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Rwanda: 10 Take-Out Points From Kigali’s New Medical Cannabis Framework

Rwanda has given the green light to a new medical marijuana framework. Ministerial Order 14  was published on 28 June 2021, giving the go-ahead to the growing, processing and medical use of cannabis in the country.


Top 10 Take-Outs on Rwanda’s New Cannabis Framework by Collins Mwai, New Times, Kigali

  1. Licensing for operations

Individuals and firms interested in any of the processes relating to cultivation, distribution and use of cannabis will be required to apply and receive prerequisite licensing by competent authorities and must only undertake operations at places of business of those establishments or at such other places as may be approved by the competent authority.

According to the law, eligible persons for the activities related to cannabis provided for by the Order are investors or any other persons committed to performing any activity of cultivation, processing, importation, export and use of cannabis and cannabis products, for medical or research purposes.


  1. Not for recreational purposes

The new order does not in any way have provisions for cultivation, processing or use of cannabis for recreational purposes in the country.

Persons found to use, cultivate or sell marijuana outside the set order will be considered to be handling narcotics which is punishable by law.


  1. Medical use only

The new ministerial order has provisions for medical use of cannabis and cannabis products in the country but noted that it can only be made on condition that they are prescribed by a specialist medical doctor.

For this purpose, the order specifies that a specialised medical doctor is one whom the Ministry of Health has given, in writing, the authority to prescribe cannabis and cannabis products for use by a patient.


  1. Types of licenses

According to the ministerial order, the cannabis value chain will have specific roles with up to eight licenses and permits required.

Types of licenses and certification include; cultivation license; import permit for seeds, genetic materials and other planting material; export permit for seeds, genetic materials and other planting materials.

Other licenses and permits include; cannabis and cannabis products processing license; cannabis and cannabis products import permit; cannabis and cannabis product export permit.

Other certifications and permits are finished cannabis and cannabis products registration certificate and research license.

The licenses provided will have a validity of a period of a renewable 5 years renewable.


  1. Security checklist

According to the new order, operators of activities related to cannabis and cannabis products will be required to provide a security plan to the Rwanda National Police for approval.

The said security plan will go to prove that the operator of activities related to cannabis and cannabis products will take appropriate measures and put up security installations.

Among the elements of the security plan include; having double-layered fencing; ensuring patrol control in between the two layers of the fence; hiring a licensed private security service company that must be securing outside 24 hours per day, seven days a week.

The facility will also be expected to have security lighting, video surveillance cameras, watchtowers, intrusion detection, system and communication control room.

The firms will also be required to prove that the staff and any other persons authorized to enter the facility wear personnel protective equipment without pockets that are kept in a designated area.


  1. Security of cannabis farm

The security of the cannabis plantation and processing facility of cannabis and cannabis products is provided in a coordinated framework with three layers, namely the inner, middle and outer layers.

The inner layer security is the responsibility of the licensee and the licensed private security service provider he or she employs. The middle layer and outer layer security is the responsibility of the Rwanda National Police.

The key security stakeholders include; an operator of activities related to cannabis and cannabis products, a private security service company, the Rwanda National Police, the Rwanda Defence Force, public institutions in charge of issuing licenses, and decentralized administrative entities ensure that security requirements are respected.


  1. Suspension of a license

If and when a license holder is found to be non-compliant with the provisions stipulated in the order, the competent authority will be at liberty to suspend the license.

An operator whose license has been suspended may appeal to the competent authority within a period of one month from the date of notification of the decision of suspension of the license.


  1. Administrative fines

Operators of activities related to cannabis and cannabis products who are found in violation of the license conditions could also be subject to fines imposed by authority of not less than Rwf1,000,000 and not more than Rwf50,000,000 that will be deposited on the account of the competent authority.

In case of repeat offence the administrative fine could be doubled.


  1. Traceability and reporting

Firms and individuals of activities related to cannabis and cannabis products will also be expected to document the entire supply and value chain processes of cannabis and cannabis products and make them available to authorities when requested.

The licensee will be required to report to the competent authority in accordance with the requirements set up.


  1. Transport

Transportation of cannabis products will only be done by an operator of activities related to cannabis and cannabis products or a licensed transport company authorized by the Rwanda National Police.

The product will be required to be transported in a manner ensuring that quality is maintained and it is traceable by a cargo tracking system throughout transportation.

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