Over the past few years, telemedicine has reshaped how patients access medical cannabis, launching a wave of digital clinics across Europe and beyond. But now, that wave is breaking.
In this special series, Business of Cannabis investigates the global backlash facing cannabis telehealth. Through the lens of Australia’s prosecutions, Poland’s policy reversal, and Germany’s pending legislation, we explore how telehealth became both a lifeline for patients and a liability for policymakers, and what comes next for the industry built around it.
You can read Part 1 here, and Part 2 here.
When CanG officially came into force last April, its final iteration fell well short of the architects’ original goals regarding adult-use, decriminalising possession but providing almost no legal route to accessing cannabis without growing it yourself.
However, a clause in the accompanying MedCanG shifted the entire shape of the industry overnight. The removal of cannabis from the list of narcotics swung the door open for the already well-established medical cannabis industry to provide prescription cannabis to patients’ doors quickly, efficiently, and often at prices lower than the illicit market.
The German political right has opposed these changes since they were first proposed, and the CDU/CSU ran their recent election campaign on a promise to ‘abolish’ the cannabis law. Now that they represent the largest party in the ruling coalition, this rhetoric is edging closer to becoming a legislative reality.
The looming crackdown on Germany’s online medical cannabis market has been expected for some time. Indeed, during last month’s Business of Cannabis x Mary Jane Berlin B2B day, telemedicine was top of the agenda.
Panellists were repeatedly asked for their outlook on the current situation, with the consensus appearing to accept that some form of restriction was on the way, and even that ‘over-access’ had become an issue for the industry.
Mary Jane Berlin x Business of Cannabis B2B Day
Despite its apparent inevitability, the proposals still came as a surprise to many, including regulatory expert and lawyer Kai-Friedrich Niermann.
He told Business of Cannabis: “The draft law came as quite a surprise (last) week; there had been a couple of press releases by pharmacist and physician associations, but no prior discussion or debate on the matter by the ministry.”
“I consider the draft to be a half-baked rush job. Next, the associations will be consulted, then the draft must go to the Bundesrat. The Bundesrat can make a recommendation, which is not binding. Then the draft law goes to the federal cabinet, which must also decide on it and submit the law to the Bundestag for a vote.
“There, members of parliament can make further amendments before the final vote in Bundestag. After that, the Federal Council is heard again, which cannot block the bill, but initiate a mediation committee if they do not consent to the bill. This would slow down entry into force, but not prevent the bill from being adopted by Bundestag.”
With a long road ahead before the draft makes it into law, it’s likely some changes will be made to the draft. This is despite little meaningful pushback so far from the SPD, the CDU’s coalition partners and creators of the CanG project.
Niermann suggests that, in his view, ‘at least mail order will be maintained’, something that would be a major win for patients and businesses alike.
“The whole process is politically motivated; it makes no sense to introduce different regulations for cannabis in regard to telemedicine, but not to touch even more dangerous medicines which still can be ordered online,” Niermann continued.
Four20’s Managing Director, Torsten Grief, echoed this in a recent LinkedIn Post, stating that despite the ‘wild theses and analyses’ of the potential fallout from this amendment, ‘there are still many steps to be taken before a draft bill becomes an adopted law.’
“In the history of the Bundestag, no law has ever come out of the Bundestag as it was introduced,” he continued, adding that the Federal Ministry has given the industry a fair opportunity to participate in the consultation process.
During a recent workshop at the Business of Cannabis x Mary Jane Berlin B2B day, Analyst & Managing Director, Zuanic and Associates, Pablo Zuanic walked the room through his projections for the current size of the German market.
In terms of patient numbers, Zuanic estimates that the German medical cannabis industry currently has around 338,000 active patients, around 0.4% of the total population.
Zuanic estimates that 0.4% of the German population are active medical cannabis patients — around 338,000 people. He described this as the glass-half-full interpretation of current patient penetration.
