POLICY ON THE LICIT USE OF CANNABIS IN

BOTSWANA

MINISTRY OF LANDS AND AGRICULTURE

24 FEBRUARY 2025
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CONTENTS

I. ABBREVIATIONS AND ACRONYM ....................................................................................... 3

II. INTRODUCTION ............................................................................................................................... 4
III. SITUATIONAL ANALYSIS ............................................................................................................ 4
IV. INTERNATIONAL CONTEXT ...................................................................................................... 9
V. CURRENT NATIONAL CONTEXT........................................................................................... 11
VI. POLICY GOAL AND OBJECTIVES ....................................................................................... 15
VII. GUIDING PRINCIPLES ................................................................................................................ 17
VIII. POLICY STRATEGIC INITIATIVES ......................................................................................... 18
IX. IMPLEMENTATION OF THE POLICY ................................................................................ 25
X. STAKEHOLDERS ............................................................................................................................ 36
XI. RISK MANAGEMENT .................................................................................................................... 41
XII. MONITORING AND EVALUATION ..................................................................................... 42

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I. ABBREVIATIONS AND ACRONYM

BITRI – Botswana Institute for Technology Research and Innovation

BOMRA – Botswana Medicines Regulatory Authority

BURS – Botswana Unified Revenue Service

BWP – Botswana Pula (currency)

CAP – Chapter (referring to a section in a legal document)

CCTS – Cannabis Compliance Tracking System

HS Codes – Harmonized System Codes

IKS – Indigenous Knowledge System

INCB – International Narcotics Control Board

ITKS – Indigenous Technological Knowledge Systems

LMOs – Living Modified Organisms

NCCA - Natural Cannabis control Authority

SADC – Southern African Development Community

SHE – Safety, Health, and Environment

THC – Tetrahydrocannabinol

UN – United Nations

USD – United States Dollar

WHO – World Health Organization

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 I. INTRODUCTION

1. The Government of Botswana, recognizing the evolving global

landscape of cannabis regulation and its potential contribution to
economic diversification and healthcare advancement, has developed a
comprehensive framework for the controlled use of cannabis for
medical and scientific purposes. This policy document establishes the
foundational principles, regulatory requirements, and implementation
strategies for achieving these objectives while ensuring strict
compliance with international obligations and maintaining public safety.

2. The global perspective on cannabis regulation has undergone

significant transformation over the past decade. The medical cannabis
market alone is projected to grow from USD 57.18 billion in 2023 to
USD 444.34 billion by 2030, reflecting an increasing recognition of
cannabis's therapeutic applications and economic potential. Within the
Southern African Development Community (SADC) region, countries
including Lesotho, Zimbabwe, and South Africa have established
regulatory frameworks for medicinal use, providing valuable insights for
Botswana's approach.

II.SITUATIONAL ANALYSIS

Currently, there is no cultivation of cannabis in Botswana. However, the

country possesses favorable conditions for the cultivation of Cannabis
sativa, which has significant potential for industrial, medicinal, and
economic applications. This section provides a detailed analysis of the
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agronomic requirements, growing conditions, and potential yields of
cannabis, highlighting Botswana’s suitability for its cultivation.

Botswana’s favourable soil and climatic conditions, combined with the

high yield potential of hemp, make it a promising crop for economic and
industrial development. However, realizing this potential will require a
robust regulatory framework, investment in infrastructure, and capacity-
building initiatives. By addressing these challenges, Botswana can harness
the benefits of hemp cultivation to drive economic growth, create jobs,
and promote environmental sustainability.

1. Cultivation of cannabis sativa

Cannabis sativa is an annual, herbaceous plant with a slender stem. It has

a strong taproot that penetrates deep into the soil. The plant’s height
ranges from 1 to 5 meters, depending on the cultivar and growing
conditions.

a. Soils Suitability

Cannabis can grow on a wide variety of soil types, but optimal growth
requires specific conditions:

i) Preferred Soil Type: Deep, well-aerated soils with a pH of 6 or

greater.
ii) Moisture and Nutrient Retention: Soils with good moisture
and nutrient-holding capacity are ideal.
iii) Unsuitable Soils: Poorly drained soils are not recommended,
as excess surface water after heavy rains can damage the crop.

