Documentation and GPP: What Health Canada's 2024 to 2025 Cannabis Inspection Data Reveals

Every year Health Canada publishes what it found inside licensed cannabis facilities, and every year the same handful of problems accounts for most of the non-compliant reports. They are not exotic new rules. They are documentation, assigned responsibilities, and good production practices. The reports read like the same inspection written over and over, which is the clearest possible signal that these failures are preventable with disciplined systems rather than new spending.

In its most recent cannabis inspection data summary, covering the 2024 to 2025 fiscal year, Health Canada conducted 889 inspections and issued 37 non-compliant inspection reports to licence holders. The examples the agency lists first are the same three that recur across the individual results: non-compliances related to good production practices, unsatisfactory retention of documents and information, and not conducting activities as per assigned responsibilities.

This guide breaks down what the data shows, why the same findings keep appearing, and the practical steps a licence holder can take now to stay off next year's list.

Executive Summary

• The data. In fiscal year 2024 to 2025, Health Canada conducted 889 inspections under the Cannabis Act and its regulations, including 197 inspections of personal and designated production, and issued 37 non-compliant inspection reports to licence holders.
• The three recurring findings. Health Canada lists them first: non-compliances related to good production practices (GPP), unsatisfactory retention of documents and information, and not conducting activities as per assigned responsibilities.
• The pattern. These are documentation and execution failures, not novel requirements, so they recur year over year and are preventable with a working quality system.
• The escalation risk. Health Canada backs inspections with enforcement, including corrective action demands, seizure and detention, stop sales, warning letters, and licence suspension or revocation.
• What to do. Treat documentation, the quality assurance person's authority, and GPP as day-to-day systems that can be evidenced on demand, not as a binder produced for inspection day.

What the 2024 to 2025 Inspection Data Shows

What happened? Health Canada inspected licensed cannabis operations across the country and reported the outcomes in its cannabis inspection data summary for 2024 to 2025. The headline numbers set the scene, and the individual results tell you exactly what inspectors are finding.

The volume matters less than the consistency. When the same categories of finding appear across facilities of different sizes, in different provinces, and in both regular and targeted inspections, the message is that the failures are systemic to how many operators run their quality systems, not one-off accidents.

The Three Findings That Keep Recurring

Why does it matter which findings recur? Because a recurring finding is a roadmap. If you fix the three areas Health Canada lists first, you remove the cause of most non-compliant reports before an inspector ever arrives.

1. Unsatisfactory retention of documents and information

This is the single most common thread through the individual results. A licence holder must keep records that let Health Canada reconstruct what happened, when, and who did it, and keep them for the required retention periods. In practice the finding shows up as batch and lot records that cannot be reconstructed, sanitation and pest control programmes that are performed but not evidenced, and information that exists in someone's memory rather than in a controlled record. If the record cannot be produced, for the purpose of an inspection it did not happen.

2. Not conducting activities as per assigned responsibilities

The Cannabis Regulations require named, qualified individuals to hold specific responsibilities, including the quality assurance person who must approve the quality of cannabis before it is made available for sale. This finding appears when responsibilities are assigned on paper but not demonstrably executed, when a change in the quality assurance person is not approved by Health Canada, or when the person named for a function is not the person actually performing it. Authority on an organisation chart is not the same as authority exercised and recorded.

3. Non-compliances related to good production practices

Good production practices, set out in Part 5 of the Cannabis Regulations, cover sanitation, pest control, the competencies of personnel, standard operating procedures, testing, and the controls that keep product safe and consistent. GPP findings range from sanitation and pest management programmes that are not evidenced, to the use of unauthorized pest control products, to testing gaps. Several licence holders in the 2024 to 2025 results faced stop sales tied directly to unauthorized pest control products or missing pesticide testing.

Beyond the top three, the individual results also repeat a familiar supporting cast: insufficient security measures, unauthorized storage or distribution of cannabis, unsatisfactory packaging and labelling, failure to report inventory, failure to disclose loss or theft, and unsatisfactory recall strategies. Almost all of them trace back to the same root cause, which is a quality system that is documented but not lived.

Why These Findings Are Preventable

Here is the encouraging part. None of the recurring findings requires a new capability or a large capital outlay. They require a quality system that is used every day and can be evidenced on demand. In our experience preparing licence holders for inspection, the gap is almost never knowledge of the rules. It is the discipline of recording what was done, at the moment it was done, by the person authorised to do it.

A useful test is the reconstruction test. Pick any lot released in the last year and try to rebuild its full history from records alone: cultivation or processing steps, sanitation and pest control around it, testing results, the quality assurance person's release decision, and where it went. If you cannot rebuild it cleanly, an inspector will not be able to either, and that is where the non-compliant finding starts. A disciplined set of standard operating procedures and a habit of contemporaneous recording close most of the gap.

Health Canada's inspection approach is risk based, and inspections are not always announced far in advance. Records that live on a single laptop, or that take days to compile, become a finding in themselves when an inspector asks to see them during the visit. The operators who pass cleanly are the ones whose records are indexed, controlled, and retrievable on the day, whether the inspection is on site or conducted remotely.

A common scenario shows how quickly this escalates. An inspector asks for the release records behind a specific lot. The sanitation logs for that period are incomplete, the pest control record does not name the product used, and the quality assurance person cannot point to a documented release decision. Individually each gap looks minor. Together they become a non-compliant report with corrective actions, and if the pest product turns out to be unauthorized, a stop sale on the affected lots. None of it required new knowledge to prevent, only a system that records what was done as it is done.