Roughly 60% of imports, which have risen five-fold since the passage of CanG, are processed through pharmacies, with the remaining 40% either rejected, lost, or unaccounted for.
Based on this pharmacy and import data, with an average of €7 per gram, that implies a market size of roughly €625 million. If the 60% share has grown and prices rise to €10 per gram, the market could exceed €1 billion.
Other analysts suggest the market could be far bigger. In a brief report published in May by Whitney Economics, it was suggested that medical patients have remained consistent at between 200k-300k.
However, the rise of telemedicine clinics with liberal prescription policies has meant that a new category, ‘self-paying telemedicine patients’ (those accessing the medical market for self-medication or adult-use purposes) could now number between 500k-600k, bringing the total close between 700k-900k patients utilising this legal framework to access cannabis.
Notably, the firm suggested that not only had the legal market peaked, but that oversupply could soon become a major issue, mirroring the price collapses seen across North America over the last decade.
Price dynamics according to THC content – Source: Grünhorn Group
This was supported by recent analysis from German operator Grünhorn, which cautioned of a ‘structural oversupply’ changing the economic rules of the game in the supply market.
Alongside a 120% growth in imports, the number of specialist cannabis pharmacies quintupled, rising from around 50 to over 250 within a year. This expansion has led to intensified competition and price pressure: the average taxed price per gram fell from €9.98 to €8.77, a nearly 12% drop, with low-THC products seeing sharper price declines (–24%) compared to high-THC products (–10%).
With the eventual outcome of this draft bill still fluid, it’s difficult to predict the impact it could have on the booming market.
As reported last week, looking to Poland for answers would suggest an immediate drop in patient numbers of around 50%, but a like-for-like comparison falls short due to both market’s idiosyncrasies.
That said, as seen in Poland, it’s highly likely that whatever happens will reduce access for some of the country’s most vulnerable patients.
Niermann explained: “Indeed, this proposal would spell the end of the industry as we’ve come to know it since April 1, 2024. In particular, it would affect seriously ill patients, who would have to make their way back to the doctor and the pharmacy in person.”
He goes on to suggest that the swathe of telehealth clinics will probably ‘have to switch back to the model that was in place before April 1, 2024, an “Algea-Care” 1.0 version, so to say’.
“Since cannabis was still a narcotic at that time, at least the first visit always had to take place on site.”
Source: Bloomwell Group
Whitney Economics’ report, which predicted incoming efforts to limit access before the draft bill was published, expects this move to slow the growth of the legal market.
“In other words, legal participation may have already peaked without additional reform. If supply trends on the importation continue and the imports double or triple, Germany could be faced with an increase in supply that is greater than the amount that the legal consumers can consume.
If this oversupply continues, the report suggests capacity could cover ‘60% of the total market “(illicit and legal) within the next two to three years’, driving further price compression and profitability.
Bloomwell Group, in its recent monthly ‘Cannabis Barometer’ report, said that at its clinic prescriptions filled between May and June 2025 were up over 1000% year-on-year.
In a survey of around 2700 German cannabis consumers, Bloomwell also found that restricting digital access would push ‘the majority’ of respondents back to the illicit market.
It found that nearly 57% of respondents now accessing digital therapy were purchasing from the illicit market before the law change. Furthermore, over 41% of patients said they would be forced to return to the illicit market without digital access, with only 23% stating they’d approach a General Practitioner.
Bloomwell’s Co-Founder and CEO, Niklas Kouparanis: “The premise that at politicians are seriously considering slowing digital innovation in an already overburdened healthcare system, re-criminalising patients, threatening jobs, and forfeiting tax revenue is beyond absurd – and would be laughable if the consequences for patients and public health weren’t so serious.”
The post Has Germany’s Medical Cannabis Market Peaked? New Laws, Surging Supply, and Industry Unrest appeared first on Business of Cannabis.
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In this special series, Business of Cannabis investigates the global backlash facing cannabis telehealth. Through the lens of Australia’s prosecutions, Poland’s policy reversal, and Germany’s pending legislation, we explore how telehealth became both a lifeline for patients and a liability for policymakers, and what comes next for the industry built around it.