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 iv) Sensitivity: Hemp is extremely sensitive to flooding and soil
compaction, which can hinder root development and reduce
yields.

b. Growing Conditions

Cannabis thrives under specific climatic and environmental conditions:

i) Climate: cannabis prefers a mild climate and a humid atmosphere.

ii) Rainfall: It requires an annual rainfall of at least 250 mm to 500
mm.
iii) Soil Moisture: Good soil moisture is critical for seed germination
and the establishment of young plants.
iv) Temperature Tolerance: cannabis can survive daily low
temperatures as low as -0.5°C to high as 32°C. Improved varieties
that can withstand Botswana’s high temperatures may be planted.
Research and Development on cultivars suitable for Botswana’s
climatic conditions shall be facilitated.
v) Cannabis cultivation can be done in open fields or protected
environment (controlled environment)

c. Yield Potential

Hemp cultivation offers significant yield potential, making it a viable crop

for Botswana’s agricultural sector:

i) Fibre Yield:

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 • Expected yield: 3 to 4 tons of baled hemp stalks per hectare.
• Marketable fibre: Up to 2 tons per hectare.
ii) Seed Yield:

• Average yield: 1 ton of hemp seed per hectare (at a moisture

content of 12%).
• Pressed oil yield: Approximately 455 to 800 Liters per hectare.

iii) Medicinal Flowers:

• 448 –560 Kg/ha of dried unseeded flowering tops when grown
outdoors.
• 2500-5000 kg /ha of dried unseeded flowering tops when
grown indoor using hybrids.

2. Opportunities for Botswana

a. Economic Diversification:

Cannabis sativa cultivation can contribute to economic

diversification by creating new value chains in textiles,
construction, food, and pharmaceuticals.

b. Job Creation:

The establishment of hemp farms and processing facilities can

generate employment opportunities in rural and urban areas.

c. Environmental Benefits:

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 Hemp is a sustainable crop that requires minimal pesticides and
herbicides, improves soil health through phytoremediation, and
has a high carbon sequestration potential.

d. Alignment with Global Trends:

The global demand for hemp-based products is growing,

particularly in the health, wellness, and sustainable industries.
Botswana can position itself as a regional leader in hemp
production.

3. Challenges and Considerations

a. Regulatory Framework:

The current prohibition on cannabis sativa cultivation requires

legislative amendments to enable the licit cultivation.
b. Infrastructure and Expertise:

Developing the necessary infrastructure (e.g., controlled

environments, processing facilities) and building technical
expertise among farmers will be critical.
c. Market Development:

Establishing domestic and international markets for hemp

products will require strategic partnerships and marketing
efforts.
d. Environmental Safeguards:

Ensuring sustainable cultivation practices to prevent soil

degradation, water contamination, and biodiversity loss.
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 III. INTERNATIONAL CONTEXT

Botswana's approach to cannabis regulation is fundamentally shaped by

its international commitments, particularly its obligations under the United
Nations Single Convention on Narcotic Drugs (1961), which it acceded to
in 1996. This framework requires a carefully balanced approach that
enables legitimate use while maintaining strict controls.

The underpinning regulatory framework must align with the international

conventions:

1. Single Convention on Narcotic Drugs (1961)

This international treaty establishes a framework for controlling the

production, distribution, and use of cannabis for medical and scientific
purposes. Botswana’s compliance with the Convention includes the
following measures:

a. Restrict cannabis use to medical and scientific purposes.

b. Establish a national cannabis agency.
c. Implement comprehensive licensing systems.
d. Maintain detailed production and distribution records.
e. Submit regular reports to the International Narcotics Control
Board.

2. Convention on Psychotropic Substances (1971)

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The Convention on Psychotropic Substances (1971) provides a regulatory
framework for synthetic cannabinoids and THC derivatives. Botswana
adheres to this Convention by implementing control mechanisms that
ensure the safe and controlled use of psychotropic substances.

Key requirements include:

a. Regulates synthetic cannabinoids.

b. Establishes control mechanisms for tetrahydrocannabinol
(THC) derivatives.
c. Requires safety monitoring systems.
d. Mandates reporting requirements.

3. United Nations Convention against Illicit Traffic (1988)

The Convention focuses on preventing the diversion of controlled

substances and strengthening international cooperation in combating illicit
drug trafficking. Botswana’s implementation of this Convention includes
measures such as:

a. Focuses on preventing diversion

b. Establishes border control requirements
c. Requires precursor chemical controls
d. Mandates international cooperation

4. Cartagena Protocol on Biosafety

a. Focuses on the safe handling, transport, and use of living
modified organisms (LMOs) that may have adverse effects
on biological diversity and human health.

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 b. Requires risk assessments and monitoring for genetically
modified cannabis strains, if applicable.

IV. CURRENT NATIONAL CONTEXT

5. The Republic of Botswana currently maintains a comprehensive

regulatory prohibition on cannabis and hemp products across all
sectors. The existing legislative and regulatory framework prohibits
the licit cultivation, manufacture, distribution, or use of cannabis
or hemp products for any purpose. There are specific
authorizations permission available for medical, pharmaceutical
analysis and research which are limited by the absence of
regulations and regulatory mechanisms.

6. Botswana's existing cannabis control framework spans multiple

pieces of legislation. The current legislation prohibits the use of
cannabis any beneficiation thereof.

7. The present regulatory environment is characterized by the

following elements:

a. Legislative Status

Botswana’s current legislative framework maintains a strict prohibition on

the cultivation, manufacture, and distribution of cannabis. This prohibition
is enshrined in multiple laws, which collectively restrict all forms of
cannabis use.

