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As we are mapping our NAPCS Canada to CPC after the legalization of cannabis for non-medical (recreational) use in Canada, we are faced with the decision to know which CPC codes would cover cannabis for recreational use, if that is possible. Is there an official position on recreational cannabis being out of scope (because it is an illegal substance) for CPC? Put another way: who can confirm to me if only cannabis for medical/research purposes and industrial hemp products are covered in CPC?

Dear Franklin, We are of the opinion that cannabis for non-medical (recreational) use belongs to class 01930 Plants and parts of plants used primarily in perfumery, in pharmacy, or for insecticidal, fungicidal or similar purposes under CPC Ver. 2.1, which is defined by HS 2007 headings 1211 and 1302.11. Since the CPC “classifies products based on the physical properties and the intrinsic nature of the products as well as on the principle of industrial origin”(CPC Ver. 2.1, para. 7), we consider cannabis as a plant “used in perfumery, pharmacy, or for insecticidal, fungicidal or similar purposes” (CPC group 019). This opinion is corroborated in Eurostat’s Handbook on the compilation of statistics on illegal economic activities in national accounts and balance of payments (https://ec.europa.eu/eurostat/documents/3859598/8714610/KS-05-17-202-EN-N.pdf/eaf638df-17dc-47a1-9ab7-fe68476100ec), which puts cannabis plants in CPA 2008 (European version of CPC) product category 01.28.30: “plants used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purposes”. And the correspondence between CPA 2018 and CPC Version 2 (https://ec.europa.eu/eurostat/web/cpa-2008) points back to CPC subclass 01930. Please also note that according to the principles, definitions and classification rules of the CPC as mentioned above, the legality or illegality of the product or of its use is not a factor in determining the scope of CPC. Similarly, class 01930 of CPC Ver. 2.1 includes cannabis for medical and recreational use. Our apologies again for the delayed reply.