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Supply and wholesaling of medicinal cannabis products (MCP)

Version 1.0, April 2021
13 April 2021
Download Supply and wholesaling of medicinal cannabis products (MCP)


Wholesale supply of any finished therapeutic goods that are not included in the Australian Register of Therapeutic Goods, including medicinal cannabis products (MCP), is not consistent with the therapeutic goods regulatory framework.

A person who supplies unregistered MCP by wholesale is likely to contravene the Therapeutic Goods Act 1989. Those contraventions may result in regulatory action under the TG Act, and can also have implications for licences issued under the Narcotic Drugs Act 1967, Customs (Prohibited Imports) Regulations 1956 and state and territory legislation.

The legal requirements that apply when supplying MCP depend on whether the supplier is the 'sponsor' of the goods. Both sponsors and persons who are not the sponsor are prohibited from supplying unregistered MCP by wholesale.

  • Summary
  • Starting materials for use in manufacturing MCP
  • Importing and manufacturing finished MCP
  • Loss of 'direct control' through a distribution agreement
  • Maintaining 'Direct Control' with distribution agreement in place
  • Supply of finished MCP by a sponsor
  • Supply of finished MCP by persons other than the sponsor

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