Manitoba Dispensary Laws

Published January 31, 2018 - Last updated January 25, 2021
 
The province of Manitoba’s Liquor, Gaming and Cannabis Control Act gives authority to the Liquor, Gaming and Cannabis Authority (LGCA) to regulate cannabis and issue retail licenses to private cannabis stores. Manitoba has a hybrid public/private model for non-medical legal cannabis. Licensed private retailers, selected through a competitive request for proposal bidding processes, are allowed to operate cannabis retail locations in Manitoba. Cannabis products in the province are supplied to all stores by Manitoba Liquor and Lotteries (MBLL).
 
Starting June 2020, the province opened the market to new retailers. It accepts applications for both Age-Restricted and Controlled-Access Store licenses. The latter will allow retailers to sell cannabis in stores that sell other products, albeit with certain conditions.
 
Below are some answers to Manitoba dispensary laws questions regarding retail cannabis sales and the cannabis retail permitting process in Manitoba. This page will be updated frequently as more information is released, but this page is informational only and should not be considered legal advice. Be sure to check out our Canada cannabis retail laws page for information about regulations in other provinces.

FAQ

Cannabis Retail Licensing & Sales

Remaining compliant with federal and provincial regulations is critical. Learn the details of Manitoba’s cannabis retail laws.

What kind of retail locations are authorized?

Cannabis retail locations will be run by private operators who are licensed through the Liquor, Gaming and Cannabis Authority (LGCA). Distribution of wholesale cannabis will be government-run through Manitoba Liquor and Lotteries (MBLL).

Starting June 1, 2020, there will be 2 types of cannabis retail store licenses available:

Age-Restricted Stores must prohibit anyone under the age of 19 from entering the store.

Controlled Access Stores may sell cannabis inside a retail store that sells other products, so long as cannabis is not visible, and the age of cannabis customers is verified before purchase.

How Do I Apply for a Cannabis Retail License in Manitoba?

Beginning June 1, 2020, new applications for cannabis retail licenses will be accepted. This is a 2-part process that requires you to apply with the MBLL and LGCA.

First, download the Cannabis Retailer Application Toolkit from the MBLL's Become a Cannabis Retailer website. Once you complete this application and enter into the required Cannabis Store Retailer Agreement with the MLBB, you will receive an application from the LGCA, which will conduct background checks before issuing a retail license.

What are the purchase limits for retail customers?

Under Canada’s Cannabis Act, public possession of more than 30 grams of dried cannabis or its equivalent will be unlawful.

Cannabis stores in Manitoba must therefore enforce a daily purchase limit of 30 grams of dried cannabis or:

  • 70 grams of liquid product
  • 15 grams of edible product
  • 0.25 grams of concentrate
  • 1 cannabis plant seed
  • 5 grams of fresh cannabis

What is the minimum age of purchase for retail cannabis?

Manitoba has set the minimum age for cannabis purchase and consumption at 19.

Cannabis Tracking and Reporting

Cannabis tracking and reporting helps the government prevent diversion into the black market. Get the facts here.

What is required of cannabis retailers with regard to tracking and reporting?

To meet federal and provincial regulations, including those outlined in the Cannabis Act, Manitoba cannabis retailers must submit 2 monthly reports.

The federal report for Health Canada's Cannabis Tracking System is submitted by retailers to the MBLL.

Provincial inventory reports must be submitted to the LGCA via their web portal. These reports include inventory purchases, returns, transfers, sales, recalls, disposal, and inventory on hand.

A dedicated cannabis POS & Inventory Management system will simplify the process by tracking inventory and generating these compliance reports in the proper format.

Cannabis Marketing Laws in Manitoba

I am a cannabis retail owner in Manitoba. How can I advertise my business?

It's important to know what the law says about cannabis advertising and marketing. The Cannabis Act specifically outlines five main restrictions, including:

  • No testimonials or personal endorsements;
  • Advertisements cannot appeal to minors or be located anywhere with a young audience;
  • Cannot include pricing information unless the advertisement is at the point of sale;
  • No depictions of a person, character, or animal (whether real or fiction) to promote cannabis;
  • Cannabis advertising cannot make cannabis look cool, glamorous, or exciting.

Are there any Manitoba-specific cannabis marketing laws?

Manitoba relies on federal guidelines for advertising and marketing of cannabis.

Can I advertise my Manitoba cannabis business online?

Cannabis brands, accessories, or services cannot be advertised in any publication or broadcast originated outside of Canada. While the law isn't totally clear, this could limit a dispensary from many paid advertising options online.

Google Adwords is another gray area. A cannabis brand could use hyper-targeting to limit the age range of their ads and only target users in Canada. Regardless, Google still has a strict no-cannabis policy even in legal countries like Canada.

Before investing time and money into a digital advertising or marketing strategy for your cannabis company, consult with a lawyer first.

Can a Manitoba cannabis retailer or brand give away free product?

No, Canada's federal cannabis laws are very clear that no free product can be given out.

Cannabis Marketing Laws in Alberta

What federal cannabis marketing laws affect cannabis companies and dispensaries in AB?

The Cannabis Act includes strict marketing and advertising laws. Specifically, it outlines five main restrictions when it comes to marketing cannabis products, accessories, and services. They include:

  • No testimonials or personal endorsements (from clients, customers, employees, or celebrities);
  • Cannot appeal to children or minors or advertise anywhere with a young audience;
  • Cannot include any pricing information except for at the point of sale;
  • Cannot use the depiction of a person, character, or animal (whether real or fiction) to promote cannabis;
  • No cannabis advertising or marketing can make cannabis look cool, glamorous, or exciting.

Can cannabis companies in Alberta use paid ads such as Google Adwords?

The law makes it clear that no cannabis, cannabis accessory, or cannabis service can be advertised in any publication or broadcast that originates outside of Canada. This is likely to limit a dispensary from many paid advertising opportunities on sites that reach an audience outside of the country. And since no testimonials are allowed, review-based sites like Yelp are a gray area.

When it comes to paid ads on Google Adwords, a cannabis brand could limit the age range of their ads to 19 years and older and only target users in Canada to work around federal marketing laws. But this doesn’t change the fact that Google has a strict no-cannabis policy, even in legal countries. A cannabis brand can try to get ads through this filter, but multiple disapproved ads can get your site URL banned for good.A better option is to focus on organic search optimizations.

Can I give away free product at my cannabis dispensary in AB?

No, the Cannabis Act is very clear that no free product can be given out.

Are there any province-specific cannabis marketing laws in AB?

Yes. Alberta established additional advertising laws in concert with federal guidelines. One major difference is that the AGLC allows a cannabis licensee and manufacturer of non-cannabis products and accessories to jointly advertise, so long as the advertisement complies with all other cannabis advertising laws.

The province also goes into more detail than the federal law when it comes to business-to-business advertising. Specifically, a cannabis supplier cannot direct advertising to a particular licensee or chain of licensees. But the AGLC does permit “co-operative advertising” in which an advertisement includes the specific mention of a cannabis supplier/representative, so long as the licensee covers all costs pertaining to the advertising.

The AGLC also requires every licensee to keep records of advertising for a period of two years, which the AGLC can request at any time.

ron-segev

Ron Segev

Cannabis Business Lawyer & Founding Partner, Segev LLP

Legally reviewed by

Ron Segev

Ron Segev is the founding partner of Segev LLP. A practical-minded business lawyer with expertise in the cannabis industry, he represents cultivators, dispensaries, CBD extractors, oil extractors, food processors, media and marketing companies, consultancies, and other businesses in the legal cannabis market.

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