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Key features of the legislative status include:

i) Complete prohibition on cultivation, manufacture, and

distribution.
ii) Absence of regulatory frameworks for medical or industrial
applications.
iii) Non-existence of licensing mechanisms.
iv) Prohibition on importation and exportation of cannabis-
derived products.
8. Botswana's existing cannabis control framework spans multiple
pieces of legislation:

a. Medicines and Related Substances Act (2013) and

Medicines and Related Substances Regulations, 2019:

The Medicines and Related Substances Act (2013) serves as the primary
legislation governing the regulation of medicines in Botswana. Under this
Act, cannabis is classified as a banned substance, and its use is restricted
to limited exemptions for research and pharmaceutical analysis. Key
provisions of the Act include:

i) Classifies cannabis as a banned substance through

regulations;
ii) Provides regulatory framework for medicines;
iii) Establishes Botswana Medicine Regulatory Authority; and
iv) Regulations require amendment to lift prohibition on
cannabis use and to add cannabis to the Medicines schedules
to guide their regulation.

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 b. Illicit Traffic in Narcotics and Psychotropic Substances
Act (2018):

The Illicit Traffic in Narcotics and Psychotropic Substances Act (2018)

provides the legal basis for controlling the production, distribution, and
use of narcotics and psychotropic substances in Botswana. This Act
currently prohibits all forms of cannabis use, with limited exceptions for
pharmaceutical analysis. Its framework includes:

i) Is primary legislation controlling cannabis;

ii) Provides ministerial authorization powers for pharmaceutical
analysis;
iii) Establishes enforcement framework; and

iv) Requires modification for medical/scientific use.

c. Plant Protection Act, CAP 35:02

The Plant Protection Act, CAP 35:02, regulates the introduction and
movement of plants within Botswana. Cannabis sativa is listed as a
quarantine pest under this Act, which restricts its cultivation and
importation.

Key provisions impacting cannabis regulation include:

i) Prevents the introduction and spread of plant pests;

ii) Lists Cannabis sativa as quarantine pest;
iii) Controls importation and movement of plants; and
iv) Impacts cultivation possibilities.

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 d. The Noxious Weeds Act, CAP 35:04

The Noxious Weeds Act, CAP 35:04, classifies cannabis as a noxious weed
and mandates its destruction. This Act prohibits the cultivation of cannabis
and imposes penalties for non-compliance. Its provisions include:

i) Classifies cannabis as a noxious weed; and

ii) Mandates its destruction and prohibits of cultivation of
cannabis.

e. Regulatory Implementation

The absence of a regulatory framework for cannabis control creates

significant challenges in governance and enforcement. Botswana currently
lacks the institutional mechanisms and operational protocols necessary to
oversee the licit use of cannabis.

Key gaps in regulatory implementation include:

i) No established mechanisms for quality control or

standardization.
ii) Absence of institutional frameworks for sector
governance
iii) Non-existence of authorized cultivation or processing
facilities
iv) Lack of formal protocols for handling exemptions or
authorizations

f. Market Context

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The lack of a legitimate domestic market for cannabis products limits
economic opportunities and hinders the development of value chains.
Botswana’s current market context is characterized by the following
challenges:

i) No legitimate domestic market for cannabis or hemp

products
ii) Absence of established value chains or market
infrastructure
iii) Limited engagement with international cannabis control
bodies

9. This regulatory position has precluded the development of licit

cannabis-related industries within the national economy, while
regional economies have commenced implementing controlled
regulatory frameworks for specific applications.

V. POLICY GOAL AND OBJECTIVES

10. The overall policy goal is to establish a regulated, sustainable

cannabis sector that advances public health while creating
opportunities through cultivation, medical and industrial
applications.

11. The policy intends to promote, regulated cultivation, industrial and

medical use of cannabis. Further, it provides for a legislative and
operational framework that promotes national development while
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 protecting public health and observing international obligations.
Therefore, the objectives are as follows:

a. Develop enabling legislation for cannabis use;

b. Establish institutions that effectively regulate cannabis;
c. Designate a dedicated entity to oversee cultivation and use;
d. Create designated cultivation sites through research-based
mapping; and
e. Develop market linkages and value chains.

12. Essentially, the objectives of the policy will address the following:
a. Medical and scientific applications of cannabis.
b. Industrial hemp cultivation and processing.
c. Quality control and safety standards for all cannabis variants.
d. Regulatory oversight mechanisms for both medicinal cannabis
and industrial hemp.
e. International compliance requirements including distinctions
between drug-type cannabis and industrial hemp.
f. Industry development for medicinal cannabis and industrial
hemp sectors.
g. Supply chain controls and tracking systems.
h. Research and development frameworks.
i. Market development and economic opportunities.

