This article sets out how cannabis law is written today in a number of countries. It also covers what research on the results of these laws can and cannot show. Finally, it explains why news reports so often use the wrong words for these laws.
Part 1 covers the United Nations drug treaties and five legal models. It then looks at the laws of Uruguay, Canada, four European countries and the United States. Part 2 covers Thailand, Laos, Cambodia and Vietnam, the evidence on outcomes, and how to judge what may come next.
1. Before you read
Members of this forum live under very different laws. In some places cannabis is a regulated product. In others, possession can mean years in prison.
Nothing here recommends a course of action. Nothing here suggests that reform is bound to happen, or that prohibition is irrational.
Most facts here come from encyclopaedic reference pages about each country’s law. The original article does not name these pages. Pages like these go out of date quickly. So read every status below as “what the reference pages said”. It may already have changed.
Two stronger sources take priority where they cover the same point. The first is a 2025 report by the European Union’s drug agency. The second is a law firm’s analysis of a 2025 United States law on hemp. Both are listed under References.
What to do: before you rely on any rule in this article, find the official text in your own country. Check the date it came into force.
2. The international treaties behind national cannabis laws
The 1961 convention and what it requires
Almost every national cannabis law is written to fit the Single Convention on Narcotic Drugs of 1961. This United Nations treaty requires countries to “limit exclusively to medical and scientific purposes the production, manufacture, export, import, distribution of, trade in, use and possession of drugs”.
The treaty sorts drugs into lists called schedules. Each list has its own level of control. From the start, cannabis, cannabis resin, extracts and tinctures were in Schedule I. Cannabis and resin were also in Schedule IV, the most restrictive list.
Two later treaties extended the system. They are the 1971 Convention on Psychotropic Substances and the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances.
One detail is often missed. The treaties’ penalty clauses are unclear on whether possession for personal use must be a crime. Decriminalisation works inside that unclear space. That space does not leave room for licensed shops selling to the public, because the treaties still limit trade to medical and scientific use.
Who runs the system, and the December 2020 vote
Two UN bodies run the system. The Commission on Narcotic Drugs, a committee of member states, moves substances between schedules. It acts on findings from the World Health Organization. The International Narcotics Control Board caps each country’s legal production at the medical need that country declares.
On 2 December 2020, the Commission removed cannabis and resin from Schedule IV. The change took effect in April 2021.
What did not change matters more. Cannabis stayed in Schedule I. The duty to limit it to medical and scientific purposes stayed in place. The vote eased one classification. It did not allow recreational markets.
What to do: when a headline says a UN vote “legalised” cannabis, check what actually changed. The 2020 vote only moved cannabis out of Schedule IV.
3. Five legal models that news reports often mix up
News reports often say a country has “legalised” cannabis when it has done something much narrower. The difference decides three things. Can a person buy? Can a business sell? Is a visitor committing a crime?
The table shows five models. Under decriminalisation, possession stays illegal, but a small amount brings a fine or minor penalty instead of a criminal charge. Under medical access, patients with a prescription can obtain specified products.
| Model | What changes | What stays illegal |
|---|---|---|
| Decriminalisation | Possession below a set amount becomes a minor offence | Growing for supply, supply, sale |
| Medical access | Patients with a prescription obtain specified products | Possession without a prescription; recreational sale |
| Home cultivation | A household may grow a few plants for itself | Sale; usually possession in public |
| Non-profit associations | Members grow together and receive limited amounts | Commercial sale; supply to non-members |
| Commercial adult sale | Licensed, taxed businesses sell to adults | Unlicensed sale; sale to minors |
Translator’s note: Thailand’s current rules do not fit one box neatly. Since 26 June 2025, cannabis flower may be sold only against a PT 33 prescription. That is closest to the medical access model. Part 2 gives the details.
What to do: for each country you deal with, write one line each on what a person may buy, grow and sell there. This tells you which model applies and what is still a crime.
4. Uruguay and Canada
Uruguay: registration, small amounts, residents only
Uruguay’s Law 19.172 was signed on 20 December 2013 by President José Mujica. It made Uruguay the first country in the modern era to legalise cannabis. Pharmacy sales only began in 2017, through sixteen authorised pharmacies.
