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 (the Register), 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 (TG Act). 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 (ND Act), Customs (Prohibited Imports) Regulations 1956 (CPI Regulations) 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.