Germany Reschedules Cannabis, Uncaps Domestic Production and Opens Social Clubs Across Country

Updated: May 2024

Germany’s first chapter of its journey to an adult-use market premiered on April 1, 2024.

In line with the country’s initial announcement of an adult-use market back in April of 2023, this “first pillar” of legislation includes removing cannabis from the country’s Narcotics List and scheduling it as any other prescription drug. This move makes it easier for patients to access plant medicine by eliminating cumbersome supply chain restrictions and reducing the stigma medical doctors may feel toward the plant. It also makes it easier for researchers to learn more about the plant, uncaps domestic production, and in a nod to adult use, allows the establishment of cannabis social clubs.

The country’s cannabis club structure is similar to Spain’s, requiring members to pay a membership fee in exchange for access to the plant and allowing adult-use consumption on-site. The clubs are state-controlled and not-for-profit. They start operating on July 1, 2024.

Additionally, as of April 1, individuals can now grow up to three plants on their premises.

Lawmakers are now working on the “second pillar” of cannabis legislation which is expected to eventually authorize a limited number of dispensaries in certain cities for a five-year trial period. During that time, officials and regulators will study the impact of these shops on the country’s consumption habits and black market activity before determining the next step in nationwide cannabis legalization.

Germany’s Future Cannabis Supply

Starting April 1, domestic production of cannabis in Germany is legal for anyone to partake.

For the last seven years, domestic cannabis cultivation for the country’s medical market has been limited to three federally approved suppliers. Because of this production cap, a supply gap of as much as 80% has been filled with imports primarily from Canada, Portugal, and the Netherlands.

Scaling domestic production to support this new market is expected to take years. In the meantime, the adult-use market is projected to increase product demand 7-10X, creating further reliance on imports. This demand will continue to be filled by imports from the Netherlands, Canada, and Portugal, emerging players in Macedonia, Malta, and Czech, as well as low-cost suppliers from Colombia.In keeping with its intention of building a pharmaceutical-grade system in the EU and the United Kingdom, all cannabis flower in Germany, whether imported or grown domestically, is required to be grown in GACP-validated facilities and processed post-harvest in GMP-validated facilities.

Germany Cannabis Exporting/Importing Requirements

Operators exporting cannabis flower to Germany, as well as domestic producers, have principally relied on ionizing radiation technologies like X-ray, gamma, or e-beam to meet the strict microbial compliance regulations detailed in the European Pharmacopoeia, which currently governs the EU cannabis regulatory framework. Not only are these treatments expensive, but they alter the molecular structure of the plant, creating free radicals and potentially unknown medical consequences.

Germany has taken a strong stance against both domestic and imported cannabis flower that has been treated with ionizing radiation. Producers that do use ionizing radiation are required to secure an AMRadV license for each strain treated with ionizing radiation. This license can take up to 12 months to receive and costs €4,500 per strain.

Separate from this license, the country also requires all exporters and domestic producers to follow EU GACP (Good Agricultural and Collecting Practice) and EU GMP (Good Manufacturing Practice) guidelines.

RFX Radio Frequency Microbial Treatment

Choosing non-ionizing technology like Radio Frequency (RF) to achieve microbial compliance is the most cost-effective solution for those looking to export cannabis to Germany. Radio Frequency is a non-ionizing radiation technology that ensures cannabis flower meets microbial compliance, doesn’t change the molecular structure of the plant, and therefore does not require AMRadV certification. Ziel’s RF technology has achieved EU GMP validation as a microbial control solution for cannabis flower and operating commercially in Europe. As a post-harvest treatment, RF can seamlessly integrate into EU GMP-certified operations. 

Ziel’s RFX machine has the largest throughput of any microbial control solution on the market today, making it ideal for cultivators looking to process large volumes. Using Ziel’s Business Case Calculator, cultivators can determine how much revenue the RFX will recover for their business by increasing harvest yields, avoiding compliance failure, and eliminating the need to send contaminated product off to extraction. This, in turn, also eliminates the subsequent costs for retesting. Cultivators interested in exporting to Germany are also encouraged to add up how much they’d spend in time and money on AMRadV licenses for each of their strains treated with ionizing radiation, an expense that’s nonexistent with Ziel’s RF technology.

To better understand just how much money the RFX can save a cultivation, explore the example below. Using a wholesale selling price of €4,000/kg, if a processor failed 20% of their annual harvest, they would be forced to retest, treat again, or offload the failed product to a manufacturer for a deep discount—as much as 90%, or €400. This snapshot shows the revenue a cultivator will recover within the first year of using the RFX, based on recovering 20% of the harvest that fails microbial testing on 1,000 kgs of dry flower harvested per annum.

In this example, more than €720,000 of revenue is recovered in the first year alone—more than double the cost of the RFX!

The Future of Germany’s Cannabis Market

As Germany spends the next five years monitoring its new adult-use market and the limited number of dispensaries it’s anticipated to license, microbial compliance regulations are expected to become clarified with the release of a German monograph designed specifically to address cannabis.

Cannabis cultivators looking to join Germany’s market must have a mold treatment solution in place. Radio Frequency is the safest and most cost-effective option on the market, requiring no additional licensing and operating in alignment with EU GMP processing guidelines.If you’re looking to streamline your product’s entry and position in the German cannabis market, let’s talk. Ziel’s RFX offers the largest throughput of any technology currently available and boasts a >99% pass rate for regulatory compliance. Together, we can get you set up to leverage what’s anticipated to be one of the largest cannabis markets in the world. Get in touch with Ziel today.