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Global Cannabis Rules Are Changing. Which Medical Markets Can Still Deliver Returns?
By Guest Contributor ·
Regulation has always been cannabis’s Achilles heel. In 2026, we don’t need to look backward to feel the pain of regulatory fluctuation. It’s happening in real time, country by country.
Entrepreneurs keep pushing boundaries, exposing gaps regulators never anticipated. Powerful factions keep working against cannabis, and regulators keep overreacting to what is, on balance, a positive shift. Access for all is cannabis’s mantra. Responsible use has to be part of that mantra too, even though decades of grey and legal markets worldwide show remarkably few serious negatives. The job of any regulator should be simple: build a legal, safe channel that pulls patients out of the grey market. Simple to say. Hard to do.
By Michael Sassano, founder and interim CEO of SOMAÍ Pharmaceuticals, a Portugal-based manufacturer of medical cannabis products.
USA: Culture Shifts Faster Than Law
America has two decades of regulatory lessons to draw on, and still can’t get federal reform done, even under a pro-cannabis administration. The powers capable of bottling up reform see a real threat in cannabis’s rise.
The numbers explain why. A recent Gallup poll found 17% of US adults smoke cannabis and 15% consume edibles, against just 11% who smoke cigarettes. That’s a considerable shift. A separate 2024 Carnegie Mellon study found 17.7 million Americans use cannabis daily or near-daily, versus 14.7 million daily drinkers. This is the first time cannabis has overtaken alcohol on that measure.
That’s opportunity and threat, wrapped together, for big beverage. Big alcohol saw the numbers dropping and moved. Intoxicating hemp drinks were taking real shelf space, and that was a red line. So alcohol lobbyists got a hemp THC provision inserted into the bill that ended the 2025 government shutdown, signed into law that November, one that would effectively ban most hemp-derived THC beverages and edibles a year later. Trump has now signed a further bill pushing that effective date back to December 11, 2026, and the fight isn’t over. That’s pure power politics, but it also shows consumers want what these products deliver, and that legal cannabis needs more access points, not fewer.
Globally, markets are bracing to see whether product flows to the US, or US products flow out, once DEA rescheduling finally lands.
Canada: Dumping Without Consequence
Canadian regulators aren’t doing much about Canadian growers dumping into EU markets, nor tightening the lax framework governing local producers. Regulators from Israel to Australia to the EU are moving the other way, favoring protection of internal production over low-priced imports. Canada is increasingly the odd one out, and that gap will get more expensive the longer it’s ignored.
UK: Slow-Walking Access on Purpose
UK regulators are backing local bulk API manufacturing over finished-dose EU-GMP product, and getting oil into the country keeps getting harder. There’s a real sense of deliberate friction here. Allowing UK-made gummies while blocking EU-GMP gummies is one clear example of a standard that ignores what real medical-grade production looks like.
The potency data backs it up. Products above 22% THC now account for 85% of UK prescription items dispensed so far in 2026, up from 75% in 2025. Narrow the lens further, and the 25%-plus bracket alone accounted for the majority of 2025 items at 53.6%, and is on track for roughly two-thirds of 2026 volume. Potency keeps climbing as a political flashpoint, and a statutory THC cap has been under discussion since 2023 without being legislated, leaving the market in limbo.
Regulators have also started checking the GMP certificates of growers directly, rather than relying on paperwork passed through the supply chain. That’s likely a prelude to cutting down GMP washing, meaning foreign product repackaged and sold as EU-GMP without the standard actually being met. For operators, investing directly in UK infrastructure may be the only durable answer.
Germany: Tightening the Tap After Building the Market
Germany cut insurance reimbursement for flower entirely and added a mandatory six-month try-other-therapies-first rule before extracts get covered. The law affects roughly 65,000 patients who now need to run through an approved product, Sativex, Epidyolex or Canemes, before flower or magistral extracts qualify.
GMP washing is front and centre in this story. Years of open access built the low-priced environment patients now expect, and putting that genie back in the bottle will create a real shortage over the next few years. To make it worse, foreign producers aren’t held to the same scrutiny German regulators apply to local EU-GMP groups, which puts homegrown manufacturers at a real disadvantage.
The German cultivation cap is also coming, and expect two to three months of disruption while the system resets, with EU-GMP washing likely to try to sneak through the cracks of that transition.
Australia: Attacking the Wrong Target
Australian regulators are on a constant zigzag, attacking advertising and over-prescribing rather than addressing the underlying market structure. Hammering doctors and clinics has kept the industry in disarray through a period of massive price compression that finally looks to be bottoming out.