13. The policy explicitly excludes recreational cannabis use,

maintaining existing prohibitions while creating pathways for
legitimate medical and scientific applications.
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 VI. GUIDING PRINCIPLES

14. The principles on the use of cannabis emphasise public health and
safety, promoting responsible use, resource exploitation for
development. The principles also call for adherence to legal
instruments in the country as well as international protocols. These
are as follows:

a. Public Health Protection

Public health protection is a central pillar of Botswana’s cannabis policy.

The policy prioritizes the safety and well-being of the population by
ensuring that cannabis use is strictly regulated and evidence based. Key
principles under this pillar include:

i) Prioritizing safety and quality

ii) Evidence-based decision making

iii) Risk-based regulatory approach

b. International Compliance

Botswana’s cannabis policy aligns with its international obligations under

United Nations conventions and regional agreements. The policy ensures
that all regulatory measures comply with global standards and best
practices.

Key compliance measures include:

i) Adherence to United Nations Conventions

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 ii) Regional harmonization

iii) Global best practices

c. Economic Development

The policy promotes sustainable economic development by creating

opportunities for investment, job creation, and value chain development
in the cannabis sector.

Key objectives under this principle include:

i) Industry sustainability

ii) Local capacity building

iii) Value chain development

d. Social Responsibility

Social responsibility ensures that the benefits of the cannabis sector are
equitably distributed and that communities are actively engaged in
decision-making processes. Guiding principles under this pillar include:

i) Equitable access

ii) Stakeholder engagement

iii) Community benefits

VII. POLICY STRATEGIC INITIATIVES

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Strategic initiatives are essential for shaping coherent and effective
framework that addresses the multifaceted aspects of cannabis usage and
regulation. These are intended to create a comprehensive balance
between public health and safety and economic development while
equally mitigating potential risks. In view of this, the following strategic
initiatives will be put in place:

15. Enabling Policy and Legislative Framework

The establishment of an enabling policy and legislative framework is

essential for the successful implementation of Botswana’s cannabis policy.
This framework provides the legal basis for regulating the cultivation,
production, and use of cannabis for medical and scientific purposes.

Key actions under this initiative include:

a. The policy will be reviewed every five (5) years to

accommodate contemporary issues on the use of cannabis, to
cover cultivation, industrial use, public health usage, and other
value chains;

b. Promulgate comprehensive cannabis legislative framework;

and

c. Amendment of all existing laws to permit controlled cultivation

of cannabis.

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 16. Institutional Arrangements:

The intended use of cannabis will affect several organizations. It is

fundamental that all institutional structure is established for coordination
of cannabis usage.

As a result, the following will be put in place:

a. Designate a dedicated institutional structure to oversee

national cannabis regulation including roles and
responsibilities aligned to international conventions and
national regulatory requirements;
b. Development of co-regulation strategies with affected
regulatory bodies including health, agriculture, environment,
law enforcement, customs, research institutions, and
professional councils; and
c. Creation of coordination mechanisms between agencies
through establishment of governance structures, information
sharing platforms, and standardized protocols

17. Regulatory Oversight

The deregulation of cannabis requires a strict control in accordance

with international protocols. To ensure proper regulation, the following
will be done:

a. Develop comprehensive quality control standards;

b. Implement tracking, tracing and monitoring systems;
c. Develop enforcement protocols and standards;

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 d. Establish regulatory agency to regulate cannabis industry; and
e. Designate specific and protected sites for cultivation of
cannabis.

18. Research and Development

This initiative aims to drive innovation, sustainability, creation of value

and economic growth by leveraging scientific and technical
advancements. The following will be facilitated:

a. Research institutions shall be facilitated to conduct extensive

research on the potential uses of cannabis;
b. Encouraging ongoing research into the benefits and risks of
cannabis to provide evidence-based information;
c. Strategic collaboration with international organizations and
institutions will be facilitated;
d. Conduct studies of adaptability and yield potential of cannabis
to identify suitable areas for production;
e. Establish and implement comprehensive biosafety protocols
and monitoring systems for cannabis research and cultivation;
f. Promote innovation leading to beneficiation including
economic transformation through development of value-
added products and technology transfer;
g. Facilitate business portfolios investment related to hemp and
medicinal cannabis, alternative livelihoods, and turn-key
projects;

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 h. Establish systems for conservation of germplasm through
national preservation facilities and protocols; and
i. Document and integrate Indigenous Knowledge System (IKS)
and Indigenous Technological Knowledge Systems (ITKS) in
cannabis research and development.

19. Market linkages and value chain

Effective linkages are crucial for integrating various stakeholders on

the cannabis sativa supply chain, including growers, processors and
consumers. These facilitate the flow of information, resources and
products and will enhance profitability.

Value addition of Hemp into semi-finished and finished products rather

than exporting raw hemp should be promoted. Hemp should be used
to manufacture a wide range of products in order to diversify the
product range and enhance industrialization efforts in the country.

