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                             November 20, 2020

       Lisa Sanford
       Chief Financial Officer
       Emerald Health Pharmaceuticals Inc.
       5910 Pacific Center Blvd, Ste 320
       San Diego, CA 92121

                                                        Re: Emerald Health
Pharmaceuticals Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 6
                                                            Filed November 6,
2020
                                                            File No. 024-10810

       Dear Ms. Sanford:

              We have reviewed your amendment and have the following comments.
In some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response. After reviewing any amendment to your offering statement and
the information you
       provide in response to these comments, we may have additional comments.

       Form 1-A POS filed November 6, 2020

       Dilution, page 28

   1.                                                   We note that you have
removed tables comparing the total number of shares purchased,
                                                        total consideration
paid and the average price paid per share at various levels of
                                                        participation by
participants in this offering and the effective cash cost to officers,
                                                        directors, promoters
and affiliated persons for shares acquired by them. Please revise to
                                                        provide these tables,
or advise. Refer to Item 4 of Form 1-A for guidance.
       Securities Being Offered, page 65

   2.                                                   Please disclose here,
or elsewhere as appropriate, whether you have engaged a transfer
                                                        agent registered
pursuant to Section 17A(c) of the Securities Exchange Act of 1934 to
                                                        perform the function of
a transfer agent with respect to shares of your common stock and,
 Lisa Sanford
Emerald Health Pharmaceuticals Inc.
November 20, 2020
Page 2
       if so, identify such transfer agent.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact David Gessert at 202-551-2326 or Mary Beth Breslin at
202-551-3625
with any questions.



                                                             Sincerely,
FirstName LastNameLisa Sanford
                                                             Division of
Corporation Finance
Comapany NameEmerald Health Pharmaceuticals Inc.
                                                             Office of Life
Sciences
November 20, 2020 Page 2
cc:       Rebecca G. DiStefano
FirstName LastName