To buy legally, a person must meet four conditions:
- be a Uruguayan citizen or permanent resident;
- be at least 18;
- be registered in a national database;
- choose one of three routes.
The three routes are:
- Pharmacy purchase: up to 40 grams a month.
- Home growing: up to six plants per household, with a harvest of no more than 480 grams a year.
- Club membership: a club has 15 to 45 members and may grow up to 99 plants.
Visitors without permanent residence may not buy.
Canada: a licensed commercial market
Canada’s Cannabis Act, introduced as Bill C-45, took effect on 17 October 2018. Medical access already existed under regulations from 2001.
The federal government licenses producers. Each province decides how cannabis is distributed, what kind of shops are allowed and the minimum age. The minimum age runs from 18 in Alberta to 21 in Quebec.
Adults may carry 30 grams in public and grow four plants. Quebec and Manitoba announced they would not allow home growing. Products are sold in plain packaging, and advertising is prohibited.
Two different goals
Uruguay chose registration, small amounts and no profit-driven retail. Its aim was to keep cannabis contained. Canada chose a licensed commercial market. Its aim was to replace a large illegal market.
What to do: before you travel, check whether a country’s law covers visitors at all. Uruguay’s does not.
5. Europe: what passed and what is only proposed
Germany
Germany’s Cannabis Act passed the Bundestag, the lower house of parliament, on 23 February 2024. The vote was 407 to 226, with four abstentions. It cleared the Bundesrat, the chamber of the federal states, on 22 March 2024. It took effect on 1 April 2024.
Adults may carry 25 grams in public and keep 50 grams at home. They may grow three plants.
From 1 July 2024, cultivation associations became legal. An association may have up to 500 members. Each member may receive 50 grams a month.
The planned second stage, commercial sale, was left out of the law. According to the reference pages, pilot projects were discussed but none were enacted. In spring 2025 the government said it would review the Act that autumn. A first interim evaluation report (EKOCAN) was published in autumn 2025. No decision to change the Act as a result could be confirmed here.
Malta
Malta’s parliament passed its personal-use law on 14 December 2021. It took effect on 18 December 2021. A public body oversees it: the Authority on the Responsible Use of Cannabis.
- Adults may carry 7 grams in public.
- Carrying up to 28 grams brings a fine of 50 to 100 euros, with no criminal record.
- A household may store 50 grams and grow 4 plants.
- Non-profit associations may supply each member 7 grams a day and 50 grams a month. An association may have at most 500 members.
- Sale for profit is barred. Smoking in public is banned.
Luxembourg
Luxembourg’s law passed in June 2023 and took effect on 21 July 2023. A household may grow four plants and consume cannabis at home.
Possessing, using, transporting or buying cannabis in public remains prohibited. Penalties are reduced for amounts up to three grams.
A state-run shop network has been discussed. It remains a proposal, not law. A 2018 pledge of full legalisation was never carried out. Medical cannabis was approved in June 2018.
Czech Republic
The Czech rules changed on 1 January 2026, so dates matter here. Decriminalisation dates from 1 January 2010, when the new Criminal Code, Act No. 40/2009 Coll., took effect. Possessing a small amount for personal use became a minor offence rather than a crime.
Before 2026, the courts treated more than 10 grams of dried cannabis as the line for a crime. This came from a Supreme Court opinion, Tpjn 301/2013, dated 13 March 2014.
Medical cannabis has been legal since 1 April 2013. Patients may currently receive up to 180 grams a month.
Since 1 January 2026, Act No. 270/2025 Coll. applies to people over 21:
- They may keep up to 100 grams at home and 25 grams elsewhere.
- They may grow up to three plants without a permit.
- Going above these limits is an administrative offence, punished by a fine rather than a criminal charge.
- More than 200 grams at home, more than 50 grams elsewhere, or more than five plants is a crime.
Commercial sale is still not allowed.
