Comparative analysis of cannabis regulation models in Europe

Research Period



European Commission, DG Migration and Home Affairs.



Mafalda PARDAL

In collaboration with: Tom Blickman (Transnational Institute), Xabier Arana (Universidad del Pais Vasco), Heino Stöver (Frankfurt University of Applied Sciences), Dirk Korf (Bonger Institute, University of Amsterdam), Vibeke Asmussen Frank (Centre for Alcohol and Drug Research / Department of Psychology and Behavioural Sciences, Aarhus University).


Cannabis; regulation models; Cannabis Social Club; Belgium; Europe; comparative analysis


This research project is part of a larger study called ‘New Approaches in Harm Reduction Policies and Practices’ (NAHRPP) and forms a particular work package which is carried out by the Institute of Social Drug Research (ISD). The ISD is also involved in another work package of this project, namely ‘Cannabis self regulation in a harm reduction perspective’.

Background and goals

Dissatisfaction with the current cannabis regime gives rise to new ideas. In several countries in Europe, local and regional authorities are looking at regulation, either pressured by grassroots movements – in particular the Cannabis Social Clubs (CSCs) – or due to the involvement of criminal groups and public disorder. In the Nether­lands, 60 municipalities have signed the Joint Regulation manifesto to regulate cannabis cultivation and the sup­ply of the "back door" of coffeeshops. In Copen­­hagen (Den­mark), and Ber­lin, Bremen, Frankfurt-am-Main, Hamburg and Cologne (Ger­many), local au­thorities pro­mote coffee­shop-like dispen­saries with a regu­lated supply. In Cata­lo­nia and the Basque Country (Spain) and towns such as San Sebastian (Basque Country) and Geneva, Zürich, Basel and Bern in Swit­zer­land re­gional and local authorities want to allow Cannabis Social Clubs, while in Belgium CSCs are gaining momentum. Outside Europe, regulation models exist in Uruguay and the U.S. states of Washington, Colorado, Oregon and Alaska, while it is expected that in California (U.S.) and Canada regulation models will be de­veloped during the project period. Elements of these non-European regulation models will also be taken into account.

The main objective of the project is to provide a knowledge base on possible cannabis regulation models and allow interested local authorities to share best practices in cannabis regulation in order to build future cooperation as a means to reduce the negative consequences of illicit drug markets on individuals and society and improve effectiveness of law enforcement activities aiming at the prevention and reduction of the number of drug-related offences.


A SWOT (Strengths, Weaknesses, Opportuni­ties, and Threats) analysis of different cannabis regulation models in six European countries (Belgium, Denmark, Germany, Spain, Switzerland and the Netherlands) where proposals for regulation of the cannabis market are relevant will be conducted – drawing on a previous SWOT analysis by Decorte, T. (2015). The benefit of a SWOT analy­sis is that it will present the issues in a practical overview for local authorities that con­template regulation models. The aca­demic researchers will decide on the research protocol and will focus on i.e. acceptability, feasibility, manageabil­ity, transparency and health/security/financial outcomes.

Expected output

The out­comes of the research will be published in a series of online country reports and will be brought together in one final report which will include a compara­tive analysis, as well as a concise briefing paper, describing the history and current state of cannabis regulation models and/or applications in the specific countries, with an analysis of possible or existing strengths and weaknesses in terms of implementation and outcomes, and of opportunities and threats the models are providing and facing within the country and internationally. The outcomes will feed into a confer­ence of local European authorities and will be presented to European institutions such as the EMCDDA and Europol.