Dear SAHPRA Registrar and Licensing Division,

I hope this message finds you well.

I am writing to lodge a formal complaint and request urgent clarification regarding a document currently circulating in the public domain which purports to be an official SAHPRA-issued cannabis cultivation license. The license in question bears the following characteristics:

License Number: 42069

Date of Issue: 1 April 2024

Purpose: Authorisation to "Cultivate Cannabis in terms of applicable laws"

Logos/Marks: "Approved by SAHPRA & DTIC" with a stylised cannabis leaf emblem

A copy of the image is attached for your reference.

This document does not conform to any known SAHPRA-issued license format under the Medicines and Related Substances Act 101 of 1965, Section 22C(1)(b). Specifically, it lacks:

Reference to statutory authority under the Medicines Act

Any official SAHPRA letterhead, registrar signature, or licensing conditions

The detailed regulatory structure expected of medical cannabis cultivation licenses

Furthermore, the inclusion of DTIC as an approving entity raises serious legal concerns, as to the best of our knowledge, the DTIC does not hold statutory authority to approve or co-approve medical cannabis licenses under the current legal framework.

This image appears to be a mock certificate or promotional rendering that may mislead the public or stakeholders into believing it is an official SAHPRA approval. This kind of misrepresentation—intentional or otherwise—undermines the integrity of SAHPRA's regulatory mandate and could pose risks to patients, practitioners, and the public.

We respectfully request that SAHPRA:

1. Confirm whether License No. 42069 exists and whether this format is sanctioned;

2. Issue a public clarification or advisory regarding the use of such stylised "licenses";

3. Investigate any potential regulatory breaches or misrepresentation by the entity responsible for circulating this image;

4. Take appropriate action to safeguard the integrity of SAHPRA's licensing framework.

We remain committed to regulatory compliance and to the advancement of a lawful and ethically governed cannabis sector in South Africa. Your urgent attention and guidance on this matter will be greatly appreciated.

Charl Botha B.Proc (S.A)

Legal Process Strategist | Regulatory Framework Architect | Strategic Compliance Advisor and Co-Founder

H3 Legal Solutions (Pty) Ltd

📱 Mobile: +27 78 213 2947

📧 Email: charl@h3legal.co.za

🌐 Website: www.h3legal.co.za