By Michael Sassano
Increasingly, global cannabis markets are moving toward regulated operations and have much to teach each other. Regulators around the world read the same research and developments. However, they all interpret data differently, as cannabis companies and patients do. There is no one-size-fits-all that cannabis pharmaceuticals conform to; medical cannabis markets differ from country to country.
Germany Incrementally Moves Cannabis Needle
Germany — which is long the European leader in cannabis — may not behave as cannabis entrepreneurs want all the time, but it is decidedly moving progressively upwards.
German Cannabis Market Differentiators Prioritize Patients
Legislative twists and turns aside, the current state of products consist of approximately 200 (and growing) flower strains that require European Union-Good Manufacturing Practice (EU-GMP) post-harvest pharmaceutical-grade processing. An additional portion of cannabis herbal pharmacopeia sales come from magistral-prep extracted products. Of course, a segment of pharmaceutical-authorized medicines like Dronabinol, Epidiolex, and Sativex are universally registered medicines in nearly every country.
Insurance-assisted payment for cannabis prescriptions is also unique to German pricing and sales trends. With an estimated 50:50 split of private and insured sales, insurance companies have been pushing back at reimbursements of flower in favor of extracts. Although flower-dominated cannabis sales are standard in emerging markets and for European leaders like Germany and Israel, which have 80% and 90% flower sales, respectively, flower sales in developed markets account for 35% to 45% in developed markets like the United States and Canada. Because German extracts are unfinished, magistral prep oral drops are the dominant extracted product. Additionally, Germany’s extracted cannabis products may only conform to a short list of excipients like medium-chain triglyceride (MCT) oil. Extracts are the fastest-growing segment, but more innovation is needed to help patients find healthier alternatives to smoking flower.
German Cannabis Reformation is a Consumer Access Win
Recently proposed changes to German cannabis may change these current trends. The proposed social clubs may permanently alter flower selection and pricing away from the pharmaceutical markets. Additionally, the proposal to reduce the stigma of medical prescriptions by removing cannabis from a narcotics categorization will increase access for all Germans by untying doctors’ and general practitioners (GPs) hands to more liberally diagnose patients and allow them to try cannabis alternatives for more indications. As most developing EU countries look to Germany, there is much to cheer about by reforming and more work to come.
Australian Cannabis Models International Inclusion
Australia’s market is roughly the same size in sales as Germany’s and is growing more rapidly due primarily to significant differences in how they treat cannabis products and prescriptions.
Australia Has an Edge with GACP Cannabis Flower
Extract sales were the predominant product in Australia until the pandemic, when flower sales surged to overtake extracts by capturing a 70% market share, and some estimates suggest over 500 flower genetics are present. This is mainly because, before July 1, 2023, all Good Agricultural and Collection Practices (GACP) flower was accepted into Australia, making Canadian growers extremely happy. However, as of July 1, 2023, all flower and extracts must be versions of GMP accepted from specific countries, including Canada, South Africa, and European nations. EU-GMP pharmaceutical certification is the international market’s highest specification and quality standard.
Australia’s Cannabis Market Offers More Choice than Germany’s
Unlike Germany, Australia allows finished dosage-form extracts, with products reminiscent of early U.S. and Canadian markets. Through the Australian special access program, finished dosage-form extracts are proliferating, and the flower trend may reverse again. Like in Germany, there are oral drops with MCT, but that’s where the similarities in extract markets end. Australia provides patients with access to oral drops with faster-absorbing excipients, nano-emulsions, sprays, soft gel capsules, hard capsules, creams, vaporizers cartridges, and even emerging edible chews (commonly referred to as gummies in U.S. markets). This diversity of products significantly differentiates Australia from generic magistral markets like Germany. It allows patients to have more dosage choices and enables innovations, from simple positive advancements like improving the tastes of medicines to necessary advances in improving on-set timing and absorption for patients that cannot wait an hour or more for their treatment to work.
Another significant difference between the two markets is how doctors prescribe. Any Australian GP can prescribe cannabis, and there are many specialized clinics and pharmacists. Recently, a trend toward opening U.S.-style dispensaries has also increased access and is reminiscent of what Germany’s second pillar is trying to accomplish. Professional, educated doctors and specialized pharmacies or dispensaries increase educational opportunities and allow patients to treat less severe indications like daily stress, anxiety, or common sleep issues.
Developed Cannabis Market Drawbacks Include Potential Cannabis DUI
One of the main drawbacks to developing a robust medical cannabis market in any country is the risk of patients driving under the influence. While safety is paramount, the tests that determine impairment are often not based on the reality of cannabis consumption and do not measure residual cannabis in the system correctly. The risk of legal repercussions, including driving under the influence, has scared many patients and doctors in Australia away from prescription cannabis, and legislators must realistically update such regulations to account for true or perceived impairment. There is no perfect answer.
The UK Cannabis Market Dawdles Uselessly
The United Kingdom has much to learn from German and Australian cannabis advancements. The leading issue with cannabis access in the UK is that doctors can only prescribe cannabis products if the patient has tried three separate therapies prior. To make matters worse, UK politicians have no plans to advance cannabis reform despite many adults agreeing cannabis should be legal. A framework of unsupportive health authorities and politicians is a stark contrast to Germany and Australia, which may not advance quickly enough for industry professionals and advocates, but are moving forward regardless to allow access for people that find comfort in cannabis for various indications.
Surprisingly, the UK has a similar special access medical process for cannabis as Australia, and they allow extracted products in finished form, with a more developed market mix of 60% flower and 40% extracts plus a small selection of genetics of around 100, primarily due to the small size. This increased usage in Germany’s small but growing extract market highlights that product diversity is welcomed and a key factor in the adoption of alternative delivery methods than flower. Overall, there is little growth expected in the UK. It trails Germany and Australia at around an eight times smaller market size.
Legal Reform and Patient Access Must Remain Central in Future Markets
As these countries’ advocates, patients, and the general population push for logical reforms, progress continues even if many are frustrated with the results. Access reform and developing diverse, reasonably priced product lines will be future development milestones in current and upcoming cannabis markets. New markets are all watching leaders like Germany and Australia, who are, in turn, watching more mature markets like the U.S. and Canada. There is no perfect model, but patient access and decriminalization is a theme prevalent in most countries. Let’s all remain patient and keep pushing!
By Michael Sassano, Founder, CEO, and Chairman of the Board for SOMAÍ Pharmaceuticals, a European pharmaceutical and biotech company centered on manufacturing in Lisbon, Portugal, and globally distributing EU GMP-certified cannabinoid-containing pharmaceuticals.