That might be healthy long-term. But with roughly one in five Australians still buying from the grey market and limited evidence of adverse reactions, the enforcement balance is off. A cap on imports to protect local producers keeps getting floated, and may well happen.
Australia may end up the last bastion of GMP washing and global product dumping. Most other major markets now require true EU-GMP standing or are actively moving to close that gap, and Australia’s looser standard is increasingly the exception rather than the norm.
Portugal: Winning the Export Race, Losing the Trust
Portugal’s exports hit 66,305 kg in just the first half of 2026, more than 80% of all of 2025’s total, which itself topped 79 tonnes after 2024 nearly tripled to 31,188 kg. By any measure, Portugal is Europe’s export engine, and growth is still accelerating.
But the country is still living down the embarrassment caused by a handful of bad actors, and that ripple effect hasn’t faded. Good regulatory oversight is the right call, but competitors are exploiting the moment, and buyers are increasingly nervous about Portuguese exportability, drifting toward less-scrutinized jurisdictions instead. That’s a double-edged sword weakening investability in a market that otherwise has every structural advantage. Bigger compliance and regulatory teams are now a must for anyone investing here.
Switzerland: Waffling Between Two Models
Switzerland, one of the oldest and most progressive cannabis regimes in Europe, keeps waffling between medical expansion and adult-use pilot clubs. Going fully adult-use would be a genuine EU shock, since most of the region still prefers medical, but internal Swiss costs remain high enough that the economics may simply not work.
Poland: A Pre-Election Freeze, With Decriminalization Stalled
Poland keeps slowing down script access by favoring brick-and-mortar clinics over teleclinics. The magistral pathway remains dominated by the few operators holding full dossiers and true EU-GMP standing, a high bar that keeps the market narrow even as demand grows.
Poland has now entered a pre-election period, and the next 9 to 12 months likely bring no significant changes to the medical cannabis sector, unless a move looks politically useful for attracting support ahead of the parliamentary elections. One of the real constraints on the market is the extensive authority of the Patient Ombudsman, whose actions are often shaped by political considerations. That mostly hits prescribing practices and patient access to prescriptions; it doesn’t touch product registration or distribution, so entry rules for the market remain strong.
Separately, the legislative process to decriminalize small-amount possession for recreational use and allow limited home cultivation remains suspended, with no meaningful progress currently expected.
Italy: The Deliberate Late Mover
Italy still hasn’t opened its doors. The market keeps expanding, but growth is capped by slow regulatory evolution around a few live debates: revising the 2015 Ministerial Decree to simplify fragmented prescription pathways; unifying reimbursement under the National Health System, which currently varies sharply by region; and reconciling zero-tolerance drug-driving law with the rights of legitimately prescribed patients.
The sharpest fight is over CBD. Rome has repeatedly tried to classify oral CBD extracts as narcotics, and administrative courts have repeatedly suspended those decrees. The final call now sits with the European Court of Justice on free movement of goods. Italy will stay a late mover, cautious and incremental, until the broader EU picture forces its hand.
Spain: Grey Market by Design
Spain has some of the hardest rules for legal medical cannabis anywhere in Europe, while openly tolerating the grey market through social clubs. Most of the product moving through Portugal ends up destined for Spain, and regulators keep asking why. The answer is obvious: legal social-club pathways exist alongside a medical program too hard to access, so demand routes around it instead of through it.
Greece: Playing Both Sides of EU Law
Greece blocks pharmaceutical cannabis imports from other EU countries under Law 4864/2021, while continuing to export freely. That’s a clear conflict with EU single-market rules, and continuing down this protectionist path risks damaging Greece’s standing with the pharmaceutical investors it’s trying to attract.
What to Watch Through the End of 2026
Most smaller countries are still fighting internal battles over how to regulate use and production. Many are embracing production while failing to build a safe domestic market to match. The general sentiment is that once the US opens up, many of these countries will follow.
Regulatory chaos hasn’t slowed cannabis sales, and it won’t. Countries that expand access keep growing their taxable base while cutting into the grey market. That pattern isn’t changing.
A few predictions for year-end: sales keep growing regardless of the noise; Germany works through its cultivation-cap shutdown and tightens GMP drying rules; France pushes forward with its own access framework; Portugal holds its lead despite the current trust gap; the EU opens formal talks on protectionist measures against non-EU-GMP dumping; and more countries keep opening access to patients, one flawed framework at a time.
Editor’s note: The figures and legislative developments cited in this commentary draw on the following reports. Market assessments and forecasts are the author’s views.
Guest Contributor
September 23, 2026