In this regard, the following will be done:

a. Select the right strains for cultivation of cannabis for specific

markets demands;
b. Transform raw cannabis into products that can serve identified
products and markets;
c. Connect products to consumers with specific regulations to
each; and
d. Ensure efficient logistics for product while adhering to legal
requirements.

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The following table depicts some of the products which can be produced
from hemp:

Table 1: USES OF CANNABIS SATIVA

Plant organs Primary Secondary Products

products
Stalk Fiber • Textiles
• Insulation
• rope
Hurds • paper
• organic compost
• animal bedding
• fiber board
• hempcrete
Seeds oil • cooking /seasoning oil
• dietary supplements
• body care products
• fuel
• paint
Hemp nut • milk/dairy
• bakery
• granola
• protein powder
Seed cake • Flour
• Beer
• Animal feed
roots roots • Medicine
• Organic compost
Leaves/flower • Animal bedding
• Mulch/compost
• Hemp tea
• Medicine

20. Public Awareness and Education:

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Public awareness and education campaigns are essential for promoting
informed decision-making and addressing misconceptions about cannabis
use. Botswana will implement targeted initiatives to educate the public
about the legal status, benefits, and risks of cannabis. Key efforts under
this initiative include:

a. Health and Safety information shall be provided on the positive

and negative effects and the extent to which cannabis has
been allowed;
b. The nation shall be informed about the legal status of
cannabis, including regulations surrounding handling,
possession, use and distribution;

21. International Protocols and Collaboration:

Botswana’s cannabis policy aligns with international protocols and

promotes collaboration with global partners. The policy ensures that all
regulatory measures comply with international standards and best
practices.

Key actions under this initiative include:

a. Adhere to international protocols such as those established by

the United Nations;

b. Collaborate with other countries to share data and best

practices regarding medicinal and developmental benefits and
risks of cannabis;

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 c. Harmonize national laws and regulations to observe
international protocols; and

d. Adhere to established international norms to bolster the

national credibility and reputation on the global stage,
promoting a responsible approach to cannabis use that aligns
with international expectations.

VIII. IMPLEMENTATION OF THE POLICY

The implementation of this policy shall ensure systematic development of

the cannabis sector while maintaining strict regulatory control. The
implementation framework addresses each strategic initiative through
specific action plans, timelines, and responsible entities.

22. Governance Structure

The governance structure ensures compliance with international protocols

and establishes a robust national oversight framework for the cannabis
sector.

a. International Protocol Alignment Implementation shall comply with:

i) United Nations Single Convention on Narcotic Drugs (1961)
ii) Convention on Psychotropic Substances (1971)
iii) UN Convention against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances (1988)
iv) Cartagena Protocol on Biosafety

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 b. National Oversight

The national oversight framework includes:

i) Establishment of National Cannabis Control Authority

ii) Inter-agency coordination mechanisms to ensure
collaboration among stakeholders.
iii) Regulatory enforcement framework
iv) Fulfillment of international reporting obligations.

24. Licensing and Authorization

The licensing and authorization framework ensures that all cannabis-

related activities are conducted under strict regulatory oversight.

a. License Categories

Licenses shall be issued for:

i) Cultivation (medicinal and industrial)

ii) Transportation
iii) Processing and manufacturing
iv) Therapeutic dispensing
v) Research and development
vi) Laboratory testing
vii) Import and export operations

b. Licensing Requirements

All applicants must provide the following documentation:

i) Business registration and tax compliance

ii) Land use authorization
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 iii) Security implementation plan
iv) Personnel vetting documentation
v) Standard operating procedures
vi) Quality assurance protocols

c. Application Process

i) Submission requirements
ii) Fee structure
iii) Inspection protocols
iv) Authorization procedures

25. Operational Controls

a) Cannabis Compliance Tracking System (CCTS)

The Cannabis Compliance Tracking System (CCTS) ensures the

traceability and transparency of cannabis products from cultivation to
sale. This system facilitates knowledge of the origin, testing results,
handling, and chain of custody information, making it visible and traceable
by regulators and law enforcement. The CCTS aligns with international
best practices and ensures compliance with Botswana’s obligations under
the Single Convention on Narcotic Drugs (1961).

i) Seed-to-Sale Tracking

Seed-to-sale tracking is a critical component of the CCTS, ensuring that

every stage of the cannabis supply chain is monitored and documented.
This system uses unique identification systems, chain of custody

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documentation, quality control checkpoints, and distribution monitoring to
maintain the integrity of cannabis products and prevent diversion.

- Unique identification systems

- Chain of custody documentation
- Quality control checkpoints
- Distribution monitoring

ii) Record Keeping Requirements

Accurate and comprehensive record-keeping is essential for regulatory

compliance and transparency. Producers are required to maintain detailed
records of production, testing, transactions, and compliance reports,
ensuring that all activities are traceable and verifiable by regulators.

