Section 138 of the Cannabis Regulations sets the Canadian labelling minimum for a bulk export container: the licence holder's name, telephone number and email address, plus a lot number and a packaging date. Importers add their own requirements on top, and most of them concern the bag that touches the flower.
Bulk cannabis export packaging is the sealed primary bag, rigid secondary container and labelled shipping unit that carry dried flower from a Canadian Licensed Producer to an importer's GMP facility. Importers judge it on barrier protection against moisture, oxygen and light, documented material suitability, lot-level labelling that matches the paperwork, and whether the flower arrives in the same physical condition it left in.
How bulk cannabis export packaging is built
Importer specifications for bulk dried flower tend to follow the same basic structure. We call it the three-layer export pack, because each layer fails in a different way and gets checked by a different person.
Layer 1: the primary pack
This is the bag that touches the flower. It's usually a heat-sealed, high-barrier laminate holding a fixed net weight agreed in the supply contract. Because it protects cannabinoid and terpene content, the importer's quality team reviews it more closely than any other layer.
Layer 2: the secondary container
A rigid, opaque outer container (a sealed pail, tote or carton) protects the primary pack from crushing and light. It carries the lot label and a tamper-evident seal. If the seal is broken on arrival, many importers quarantine the unit before anyone opens the bag.
Layer 3: the shipping unit
Secondary containers are palletised or boxed into the shipping unit that travels under the export permit. Under Part 7 of the regulations, the packaging and labelling requirements don't apply to a shipping container. Customs brokers and the importer's receiving team still need to match each shipping unit to the commercial invoice and the permit, so label it clearly anyway.
Treat each layer as a separate specification with its own owner. When one document tries to cover all three, the primary pack is the part that ends up underspecified.
Primary packaging materials and the specs importers request
EU-GMP expects packaging materials to be bought against an approved specification, from qualified suppliers, and checked on receipt. An importer manufacturing under EU-GMP will extend that expectation to you, because your bag becomes part of their starting material.
In practice, expect a request for three documents before the first shipment:
- A material specification for the primary bag, covering laminate structure, thickness and barrier properties.
- A declaration of conformity for product-contact plastics. Many EU importers use Commission Regulation (EU) No 10/2011 on plastic food-contact materials as their baseline.
- Your supplier qualification record for the packaging vendor.
The sealing method matters as much as the material. The table compares the four common options for premium dried flower.
| Sealing method | What it does | Main risk | Fit for large-bud flower |
|---|---|---|---|
| Heat seal, no vacuum | Closes the bag with ambient headspace | Oxygen left in headspace | Good, protects bud structure |
| Nitrogen flush and heat seal | Replaces headspace oxygen with nitrogen | Needs validated flush equipment | Very good |
| Light vacuum | Removes some air without full compression | Hard to control consistently | Acceptable with care |
| Hard vacuum | Removes nearly all air | Crushes buds and trichomes | Poor |
Humidity control packs divide importers. Some importers accept two-way humidity packs inside the primary bag. Others treat anything inside the bag as a product-contact material that needs its own qualification. If you're shipping into an irradiation step, check that the bag and any insert are compatible with the importer's process too (our guide to cannabis irradiation in export markets covers the methods).
Get the importer's written answer on inserts and sealing method before you build stability data, because changing either one later means repeating the study.
Labelling bulk cannabis containers for export
Bulk flower that isn't packaged for retail sale isn't a "cannabis product" under the regulations, so Canada's plain-packaging rules, health warnings and child-resistant container requirements don't apply to it. Section 138 does. Every container of exported cannabis must show:
- The name, telephone number and email address of the licence holder exporting it.
- The lot number, preceded by "Lot number", "Lot no.", "Lot" or "(L)".
- The packaging date.
That is the Canadian floor. Importers usually add their own fields through the quality agreement: cultivar name, net weight, unit number within the lot (for example, 4 of 20), storage conditions, retest or expiry date, and sometimes the export and import permit references. Some ask for the label in their own language as well as English.
Mismatched lot numbers cause more labelling problems than missing fields. The lot number on the container, the certificate of analysis, the export permit and the commercial invoice must be identical, character for character. A COA tested under ISO/IEC 17025 accreditation is worth very little to an importer if its lot reference reads differently from the label.
Build one master lot record and generate every label and document from it. Retyping lot numbers is how shipments get held at the border.
Where export packaging fails and how to prevent it
Compression damage
Large, dense buds don't survive hard vacuum. The bag pulls tight, buds flatten, and trichome heads break off against the film. The flower can still pass potency testing and fail the importer's visual inspection. Hard vacuum has no place on premium hand-trimmed flower. If you've paid for hand trimming, as our comparison of hand-trimmed and machine-trimmed export flower explains, compressing it in the bag throws that value away.
Seal failure in transit
Air cargo holds are kept at a lower pressure than the ground, so bags with trapped headspace expand during the flight. A weak seal that held on the packing line can open over the Atlantic. Run a seal-integrity check on every unit before release, and record it in the batch record.
Condensation at transfer points
Cold product moved into a warm receiving area will pull moisture onto the outside of the bag, and into it if the bag is opened too early. Let sealed containers reach room temperature before opening. Our article on cold chain and customs requirements for cannabis exports covers temperature control in transit, and our water activity and moisture limits guide explains why a small moisture gain matters.
Packaging that doesn't match the stability data
Shelf-life data only supports the packaging configuration it was generated in. Switch bag suppliers, change the laminate or add a humidity pack, and your shelf-life claim no longer has evidence behind it. Importers in Europe, and Australian sponsors working to TGO 93, will ask which configuration the study used. The cannabis stability testing guide walks through how LPs set export shelf life.
AlphaLeaf is a Health Canada Licensed Producer in Montreal growing indoor, hand-trimmed flower from refined genetics. We hold export authorisation under the Cannabis Act, test every batch through ISO/IEC 17025 accredited laboratories, and keep full traceability records from plant to sealed export unit for EU and Australian import partners.
Packaging decides what your importer sees when the bag is opened. Agree the specification before the first lot is packed, and treat any later change as a formal change control. If you're planning a first shipment and want to compare packaging specifications, contact the AlphaLeaf team.
Frequently Asked Questions
What labelling does Health Canada require on bulk cannabis exported from Canada?
Section 138 of the Cannabis Regulations requires each container to show the exporting licence holder's name, telephone number and email address, the lot number with an approved designation such as "Lot", and the packaging date. Importers usually add more fields through the quality agreement.
Do Canadian plain-packaging rules apply to bulk cannabis exports?
No. Plain packaging, health warnings and child-resistant containers apply to cannabis products packaged for retail sale. Bulk flower that isn't packaged for retail falls under section 138 labelling instead, and Part 7 requirements don't apply to the shipping container.
Should bulk cannabis flower be vacuum sealed for export?
Hard vacuum is a poor choice for premium flower because it compresses buds and damages trichomes. A heat seal with a nitrogen flush gives oxygen protection without crushing the product, provided the flush process is validated.
Can humidity control packs go inside bulk cannabis export bags?
Only if the importer agrees in writing. Some importers accept two-way humidity packs, while others treat any insert as a product-contact material that needs its own qualification and stability data.
Does packaging affect a cannabis lot's shelf life?
Yes. Stability data supports only the packaging configuration it was generated in. Changing the bag material, sealing method or inserts means the existing shelf-life claim no longer has supporting evidence.
What packaging documents do EU importers ask Canadian LPs for?
Expect requests for a primary bag specification, a declaration of conformity for product-contact plastics, often referencing Commission Regulation (EU) No 10/2011, and the qualification record for your packaging supplier.
