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Karl Lauterbach is planning the legalization of cannabis in Germany through two pillars based on the CARe model. Accordingly, home cultivation and communal cultivation in Cannabis Social Clubs (CSCs) will be part of the first pillar. Pillar 2 envisions regional model projects. How can we imagine Cannabis Social Clubs in Germany?
The framework is taking shape
In the "Law on the Controlled Use of Cannabis and Amendments to Other Regulations" with the latest revision as of April 28, 2023, the first pillar for the legalization of cannabis is proposed. In addition to home cultivation, communal cultivation in cultivation clubs will be allowed, as well as the sell of cannabis and cannabis preparations to their members. The goal is to improve youth and child protection, ensure quality control, and eliminate the black market.
A Cannabis Social Club will be allowed to have up to 500 members. Being a member of multiple clubs remains prohibited. Club members are permitted to purchase up to 50 grams of cannabis per month and 25 grams in a single day. Young adults (individuals between 18 and 21 years old) are limited to a maximum of 30 grams per month. They are also subject to a THC limit of 10%.
For non-members, the provision is limited to the purchase of propagation material such as hemp seeds or cuttings. The monthly purchase of seven seeds or five cuttings in the CSC will be allowed. Young adults can only buy strains that produce less than 10% THC. However, they are also allowed to cultivate up to three female plants.
Documentation challenges for CSCs?
Cannabis Social Clubs will have to meet strict regulations. Concerns have been raised multiple times that CSCs could be overwhelmed by excessive documentation if the currently proposed regulations are adopted.
It starts with the need for meticulous quality control. Each package of cannabis must include a leaflet with weight, harvest date, expiration date, and active ingredient content. The clubs must also be able to demonstrate compliance with limits regarding fertilizer residues and similar substances. So far, so good - there is nothing to object to when it comes to ensuring the best quality.
Furthermore, each club must document exactly where seeds are sourced, how many plants are cultivated, how much cannabis is provided, how much is produced, and so on. This means a significant amount of paperwork for each plant. By January 31, each CSC must report to the authorities how much cannabis and propagation material was produced, provided, and destroyed in the previous calendar year. The respective strains, including CBD and THC content, must be listed. Those who violate the rules may face the revocation of their permit.
Financing cannabis social clubs
In addition, CSCs are intended to be non-profit organizations that are not allowed to generate profits. They are expected to finance themselves not only through the sale of cannabis and propagation material but also through membership fees. This aspect will also be closely monitored, which adds further documentation requirements.
Special requirements for staff and board members
CSCs must also appoint youth protection, addiction, and prevention officers. These individuals must undergo regular training to hold their positions. The aim is to promote prevention and education, ensuring better child and youth protection as well as addiction prevention. Board members of a club are currently required to provide their certificate of good conduct.
CSC properties are to be fenced and secured, including the provision of burglar-proof doors and windows. Additionally, a minimum distance from schools and similar institutions is expected, although precise regulations in this regard will likely be determined at the state level.
Communal consumption, edibles, cannabis restaurants, and future outlook
Communal consumption in CSCs is not provided for in the draft law. The focus is strictly on cultivation and distribution of cannabis. However, this is a point of contention within the government.
The sale of edibles is apparently not allowed. Cannabis will only be permitted in its pure form or as hash, with no information available on more potent forms such as dabs. Mixtures of cannabis with tobacco, alcohol, food, flavors, or similar substances are expected to be prohibited. Therefore, Germany will not see delicious THC vape pens or restaurants where meals are accompanied by joints anytime soon.
A ban on cannabis advertising is naturally included, with requirements for neutral packaging for buds, for example.
The bottom line: Decriminalization, but half-hearted?
Initially, there was talk of coffee shops or dispensaries inspired by the American model. However, all hopes were dashed until we ended up with Cannabis Social Clubs, where even communal consumption may not be allowed. Despite the disappointments and sluggish legislation, credit must be given for at least some progress and changes on the horizon. We can only hope that this snowball effect gains momentum and becomes unstoppable.