- Production records
- Testing documentation
- Transaction logs
-Compliance reports

b) Quality Control and Safety

Accurate and comprehensive record-keeping is essential for regulatory

compliance and transparency. Producers are required to maintain detailed
records of production, testing, transactions, and compliance reports,
ensuring that all activities are traceable and verifiable by regulators.

i) Biosafety Measures

Biosafety measures are designed to minimize risks to human health and

the environment during cannabis cultivation and processing. These

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include contamination prevention, environmental protection, material
control protocols, and effective waste management practices.

- Contamination prevention
- Environmental protection
- Material control protocols
- Waste management

ii) Product Safety

Product safety protocols ensure that cannabis products meet stringent

quality standards before reaching consumers. This includes mandatory
testing requirements, adherence to quality standards, proper storage
specifications, and secure transport protocols.

- Testing requirements

- Quality standards

- Storage specifications

- Transport protocols

26. Producer Requirements

Producers must adhere to strict facility management and inventory

control requirements to ensure compliance with regulatory standards
and maintain the safety and integrity of cannabis products. These
requirements cover physical security, operational procedures,
inventory tracking, and supply chain management.

a) Facility Management
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 Facility management requirements ensure that cannabis production
facilities are secure, well-maintained, and operated in compliance with
regulatory standards. This includes physical security measures,
operational protocols, staff training, and emergency preparedness.

i) Physical Security

Physical security measures, such as access control systems, surveillance

requirements, inventory security, and personnel protocols, are essential
to prevent unauthorized access and ensure the safety of cannabis
products.

- Access control systems

- Surveillance requirements
- Inventory security
- Personnel protocols
ii) Operations

Operational requirements include standardized production

procedures, regular equipment maintenance, staff training programs,
and emergency protocols to ensure efficient and safe facility
operations.

- Production procedures
- Equipment maintenance
- Staff training
- Emergency protocols

b) Inventory Control

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Inventory control measures ensure that all cannabis plants, products, and
equipment are accurately tracked and managed throughout the supply
chain. This includes tracking requirements for mother plants, clones,
product labelling, and equipment, as well as supply chain management
protocols for material sourcing, production tracking, distribution control,
and recall procedures.

i) Tracking Requirements

Tracking requirements ensure that all cannabis plants and products are
uniquely identified and monitored throughout their lifecycle, from mother
plants and clones to final products and equipment.

- Mother plants
- Clone management
- Product labelling
- Equipment tracking

ii) Supply Chain Management

Supply chain management protocols ensure the traceability and

accountability of cannabis products from material sourcing to distribution,
including robust recall procedures to address any safety or compliance
issues.

- Material sourcing

- Production tracking

- Distribution control

- Recall procedures

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 27. Compliance Requirements

Compliance requirements ensure that operators adhere to regulatory

standards and maintain safety and quality throughout their operations.
These requirements include regulatory compliance, safety and standards
implementation, and robust monitoring and reporting mechanisms.

a. Operator Obligations

Operators are required to comply with all license conditions, reporting

requirements, and inspection protocols, as well as maintain accurate
records to demonstrate compliance with regulatory standards.

i) Regulatory Compliance

Regulatory compliance obligations include adherence to license

conditions, timely submission of reports, cooperation with inspections,
and maintenance of accurate records.

- License conditions
- Reporting requirements
- Inspection cooperation
- Records maintenance
b. Safety and Standards

Safety and standards requirements ensure the implementation of Safety,

Health, and Environment (SHE) protocols, quality assurance measures,
worker safety standards, and environmental protection practices.

- Safety Health Environment (SHE) implementation

- Quality assurance
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 - Worker safety
- Environmental protection

c. Monitoring and Reporting

Monitoring and reporting mechanisms ensure that operators maintain

internal controls for quality monitoring, compliance checking, incident
reporting, and performance tracking, as well as fulfil external reporting
obligations to regulatory authorities and international bodies.

i) Internal Controls

Monitoring and reporting mechanisms ensure that operators maintain

internal controls for quality monitoring, compliance checking, incident
reporting, and performance tracking, as well as fulfill external reporting
obligations to regulatory authorities and international bodies.

- Quality monitoring
- Compliance checking
- Incident reporting
- Performance tracking

ii) External Reporting

External reporting obligations include submissions to regulatory

authorities, reporting to the International Narcotics Control Board (INCB),
incident notification, and compliance documentation.

