The Czech Republic and Portugal are two of the European cannabis industries’ most crucial markets.
Both have a population of around 10m, both were European pioneers in cannabis decriminalisation, and before Portugal’s recent government dissolution, both looked to be targeting adult-use legalisation.
Despite comparable beginnings and a shared liberal outlook on cannabis, the country’s respective cannabis industries have developed into very different beasts.
Business of Cannabis spoke to Sean Carney, Founder of Herbology Ventures and former Director of Business Development at Tilray, to explore why they have taken such different paths, and where these could lead them in future.
Portugal is a market where medical cannabis treatment is legal, but patient numbers are extremely low due to the lack of a developed infrastructure for treatment.
Mr Carney suggests that its domestic medical industry is ‘window dressing’, and that the country’s core industry centres around supplying medical cannabis to neighbouring countries, playing the role of ‘the Canada of Europe’.
The industry was established and promoted by the government initially to prevent ‘significant brain drain’ taking place, with youth unemployment sitting at around 25% in the early 2010s.
“The Portuguese saw an opportunity for economics. They really have been doubling down on the economic aspects of the cultivation industry. I believe a big part of this was to prevent brain drain… and it’s working.
Initially, he continued, unskilled labourers were hired to work in greenhouses, but the government soon realised that the creation of more sophisticated manufacturing facilities would attract expats back to the country, and they soon began attracting ‘PhD students from all the universities to the industry’.
The Czech Republic had no such issues, with one of the lowest unemployment rates in the EU. Cultivation was allowed a little earlier here, around 2014, but initially only through a state tender.
This requirement was scrapped in 2022, and the government has since been awarding cultivation licences ‘based on merit’
“Finally, they caught on but they’re around four years behind Portugal in cultivation.”
However, crucially, the Czech Republic became the first country in the EU to raise the THC limit on industrial hemp to 1%.
“That’s important because hemp producers don’t have to wash down their hemp to be compliant with a 0.2% THC limit. That means that hemp is cultivated here, if it’s a good strain, can have a lot better minor cannabinoid content than anywhere else in the EU.”
The approaches of government
In September 2023, news broke that Portugal’s Socialist Party (which at the time held a majority government) announced plans to form a working group to discuss and explore the regulation of adult-use cannabis.
While the country had already become a key location in European cannabis with a number of major companies investing significantly, taking advantage of its ideal growing conditions, favourable regulatory environment and proximity to other key markets, this news exacerbated interest.
Months after this promising announcement, Portugal’s administration was felled by a corruption scandal, and many fear that plans for adult-use reform will go with it.
However, Mr Carney suggests that just as the Czech Republic was ‘late to the party’ on liberalising cannabis cultivation, Portugal was ‘late on adult-use’.
Furthermore, like its medical cannabis programme, this legislation would not have had the full weight and attention of the government behind it, unlike in the Czech Republic.
Just three weeks after Germany ‘broke the ice’ internationally with the announcement that it would seek to legalise medical cannabis two years ago, the Czech Republic announced similar intentions.
“So the big difference here now is the Czech Republic has been working on this for years quietly, unlike the Portuguese who are kind of new to the game.”
It’s not just Portugal though. According to Mr Carney, the Czech Republic differs from every country in Europe in its approach.
Fundamentally, they are not proposing legislation as a standalone item. Instead it is being incorporated into a far wider strategy focused on public health and harm reduction, with cannabis forming only a small part of an overarching legislative strategy.
“I think this is a crucial point that Europe needs to take note of.”
He continued that this is now becoming the most realistic strategy for countries to overcome EU regulation, as the Single Convention on Narcotic Drugs states steps must be taken to protect the welfare of mankind, making a strategy centred purely around harm reduction difficult to dismiss.
“Traditionally this was done through prohibition. The Czechs are now saying that it can be done through regulation.”
Furthermore, other countries, including Malta, Germany, Luxembourg and the Netherlands are beginning to take note of this strategy, and will be keeping a close eye on the progress of the Czech Republic’s harm reduction strategy as it ‘breaks the ice’ for their individual efforts.