By Marguerite Arnold

If 2014 was the year that the recreational cannabis market finally got going in the U.S. and later in Canada, 2019 may well be remembered as the same kind of year on the other side of the Atlantic. Despite the well-connected winks and assertions by many of the top cannabis companies in the world that the ball will finally shift circa 2020 or 2021, the first whiff of real change is afoot this year across the European continent.

But what does European reform most broadly resemble? Earlier in the year, big Canadian execs were frequently in the media expounding that Europe will be “just like” Canada. However, that is clearly not the case. In fact, what appears to be shaping up is that the European market will, in general, be much more like the American market path to reform.

However, even that is also not the whole story. Like the Canadian market, each European “state” domino that now flips into the recreational column will also carry national regulatory punch. If not compliance.

Europe is in effect, set to be a distinct hybrid all of its own.

Why?

Beyond EU regulations, each member state will be setting up its own national (not state) system. This has far more impact on local citizens, as well as policy and regulation setting.

Why Is Europe More Like The US Market?

The states’ rights movement aside, most Americans are impacted by their state rules and regs than federal ones. This is true from civil and consumer rights to market regulations. In Europe, while this is also true within countries themselves, the movement of the issue on a “federal” state-level means that the reforms are being baked in at a higher level earlier.

However, it also means that federal reform is also often far removed from those it affects the most. In Germany for example, patients lost the right to grow their own even as insurance companies were then put on the front line of payment. So far, that has resulted in a large medical market where dronabinol is usually the first drug on offer.

This is very much like the United States where dronabinol was first introduced to the medical community during the AIDS crisis. The failings of the drug are well known, no matter how cheap it is.

Unlike in the US, there is at least more possibility of obtaining insurance coverage for the drug. And unlike the US, certainly at this point, patients who do not like or cannot tolerate dronabinol are faced with few options outside of the black market (still).

Why Does Europe Look Like Canada?

To the extent at this point that both American and Canadian companies are in the money, with well-connected lobbyists at the European level, yes, European reform looks a bit like the Canadian model. What is missing, however, is any country declaring that individuals have a constitutional right to access the drug. Canada also does not have any insurance mandate to cover the drug.