro-class licences were increased, giving small cultivators and processors more room to operate.
- Several requirements were simplified to cut duplication and paperwork.
Health Canada has said it will update the Good Production Practices Guide to reflect these changes. Until then, read the guide alongside the amended regulations, and confirm any requirement that affects a release decision against the current regulatory text.
GPP Compliance Checklist
- Confirm which Part 5 requirements apply to your licence class and cannabis class using Appendices A and B of the GPP Guide.
- Maintain current, approved SOPs for every quality-affecting activity, and train staff against them.
- Run and record a documented sanitation program covering premises, equipment and personal hygiene.
- Control and record the use of pest control products, sanitizers and agronomic inputs.
- Maintain, qualify and calibrate equipment, and keep filtration, ventilation and water systems verified.
- Store and distribute cannabis under conditions that prevent contamination, deterioration and mix-ups.
- Test each lot or batch for phytocannabinoids and contaminants, and complete mandatory pesticide testing using validated methods.
- Retain a qualified, security-cleared QAP, and designate alternate QAPs to cover absences.
- Keep complete, contemporaneous records that prove each requirement was met.
- Review your quality system on a schedule and after any significant change or deviation.
Common GPP Mistakes and Inspection Findings
Most GPP findings are not exotic. They come from gaps between what a producer wrote down and what it actually does. A regular internal audit catches these before Health Canada does. The issues below appear repeatedly in inspections and consulting gap assessments.
- SOPs that are out of date, missing or not followed in practice.
- Incomplete or missing records, so the producer cannot prove a task was done.
- Releasing product before testing is complete, or without proper QAP sign-off.
- Sanitation programs that exist on paper but are not performed or recorded on schedule.
- Using pest control products or inputs that are not acceptable for cannabis, leading to failed pesticide tests.
- Equipment that is not calibrated, so measurements cannot be trusted.
- A QAP who lacks authority or is too stretched to provide real oversight.
- Weak change control, so improvements to the facility quietly break the validated process.
The fix for most of these is a disciplined corrective and preventive action (CAPA) process. When a gap is found, document it, investigate the root cause, correct the immediate issue, and put a preventive measure in place so it does not recur. A producer that can show a working CAPA system tells inspectors that its quality culture is real, not cosmetic.
Frequently Asked Questions
Is GPP mandatory for every cannabis licence in Canada?
Yes. GPP is set out in Part 5 of the Cannabis Regulations and applies to holders of federal cannabis licences. The specific requirements that apply depend on your licence class and the class of cannabis you handle, which Appendices A and B of Health Canada's GPP Guide set out. GPP is a continuing condition of your licence, not a one-time step.
What is the difference between GPP and GMP?
GPP is the mandatory Canadian standard for producing cannabis domestically. GMP, and in particular EU-GMP, is a higher pharmaceutical grade standard required to export cannabis to the European Union and similar markets. GPP is required to operate in Canada, while EU-GMP is required to reach many international medical markets. Strong GPP systems make EU-GMP certification easier to achieve later.
Who is responsible for GPP compliance?
The licence holder is ultimately responsible, but the Quality Assurance Person plays the central role. A processing licence holder must retain a QAP with the training, experience and technical knowledge to assure quality, and the QAP approves cannabis before it can be made available for sale. Since March 2025, producers can also designate alternate QAPs.
What does Health Canada look at during a GPP inspection?
Inspectors review your SOPs, records, sanitation program, equipment maintenance and calibration, storage and distribution controls, testing results and QAP oversight. They commonly compare what your procedures say against what staff actually do. Gaps between documentation and practice, and missing records, are among the most frequent findings.
Does GPP require product testing?
Yes. Before sale, cannabis must be tested for phytocannabinoid content and for contaminants, and mandatory pesticide testing must be completed against Health Canada's published list and limits. Testing must use validated methods, and the QAP reviews the results against specifications before releasing product. Regulated testing is performed under an analytical testing licence.
What changed for GPP in 2025?
The streamlining amendments (SOR/2025-43), in force 12 March 2025, reduced regulatory burden in several areas. For quality systems, the most relevant changes let producers designate one or more alternate QAPs and raised production thresholds for micro-class licences. Health Canada has indicated it will update the GPP Guide to reflect the amendments.
How MFLRC Can Help
Building and maintaining a GPP system that survives a Health Canada inspection takes regulatory knowledge and practical operations experience. MF License and Regulatory Consultants (MFLRC) works with cultivators, processors and sellers across Canada to make GPP compliance straightforward and defensible.
- Gap assessments that compare your operation against Part 5 and the GPP Guide and prioritise what to fix.
- SOP development and quality system builds tailored to your licence class and cannabis class.
- QAP services and support, including coverage, mentoring and review of release decisions.
- Inspection readiness and mock audits so you meet Health Canada with confidence.
- Licensing and amendment support, plus import and export guidance for producers pursuing EU-GMP.
- Validation and qualification support for premises, equipment and processes.
Whether you are preparing your first application or tightening an established quality system, MFLRC can help you close the gaps before an inspector finds them. Book a consultation and we will map a clear, practical path to GPP compliance.
Conclusion
Good Production Practices are the foundation of a compliant cannabis operation in Canada. They are mandatory under Part 5 of the Cannabis Regulations, they are enforced through inspection, and they rest on the shoulders of a capable Quality Assurance Person. The producers who treat GPP as a living quality system, rather than a licensing formality, are the ones who avoid recalls, pass inspections and earn the trust that opens domestic and international markets.
The 2025 streamlining amendments have eased some of the burden, but the core expectation is unchanged. Document what you do, do what you document, and prove it with records. Get that right, and GPP stops being a hurdle and becomes a competitive advantage.
Sources and References
- Cannabis Regulations (SOR/2018-144), Part 5, Justice Laws Website
- Good Production Practices Guide for Cannabis, Health Canada
- Mandatory cannabis testing for pesticide active ingredients, Health Canada
- Regulations Amending Certain Regulations Concerning Cannabis (Streamlining of Requirements), SOR/2025-43, Canada Gazette Part II
- Summary of changes following the streamlining of regulations, Health Canada
- Cannabis licensing summary, Health Canada
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