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NL: Cannabis supply chain to be operational in 1st quarter of 2023?

On September 23, 2020, the government published a document with questions and answers that were asked during an information meeting on August 27 with (possible) cultivation municipalities.

The Dutch government is undertaking a challenging project, as it expects that 10 growers will be selected by the beginning of 2021. This basically means that these growers should meet the government’s criteria and that municipalities agree on the building of the facility, and that odor, safety and infrastructure impact are positively addressed.

A municipality has 6 weeks from the date it receives a request from the government to give advice whether a grower is permitted to build and establish itself locally, including an opinion on safety and public order as a result of the establishment. There is a possibility for a municipality to ask for more time and most probably will, so that the recommendations are recommended to the government in early 2021. The main challenge stems from the fact that many processes for building permit application processes have yet to start, giving municipalities a rather short time to approve the different projects.

Eric Uleman, director of CannNext Netherlands, a legal grower and consultancy firm in the Netherlands with a government research permit for growing medicinal cannabis, sees a heavy task for municipalities: “It is striking that the cultivation municipalities have to do a lot of work themselves without financial support from the government to review and advice on the permits from growers,” he observes. “In addition, during the experiment cultivation, municipalities will neither receive any financial contribution. The government indicated that the information exchange between the government, cultivation municipalities and coffee shop municipalities will only start after the 10 cultivation municipalities have been designated, therefore in Q1 2021.”

After obtaining a permit, most parties will be busy with construction and inspections for 9 months. Likely, the facilities probably cannot be built at the same time due to overlap in suppliers. On the government and municipality side, this is a new industry and municipalities still have little knowledge of inspection of cultivation locations and the government has very limited capacity. The compliance and inspection requirements are extremely high which requires long and extensive compliance audits. “This term is therefore still optimistic,” says Eric Uleman. “Moreover, we are also dealing with the Covid-19 factor.” Incidentally, the locations specified in the application may no longer be changed. So, if the intended location cannot take place due to a negative advice from the municipality, this end is exercise for the grower. Construction will eventually possibly be completed for many growers around the 4th Quarter of 2021.

Given the complexity and novelty of large-scale cannabis cultivation, licensed growers will have to be able to grow the desired high-quality cannabis in a relatively short time. “It is striking that no attention is paid to the necessary preparations for cultivation. Where are growers to get the tens of thousands of cuttings from to start their cultivation,” Eric observes. “How can they prepare so that they start with a solid plant once allowed?  After all, cultivation is illegal and suddenly all facilities must be filled with high-quality plants that are wanted by the consumer. In quantities that have never been legally grown here in the Netherlands.” Eric Uleman expects most growers to be ready to deliver around the 4th quarter of 2022.

Another issue to address is the implementation of a national track-and-trace system for the whole cannabis supply chain, which in itself may take at least 6 months.

Until 2022 or 2023, municipalities and companies will have to invest substantially before the first cannabis can be sold. Hopefully, the preparation time will be used well to ensure that production at the time of delivery matches well in terms of price and product with the wishes of the consumer.

It is not surprising that all of Europe is watching the cannabis trial. It is a tough process in a multi-billion market with major financial interests.

Source: rijksoverheid.nl