What Good Production Practices Actually Require

Good production practices are the cannabis sector's equivalent of the manufacturing quality controls that other regulated industries know as GMP. Under Part 5 of the Cannabis Regulations, a licence holder must have, among other things, a sanitation programme, a pest control approach that uses only authorized products, qualified personnel, written standard operating procedures, a system for testing, and controls over the building, equipment, and storage. Our explainer on good production practices for cannabis walks through the framework in detail, and our guide to GPP versus EU-GMP is worth reading for any operator eyeing export.

The inspection data makes the priorities concrete. Sanitation and hygiene in processing must be both performed and documented. Pest control must rely only on products authorized for the use. Testing must actually be completed on the product being sold. Each of these is a place where operators lost ground in 2024 to 2025, and each is fixable with a procedure, a record, and a verification step.

The Quality Assurance Person Is Central

The quality assurance person, or QAP, sits at the centre of two of the three recurring findings. The QAP is responsible for assuring the quality of cannabis and for investigating complaints, and the regulations require the QAP to have the training, experience, and technical knowledge for the role. When Health Canada finds that activities were not conducted as per assigned responsibilities, the QAP function is often where it lands, whether because the release decision was not properly recorded, a new QAP was not approved by Health Canada, or the QAP did not have the authority to stop a release.

Treat the QAP as a working control, not a title. The person must be qualified, empowered to reject product, and supported by records that show the quality decisions they made. Where a licence holder lacks the in-house depth, an experienced external QAP or QAP support arrangement can hold the line while the internal system matures.

Cannabis GPP and Documentation Compliance Checklist

• Run the reconstruction test on a recent lot: can you rebuild its full history from records alone?
• Confirm document retention periods are met and records are readily retrievable, including for a remote or short-notice inspection.
• Evidence your sanitation programme with completed, dated records, not just a written procedure.
• Verify that only authorized pest control products are used, and that use is recorded.
• Confirm testing is completed on every lot released for sale, with results on file.
• Check that the quality assurance person is qualified, and that any change of QAP has Health Canada approval.
• Make sure assigned responsibilities on the organisation chart match who actually performs and records the work.
• Keep security, inventory, and loss or theft reporting current and evidenced.
• Maintain a tested recall strategy and current standard operating procedures.
• Close inspection findings with documented corrective and preventive action that addresses root cause.

Common Mistakes

• Treating the quality system as an inspection-day binder. Inspectors look for evidence the system runs every day, not a document assembled the night before.
• Assigning responsibilities on paper only. A named QAP who does not exercise and record the role produces the exact finding Health Canada reports most.
• Assuming any pest product will do. Using unauthorized pest control products triggered stop sales in the 2024 to 2025 data.
• Skipping or thinning out testing. A lack of required testing on product sold is a direct compliance failure, not a paperwork detail.
• Closing findings without root cause. A corrective action that does not fix the underlying system invites the same finding at the next inspection.

Frequently Asked Questions

How many cannabis inspections did Health Canada conduct in 2024 to 2025?

Health Canada conducted 889 inspections under the Cannabis Act and its regulations in fiscal year 2024 to 2025, including 197 inspections of personal and designated production, and issued 37 non-compliant inspection reports to licence holders.

What are the most common cannabis inspection findings?

Health Canada lists three first: non-compliances related to good production practices, unsatisfactory retention of documents and information, and not conducting activities as per assigned responsibilities. Security, storage, packaging and labelling, inventory reporting, and recall strategy findings also recur.

What are good production practices for cannabis?

Good production practices are the controls in Part 5 of the Cannabis Regulations that keep cannabis safe and consistent, including sanitation, authorized pest control, qualified personnel, standard operating procedures, testing, and controls over buildings, equipment, and storage.

Who is the quality assurance person and why does it matter?

The quality assurance person, or QAP, is the individual responsible for assuring the quality of cannabis before it is made available for sale and for investigating complaints. A change of QAP must be approved by Health Canada, and the QAP must have the training, experience, and technical knowledge for the role.

What happens after a non-compliant inspection report?

Health Canada can require corrective actions and escalate as needed, including seizure and detention, stop sales, warning letters, and licence suspension or revocation. Corrective actions must address the root cause, not only the symptom, to prevent the finding from recurring.

How long must a cannabis licence holder keep records?

Record retention periods are set out in the Cannabis Regulations and vary by record type. The practical standard is that records must be complete, contemporaneous, and readily retrievable so that an inspector can reconstruct what happened.

How MFLRC Can Help

MFLRC helps cannabis licence holders turn the recurring inspection findings into a quality system that holds up under scrutiny. Our audit and inspection-readiness team runs mock inspections against Health Canada's own findings, our quality assurance specialists build the SOPs, documentation, and quality assurance person framework the regulations expect, and we support corrective and preventive action that fixes root cause. We work with operators across the cannabis and hemp sector, from pre-licence applicants to producers preparing for export.

A useful first step is an honest gap assessment. Run our Health Canada inspection-readiness self-assessment, or book a consultation and we will benchmark your documentation, QAP authority, and GPP against what inspectors are actually citing.

Conclusion

Health Canada's 2024 to 2025 cannabis inspection data is not a warning about new rules. It is a mirror. The same three findings, documentation, assigned responsibilities, and good production practices, drive most non-compliant reports because they reflect how a quality system is run day to day, not what an operator knows. Fix the systems behind those findings, evidence them contemporaneously, and give the quality assurance person real authority, and you remove the cause of most inspection failures before an inspector arrives. For help closing the gap, respond to inspection observations with documented corrective and preventive action, and build the discipline in before the next inspection cycle.

Sources and References

• Health Canada, Compliance and enforcement report: Cannabis inspection data summary 2024 to 2025
• Cannabis Regulations (SOR/2018-144), including Part 5 Good Production Practices
• Cannabis Act (S.C. 2018, c. 16)