Translator’s note: none of these four countries allows commercial sale of cannabis for non-medical use. Associations grow for their own members. So these laws do not create a legal buyer abroad for Thai flower sold for non-medical use. Importing medical flower is a separate, licensed route. See Five Medical Flower Markets Compared and The Export Pathway. Also check the Thai export rules in Part 2.
What to do: if a European contact offers to buy Thai flower for “legal recreational sale”, ask which licence in their country allows it. Under the four laws above, none does.
6. The United States
Federal law and state law pull in different directions
The Controlled Substances Act of 1970 is the federal law that ranks drugs in five schedules. Schedule I is for drugs with high abuse potential and no accepted medical use. All cannabis was in Schedule I until April 2026.
In April 2026, two groups moved to Schedule III, a less tightly controlled list. The first is marijuana in drug products approved by the Food and Drug Administration (FDA). The second is marijuana covered by a state medical-marijuana licence. All other marijuana stays in Schedule I. (“Marijuana” is the term used in US federal law.) The case study below gives the details.
States moved earlier:
- Oregon decriminalised in 1973.
- California allowed medical use by a public vote in 1996.
- Colorado and Washington legalised adult use in 2012.
According to the reference pages, 24 states and the District of Columbia allow adult use. Between 39 and 40 states allow medical use, depending on how the count is made.
Federal law still applies inside those states. In 2005, in Gonzales v. Raich, the Supreme Court ruled that federal drug law still applies where a state has legalised. So federal restraint has been a policy choice, not a legal right.
Two examples show how easily that restraint can change:
- The Cole Memorandum of 29 August 2013 told federal prosecutors not to target businesses that followed state law. It was withdrawn on 4 January 2018.
- A budget clause first passed on 30 May 2014 stops federal money being spent against state medical programmes. Congress must renew it every year.
What to do: when you read that cannabis is “legal” in a US state, remember that federal law still applies there.
Hemp: the definition changes in late 2026
The farm bill signed on 20 December 2018 removed hemp from federal control. Hemp was defined as cannabis with no more than 0.3% delta-9 THC by dry weight. Delta-9 is the main intoxicating form of tetrahydrocannabinol (THC). “Dry weight” means the percentage is measured on dried plant material.
The rule measured only one molecule. So an industry grew around other intoxicating forms of THC that the definition did not count. These are isomers: the same atoms, arranged differently.
A federal spending bill signed on 12 November 2025 closed that gap. According to the law firm’s analysis, the new definition works like this:
- Hemp products may contain no more than 0.4 milligrams of total THC per container. “Total THC” means delta-9 THC and its acid form, THCA, counted together with other cannabinoids that have similar effects. It is not delta-9 alone.
- Cannabinoids made outside the plant are excluded.
- Products marketed as having effects similar to THC are excluded.
The bill set the change for 12 November 2026, one year after signing. A later law, H.R. 6500, signed on 2 September 2026, moved the total-THC standard and the 0.4 milligram per-container limit to 11 December 2026. The exclusion of cannabinoids that the plant cannot produce naturally still takes effect on 12 November 2026. The analysis expects most current cannabidiol (CBD) products to exceed the new limit.
Translator’s note: if you grow hemp in Thailand, or make CBD products with US buyers in mind, the old rule no longer protects you. A product that met the 0.3% rule may fail the new per-container limit. Before you sign a contract or ship, ask the buyer to confirm in writing that the product meets the new US definition, which applies in full from 11 December 2026. Also check what may leave Thailand at all: see What Can Actually Leave Thailand as Hemp.
Case study: the 1988 Young ruling
Who: Francis L. Young was the chief administrative law judge of the Drug Enforcement Administration (DEA), the US federal drug agency. An administrative law judge works inside a government agency. He hears evidence and recommends a decision.
What happened: a petition asked the DEA to move cannabis to a different schedule. After a long hearing, Young ruled on 6 September 1988. He found that cannabis did not meet the legal criteria for Schedule I. He recommended moving it to Schedule II, a list for drugs with accepted medical use but high abuse potential.
His most quoted line calls cannabis, in its natural form, “one of the safest therapeutically active substances known to man”.
