SACCA Code of Compliance -
For Profit Clubs
Last Updated : 17 July 2025
This is a living document — reviewed regularly with input from registered SACCA Members on the Forum.
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SACCA Members suggest edits on the Forum.
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SACCA Members approve suggested edits via comments :
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Comment "YES" or "NO" on the suggested edit to cast your vote.
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Votes are counted after 14 days,
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Majority Vote (55% YES) is required for edits to be approved.
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Suggested edits approved via votes are implemented on this page and updated manually.
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A version history will be posted on the Forum for clear transparency.
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SACCA Members agree to provide feedback, report abuses, and help refine standards over time.
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SACCA encourages cooperation with researchers, lawmakers, and community leaders to build a transparent, trusted industry.
This paper outlines SACCA's formal position on the legal recognition and regulation of Private Cannabis Clubs in South Africa. It is intended to guide and inform policymakers, regulators, and civil society stakeholders on a practical and rights-based framework for cannabis reform.
FOR-PROFIT PRIVATE CANNABIS CLUBS
Legal Grey Area:
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Operate under Section 21 (NPC) structures but behave like commercial entities.
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Revenue-generating, often sourcing cannabis externally.
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Often rely on interpretive loopholes, which may not be constitutionally defendable.
Key Compliance Pathway (Proposed by SACCA):
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Clubs must obtain commercial cannabis through licensed cultivators (e.g. export-grade facilities).
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Clubs must register with SARS and pay relevant TAX/VAT.
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Clear distinction between entertainment/lifestyle services and cannabis access services.
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May require future licensing via DTI, SAPHRA, or Department of Agriculture.
SACCA Support:
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Separate Code of Compliance for For-Profit Clubs
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Guidance to transition toward legally licensed operations (if/when legislation allows)
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Opportunity for future integration into formal cannabis retail frameworks
1. Legal Foundation & Principles
This Code is grounded in South African law and the constitutional rights of adults to privacy and association. SACCA member clubs:
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Operate non-commercially, as private associations, sharing cannabis among adult members.
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Are governed by the right to privacy (Constitutional Court 2018) and freedom of association.
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Recognize the Cannabis for Private Purposes Bill as an evolving legal context and commit to shaping future regulations responsibly.
Clubs operate under the principle that cannabis may be cultivated and shared privately among consenting adults — not bought or sold to the public.
2. Membership & Access
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Clubs are strictly private associations, not open to the public.
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All members must be 18 years or older and verified via valid ID.
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Members must sign a Membership Agreement outlining their rights, responsibilities, and limits under the club model.
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Clubs must have a written constitution or founding document, provide transparent track & tracing, clear governance, and a designated compliance officer or point of contact.
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Members must not resell cannabis received from the club.
3. Cultivation Models
SACCA recognizes two cultivation frameworks to reflect how clubs currently operate:
✅ 3.1 Onsite Cultivation
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Cannabis may be cultivated on private club premises on behalf of members.
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Cultivation quantities must be proportional to the number of active members, using a collective cultivation mandate system (e.g. each member delegates a portion of their right to the club).
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Cultivation must take place in secure, access-controlled environments.
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Onsite cultivation should comply with health and safety measures: ventilation, cleanliness, and pest control.
✅ 3.2 Offsite Cultivation
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Individual members or assigned growers may cultivate cannabis privately and contribute it to the club.
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Clubs must maintain a Cultivation Declaration Log for all offsite sources, including:
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Grower/member name or ID
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Strain name
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Grow location (private and confidential)
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Method (e.g. organic, indoor, greenhouse)
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Harvest date
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Offsite growers must sign a Cultivation Declaration Form affirming the cannabis is for private member use only.
4. Distribution Protocol
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Cannabis must be shared exclusively among registered members, based on their delegated share of cultivation.
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No public trade, advertising, or resale is permitted under any circumstances.
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Clubs must record each distribution event in a private log (date, member ID, strain/amount).
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Cannabis should be packaged in discreet, labelled, and child-safe containers, including:
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Strain name
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Batch/harvest date
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THC/CBD estimate (if available)
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5. Product Safety & Integrity
Clubs must take reasonable steps to ensure product quality and safety:
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Cannabis should be properly dried, cured, and free of mold or pests.
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Edibles, oils, or infused products must be:
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Clearly labelled with estimated potency/dosage
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Stored securely and out of reach of minors
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If possible, clubs should use third-party or in-house testing to verify cannabinoid content and screen for contaminants.
6. Responsible Use & Club Spaces
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Clubs may provide onsite consumption areas, as long as:
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Access is restricted to 18+ members only
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These areas are discreet, ventilated, and compliant with local bylaws
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Harm reduction is promoted and intoxication limits are respected
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Clubs should actively educate members on responsible use, dosage, interactions, and health impacts.
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No illicit substances may be consumed or sold in club spaces.
7. Education & Community Engagement
SACCA clubs are encouraged to:
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Host educational workshops, talks, or member briefings.
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Promote responsible, stigma-free dialogue about cannabis use.
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Engage with civil society, researchers, and traditional healers where appropriate.
8. Record-Keeping & Confidentiality
Each club must maintain:
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A Member Registry (confidential and secure)
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A Cultivation Log (onsite & offsite grows)
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A Distribution Log (date, quantity, strain)
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Incident logs if needed (e.g. safety issues, violations)
All records must be stored securely and used only for internal accountability, unless legally required by a court.
9. Prohibited Practices
Clubs violating the following may be removed from SACCA:
❌ Selling or advertising cannabis publicly
❌ Supplying to or involving minors
❌ Operating without member agreements
❌ Failing to verify member identity/age
❌ Hosting public cannabis events without membership controls
❌ Allowing other illicit substances on premises
10. Compliance Oversight & Evolution
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Clubs agree to self-audit annually using SACCA’s toolkit.
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SACCA may request peer reviews or provide compliance support.
✅ Club Commitment
As a SACCA member, your club acknowledges and agrees to:
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Operate safely, transparently, and within private-use boundaries
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Promote inclusivity, wellness, and respect for South African cannabis heritage
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Contribute to shaping a fair and representative national cannabis framework