- Authority submissions

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 - INCB reporting

- Incident notification

- Compliance documentation

28. Enforcement Framework

The enforcement framework ensures compliance with regulatory

standards through a robust system of inspections, audits, and penalties
for non-compliance. This framework includes routine inspections,
compliance audits, investigation protocols, and enforcement actions,
as well as a structured approach to managing violations and corrective
actions.

a. Inspection Program

The inspection program ensures regular oversight of cannabis

operations through routine inspections, compliance audits,
investigation protocols, and enforcement actions to address non-
compliance

i) Routine Inspections
ii) Compliance Audits
iii) Investigation Protocols
iv) Enforcement Actions

b. Non-Compliance Management

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Non-compliance management includes a structured framework for
categorizing violations, imposing penalties, implementing corrective
actions, and providing appeal procedures to ensure fairness and
accountability.

i) Violation Categories
ii) Penalty Framework
iii) Corrective Actions
iv) Appeal Procedures

TABLE 2: SKAKEHOLJDERS, INTEREST AND ENABLERS

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 IX. STAKEHOLDERS
ITEM STAKEHOLDER INTEREST ENABLERS TO THE POLICY
1 Ministry for State - Political oversight and leadership - Provides political will and direction
President - National security considerations - Coordinates inter-ministerial efforts
- International relations management - Ensures alignment with national agenda
- Facilitates international cooperation
2 Ministry of Lands - Plant cultivation control - Controls seed importation and dispersal
and Agriculture - Seed regulation and certification - Provides agricultural expertise
- Agricultural development - Monitors cultivation practices
- Hemp industry development, / - Supports farmer development programs
Exportation of planting material
-Allocation of land
-Phytosanitary protocols

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 -Regulation of Production of animal
feed

3 Ministry of Health - Public health protection - Oversees medical cannabis program

- Medical cannabis regulation - Implements health safeguards
- Health system integration - Monitors adverse effects
- Healthcare professional training - Develops clinical guidelines
- Food safety
- Social Welfare issues
4 Ministry of Trade - Industry development - Facilitates business development
and - Export promotion - Promotes international trade
Entrepreneurship - Investment attraction - Attracts foreign investment
- Economic diversification - Develops value chains
- Quality Control
5 Ministry of - Revenue collection - Develops fiscal framework
Finance - Financial controls

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 - Economic planning - Manages revenue collection- Oversees
- Investment framework financial controls
- Tax and Customs Control (BURS) - Plans economic integration
- Classification of products using the
customs Harmonized System (HS codes)
6 Ministry of - Environmental impact - Ensures sustainability
Environment and - Sustainable practices - Protects resources
tourism - Resource management - Manages impacts
- Waste control - Controls pollution
7 Ministry of - Research and Development -Provides funding for R&D and Innovation
Communications - Innovation and technology and technology transfer
and Innovation development -Conducts research through BITRI
Provides technology incubation and
8 Botswana - Product registration and licensing - Implements regulatory framework
Medicines - Quality control standards and testing - Controls product quality
- Issues licenses

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 Regulatory - Safety monitoring, - Monitors compliance
Authority pharmacovigilance and
- Clinical trials oversight post-market
surveillance
- Import/export control
9 Law Enforcement - Security measures - Enforces regulations
Agencies - Diversion prevention - Prevents illegal activities
- Border control - Controls borders
- Criminal investigation - Investigates violations
10 National -Commercialisation and technology -Conducts Research and Development
Agricultural transfer -Innovation and technology transfer
Research and -Research and development -Commodity based specialised research and
Development innovation centers
Institute

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11 Local and - Community interests - Facilitates community engagement
Traditional - Cultural considerations - Provides local insights
Authorities - Local development - Supports implementation
- Social impact - Manages social impact
12 Private Sector - Business opportunities - Provides investment
- Investment potential - Creates employment
- Market development - Develops markets- Drives innovation
- Economic growth
13 International - Treaty compliance - Provides guidance
Bodies (WHO, - Standards alignment - Sets standards
INCB) - Technical support- Global - Offers support
cooperation - Facilitates cooperation

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X. RISK MANAGEMENT

22. Possible Risks

a. Increased recreational use: Legalization may lead to increased
recreational use, particularly among vulnerable populations.
This risk can be mitigated through strict regulations, public
awareness campaigns, and substance abuse prevention
programs.
b. Illicit market persistence: If the legal market is not well-
regulated and accessible, the illicit market may persist, posing
challenges for law enforcement and public health. The risk can
be mitigated by a dedicated entity that regulates all stages of
cannabis production and use.
c. Market failure: even under best markets management, external
factors may lead to products not performing well. To mitigate
this, there is need for benchmarking in markets that have done
well over a long time.
d. Possible shift from food production for food security purposes
to production of cannabis, the risk can be mitigated by
providing incentives for food production and land gazetting for
different agricultural enterprises.
e. The business may not be accessible to ordinary citizens due to
stringent production requirements, the risk can be mitigated by
encouraging citizen consortiums and clusters. Citizens should
also be encouraged to participate on other stages of the value
chain like processing.

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 f. Lack of research in production and use of cannabis because
there were no regulations for cultivation and use to allow for the
waiver. To mitigate this risk there is need to promote research
and capacity building in the sector.

