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8 maltatoday | SUNDAY • 9 APRIL 2023 NEWS The Strategy and Implementation Division (EU Funds) within the Ministry for the Economy, European Funds and Lands Notice of a Public Consultation The Director-General, Strategy and Implementation Division (EU Funds) within the Ministry of the Economy, European Funds and Lands, informs the general public and stakeholders of a request for a public consultation regarding Malta's REPowerEU initiatives as part of the Recovery and Resilience Facility (RRF) for Malta. The Document can be accessed through the following website address https://fondi.eu/programme/recovery-and-resilience-plan/ or by obtaining a copy from the from the Strategy and Implementation Division, European Funds Section, 32, House of Catalunya, Marsamxett Road, Valletta, VLT 1850. All interested parties are invited to send their proposals, suggestions and comments by sending an email on the email address fondi.eu@gov.mt or by submitting feedback by post addressed to the Strategy and Implementation Division, European Funds Section, 32, House of Catalunya, Marsamxett Street, Valletta, VLT 1850. Submissions can be sent until 17:00hrs CEST on Friday, 21 April 2023 Late proposals will not be considered. CONTINUED FROM PAGE 1 As confirmed by ARUC chair- person Leonid McKay in reply to questions from MaltaToday, with the largest association possible to grow cannabis being allowing a maximum of 500 members, such a cannabis club will also be able to split the volumes of cannabis it grows across multiple distribution sites. The allowance for such large clubs is a new development with the new iteration of ARUC, which recently underwent changes at the top with the resignation of former Caritas addictions expert Mariella Dimech and various board mem- bers. "The legislation does not inhibit associations from having multiple distribution sites," McKay, the new chairperson, told MaltaToday. "ARUC may allow such a sce- nario for large associations, which may not exceed 500 members, provided that the opening of mul- tiple sites is financially feasible for the size of the association and that the opening of additional sites is not done for the mere purpose of absorbing the association's profits into unnecessary costs. The pro- viso that associations must carry out the entire process from seed to distribution to their own members only would still apply." In fact, under the new ARUC policies, "non-permanent struc- tures" located outside the develop- ment zones – covered by a permit and registered as an agricultur- al holding – are expected to be greenhouses. "The Authority will ensure that the size of the premises is proportionate with the required level of operations to cater for the needs of the association's mem- bers," McKay said. MaltaToday understands that greenhouse owners seeking a foot- hold in the recreational cannabis business, would also have to in- vest considerably in air-condition- ing systems that can keep indoor climate at 26 degrees Celcius in summer, when indoor greenhouse temperatures can easily climb to well above 40 and 50 degrees. And while such expansive set- ups will require considerable in- vestment of their own, such 'chain store' dispensation of cannabis will introduce a new business philos- ophy to what was once thought would be an independent collec- tion of small growers with their dispensary. Large growers will in fact benefit from economies of scale on such demands from ARUC to test their crop's phytocannabinoid profile. "Testing is one of the most im- portant elements in this reform," McKay told MaltaToday. "The Authority's ultimate aim is to en- sure that cannabis distributed to users does not contain harmful contaminants." Crop tests To keep such crops under con- trol, Cannabis Harm Reduction Associations will carry out testing on the first batch and on every 20th subsequent batch, provided that the same cultivation practices and strains are maintained. "The cycle shall be repeated every time such practices are changed. Further- more, the Authority will also do random spot checks and testing to ensure that the quality indicated in the test results is being maintained. Labels must be affixed to each dis- tributed packet," McKay said. Registration fees for associations have also been slashed from the amounts originally planned: small associations with up to 50 mem- bers will now only pay €1,000 a year, rather than the minimum €8,750 annual fee initially pro- posed. McKay had previously said the decision came following feedback from prospective applicants, who said they would not be able to af- ford the exorbitant fees. Yet fees will rise for the larger, 500-mem- ber clubs, who will pay a €26,000 fee annually. The rules will apply to all cannabis associations, irrespec- tive of size, an approach previously criticised by cannabis lobby group Releaf, which says clubs with fewer than 100 members should be given additional leeway for more make- shift operations, such as growing cannabis in grow-tents. Even in terms of remuneration, ARUC's law states that salaries in not-for-profit cannabis associa- tions should not be substantial and in line with market levels and con- ditions as laid down in the Volun- tary Organisations Act, and then be "of material irrelevance when compared to income/expenditure of the association." But then there is an exception should ARUC determine that an administrator of these cannabis clubs has "specific skills" that are required by an association and must therefore be remunerated at a higher level. Such jobs might include professional growers from other countries with long experi- ence in the cannabis industry, with substantial salary ranges that can easily be north of €60,000, canna- bis experts told this newspaper. "The Authority is committed to ensure that the associations operate on a not-for profit basis and that any potential profits are not taken by the administrators through inflated wages," McKay says. "The Authority will evaluate each case according to the skills of the individual and the position that they shall hold within the associa- tion, the size of the association, its expected income, and the share of expenses on wages from that in- come. Considering these param- eters, no specific ranges shall be set." Ultimately the associations can- not be owned by a single indi- vidual or a group of individuals, McKay says when asked whether cannabis club founders should not be involved in the pharmaceuti- cal cannabis industry, or related to alcohol, tobacco or the gaming industry. "All members shall par- ticipate in the governance of the association so that the associations maintain a grassroot and commu- nity-based approach. The authori- ty will ensure that all associations adhere to its regulations, includ- ing its blanket ban on any form of marketing." New cannabis clubs' rules Under ARUC's rules, cannabis associations will be obliged to con- tribute 5% of annual income to a harm reduction fund and 10% of retained earnings for a community projects fund. ARUC will adminis- ter both funds. Founders must have lived in Mal- ta for at least five years to set up an association and anyone convicted of major crimes or drug-related offences in the previous 10 years cannot set up an association, hold a key role in one or work as one of its employees. ARUC inspectors will be em- powered to carry out on-site in- spections or audits. Associations that don't file a quarterly report or keep a proper list of their members will be fined €1,000 – the lowest fine stipulated in the rules. From there, fines rise gradually to €2,000 (selling alcohol at asso- ciations or having too many mem- bers), €2,500 (causing a nuisance to neighbours), €5,000 (selling canna- bis that is not clearly labelled and packaged), and finally €10,000 for the most serious contraventions. Testing is one of the most important elements in reform