That line needs its context. It compared acute toxicity, meaning harm from a single large dose. It was based on the evidence put before him. He also added a condition that is usually left out: cannabis could be used safely within a supervised routine of medical care.
Low acute toxicity is not the same as clinical safety. A substance that is hard to overdose on can still cause dependence. It can still cause psychiatric effects in vulnerable people and effects on the heart and blood vessels. It can also interact with other medicines.
Result: Young could only recommend. DEA Administrator John Lawn, the head of the agency, overruled him. In 1992 a later Administrator, Robert Bonner, set out five criteria for “accepted medical use”. In 1994 the federal appeals court in Washington, D.C. confirmed that the agency may overrule its own judge (Alliance for Cannabis Therapeutics v. DEA, 15 F.3d 1131).
Lesson: the same agency that opposed rescheduling also made the final decision. A judge’s recommendation is not the outcome.
What to do: read the “safest substances” quote as a statement about overdose risk only. Do not use it as proof that cannabis is safe for a patient. When you read that an official “recommended” a legal change, look for the final decision and its date.
What has happened since (as of mid-October 2026)
The DEA issued a final rule on 22 April 2026 and published it on 28 April 2026. It moved two groups to Schedule III:
- marijuana in FDA-approved drug products;
- marijuana covered by a state medical-marijuana licence.
All other marijuana stays in Schedule I.
A hearing on moving the rest to Schedule III ran from 29 June to 15 July 2026. It was held before Derek C. Julius, the DEA’s current chief administrative law judge. On 29 September 2026 he paused the case. He wanted to consider adding a new report to the record. The report comes from the Government Accountability Office, the audit office of the US Congress. No date is set for a decision.
Translator’s note: Thai law does not follow US scheduling. None of these US changes alters the rules in Thailand.
What to do: a client or supplier may say a US rescheduling decision now allows something in Thailand. Do not take that on trust. Check the Thai rule itself.
This article is part of the Asiannabis Community educational series on cannabis law and policy. It is general information, not legal advice. Cannabis law changes quickly. Check the current position in your own country before you act on anything here. Content is for educational purposes within jurisdictions where cannabis is legally permitted.
References for Part 1
Main sources
- Encyclopaedic reference pages on the legal status of cannabis in Uruguay, Canada, Germany, Malta, Luxembourg, the Czech Republic and the United States. The original article does not name them or give links.
- European Union Drugs Agency (EUDA), European Drug Report 2025: Trends and Developments.
- A law firm’s analysis of the hemp provisions in the US federal spending bill signed on 12 November 2025. The original article does not name the firm. A verified summary of the same provisions: Perkins Coie, “Shutdown Legislation Brings New Hemp Rules”.
Treaties, laws, decisions and court cases named in the text
- Single Convention on Narcotic Drugs, 1961; Convention on Psychotropic Substances, 1971; United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, 1988.
- Commission on Narcotic Drugs vote of 2 December 2020 (effective April 2021).
- Uruguay: Law 19.172 (signed 20 December 2013).
- Canada: Cannabis Act (Bill C-45), in force 17 October 2018; medical regulations of 2001.
- Germany: Cannabis Act, in force 1 April 2024.
- Malta: personal-use cannabis law, in force 18 December 2021.
- Luxembourg: home-cultivation law, in force 21 July 2023.
- Czech Republic: Supreme Court opinion Tpjn 301/2013 (13 March 2014); Act No. 270/2025 Coll.
- United States: Controlled Substances Act, 1970; Gonzales v. Raich (2005); Cole Memorandum (29 August 2013, withdrawn 4 January 2018); budget clause first passed 30 May 2014; farm bill signed 20 December 2018; spending bill signed 12 November 2025; H.R. 6500, signed 2 September 2026.
- Ruling of DEA Chief Administrative Law Judge Francis L. Young, 6 September 1988; Alliance for Cannabis Therapeutics v. DEA, 15 F.3d 1131 (1994).
- DEA final rule issued 22 April 2026, published 28 April 2026.
Continued in Part 2: From Prohibition to Legalisation: Thailand, Southeast Asia and What the Outcome Record Shows (Part 2 of 2)