XI. MONITORING AND EVALUATION

The monitoring and evaluation framework is designed to assess the

performance of the policy, identify challenges, and inform decision-
making. It includes the following components:

a. Objectives of Monitoring and Evaluation

i) To track progress in achieving policy goals and objectives.

ii) To assess the effectiveness of regulatory frameworks and
implementation strategies.
iii) To identify gaps, challenges, and areas for improvement.
iv) To ensure accountability and transparency in the use of resources.
v) To provide evidence-based recommendations for policy
adjustments.

b. Key Performance Indicators (KPIs)

The following KPIs will be used to measure progress:

i) Number of licenses issued for cultivation, processing, and

distribution.
ii) Volume of cannabis produced and exported.
iii) Revenue generated from the cannabis sector.
iv) Number of jobs created in the cannabis value chain.
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 v) Compliance rates with regulatory requirements.
vi) Number of adverse events or incidents reported.
vii) Public awareness levels regarding cannabis regulations.

c. Data Collection and Reporting

i) Data Sources: Data will be collected from license holders,

regulatory agencies, research institutions, and other stakeholders.
ii) Reporting Frequency: Quarterly and annual reports will be
submitted to the National Cannabis Control Authority.
iii) Data Management: A centralized database will be established to
store and analyze monitoring and evaluation data.

d. Roles and Responsibilities

i) National Cannabis Control Authority: Oversee the monitoring

and evaluation process and ensure compliance with reporting
requirements.
ii) License Holders: Submit regular reports on production, sales, and
compliance.
iii) Research Institutions: Conduct independent evaluations and
provide technical support.
iv) Stakeholders: Participate in consultations and provide feedback
on policy implementation.

e. Evaluation Methods

i) Baseline Studies: Conducted at the start of the policy

implementation to establish benchmarks.

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 ii) Mid-Term Reviews: Conducted to assess progress and make
necessary adjustments.
iii) End-of-Term Evaluations: Conducted to measure the overall
impact of the policy.
iv) Independent Audits: Conducted to ensure the accuracy and
reliability of monitoring and evaluation data.

23. Implementation Plan

A guide to activities and functions that are required to make the policy
functional
Table 3: Implementation plan and required Budget

IDATE OF DATE OF ESTIMATED

tCOMMENCEMENT COMPLETION COST
e (BWP)
m
Formulation of December 2024 30 April 2025 400 000
National Cannabis
Policy:
Legislative 1 May 2025 30 June 2025 1 000 000
Amendments
Establish 1 July 2025 30 September 55 000 000
Regulatory Agency 2025
Infrastructure 1 May 2025 31 March 2028 1 billion
Development:
(Laboratories,

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equipment, human
resources, track
and trace systems
e.t.c
Research and 1 June 2025 Continuous 20 000 000
Development
Public Awareness 1 April 2025 Continuous 1 000 000
and Education:
International 1 April 2025 Continuous 1 000 000
Collaboration and
benchmarking

24. Monitoring and Evaluation Activities

The following activities will be conducted as part of the monitoring and

evaluation framework:

a. Baseline Assessment

i) Conduct a baseline study to establish benchmarks for key indicators.

ii) Collect data on current cannabis-related activities, market
conditions, and regulatory compliance.

b. Regular Monitoring

i) Track progress against the implementation plan and KPIs.

ii) Conduct quarterly reviews to identify challenges and recommend
corrective actions.

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c. Mid-Term Review

i) Assess progress halfway through the policy implementation period.

ii) Identify gaps and make necessary adjustments to the
implementation strategy.

d. End-of-Term Evaluation

i) Evaluate the overall impact of the policy on the cannabis sector.

ii) Measure outcomes against the policy’s goals and objectives.
iii) Provide recommendations for future policy development.

e. Independent Audits

i) Conduct independent audits to verify the accuracy of monitoring and

evaluation data.
ii) Ensure transparency and accountability in the use of resources.

26. Reporting and Feedback Mechanisms

The monitoring and evaluation framework includes robust reporting and

feedback mechanisms to ensure continuous improvement:

a. Reporting Requirements

i) License holders must submit quarterly and annual reports on

production, sales, and compliance.
ii) Regulatory agencies must submit progress reports to the National
Cannabis Control Authority.

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b. Stakeholder Feedback

i) Regular consultations with stakeholders to gather feedback on

policy implementation.
ii) Public forums and workshops to engage communities and address
concerns.

c. Dissemination of Findings

i) Publish monitoring and evaluation reports on the National Cannabis

Control Authority’s website.
ii) Share findings with relevant stakeholders, including government
agencies, license holders, and the public.

27. Continuous Improvement

The monitoring and evaluation framework emphasizes continuous

improvement through:

i) Regular reviews of the policy implementation process.

ii) Incorporation of stakeholder feedback into decision-making.
iii) Adaptation of strategies to address emerging challenges and
opportunities.

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