You can read Part 1 here, and Part 2 here.
When CanG officially came into force last April, its final iteration fell well short of the architects’ original goals regarding adult-use, decriminalising possession but providing almost no legal route to accessing cannabis without growing it yourself.
However, a clause in the accompanying MedCanG shifted the entire shape of the industry overnight. The removal of cannabis from the list of narcotics swung the door open for the already well-established medical cannabis industry to provide prescription cannabis to patients’ doors quickly, efficiently, and often at prices lower than the illicit market.
The German political right has opposed these changes since they were first proposed, and the CDU/CSU ran their recent election campaign on a promise to ‘abolish’ the cannabis law. Now that they represent the largest party in the ruling coalition, this rhetoric is edging closer to becoming a legislative reality.
A predictable surprise
The looming crackdown on Germany’s online medical cannabis market has been expected for some time. Indeed, during last month’s Business of Cannabis x Mary Jane Berlin B2B day, telemedicine was top of the agenda.
Panellists were repeatedly asked for their outlook on the current situation, with the consensus appearing to accept that some form of restriction was on the way, and even that ‘over-access’ had become an issue for the industry.
Mary Jane Berlin x Business of Cannabis B2B Day
Despite its apparent inevitability, the proposals still came as a surprise to many, including regulatory expert and lawyer Kai-Friedrich Niermann.
He told Business of Cannabis: “The draft law came as quite a surprise (last) week; there had been a couple of press releases by pharmacist and physician associations, but no prior discussion or debate on the matter by the ministry.”
“I consider the draft to be a half-baked rush job. Next, the associations will be consulted, then the draft must go to the Bundesrat. The Bundesrat can make a recommendation, which is not binding. Then the draft law goes to the federal cabinet, which must also decide on it and submit the law to the Bundestag for a vote.
“There, members of parliament can make further amendments before the final vote in Bundestag. After that, the Federal Council is heard again, which cannot block the bill, but initiate a mediation committee if they do not consent to the bill. This would slow down entry into force, but not prevent the bill from being adopted by Bundestag.”
With a long road ahead before the draft makes it into law, it’s likely some changes will be made to the draft. This is despite little meaningful pushback so far from the SPD, the CDU’s coalition partners and creators of the CanG project.
Niermann suggests that, in his view, ‘at least mail order will be maintained’, something that would be a major win for patients and businesses alike.
“The whole process is politically motivated; it makes no sense to introduce different regulations for cannabis in regard to telemedicine, but not to touch even more dangerous medicines which still can be ordered online,” Niermann continued.
Four20’s Managing Director, Torsten Grief, echoed this in a recent LinkedIn Post, stating that despite the ‘wild theses and analyses’ of the potential fallout from this amendment, ‘there are still many steps to be taken before a draft bill becomes an adopted law.’
“In the history of the Bundestag, no law has ever come out of the Bundestag as it was introduced,” he continued, adding that the Federal Ministry has given the industry a fair opportunity to participate in the consultation process.
The German market today – oversupply looms
During a recent workshop at the Business of Cannabis x Mary Jane Berlin B2B day, Analyst & Managing Director, Zuanic and Associates, Pablo Zuanic walked the room through his projections for the current size of the German market.
In terms of patient numbers, Zuanic estimates that the German medical cannabis industry currently has around 338,000 active patients, around 0.4% of the total population.
Zuanic estimates that 0.4% of the German population are active medical cannabis patients — around 338,000 people. He described this as the glass-half-full interpretation of current patient penetration.
Roughly 60% of imports, which have risen five-fold since the passage of CanG, are processed through pharmacies, with the remaining 40% either rejected, lost, or unaccounted for.
Based on this pharmacy and import data, with an average of €7 per gram, that implies a market size of roughly €625 million. If the 60% share has grown and prices rise to €10 per gram, the market could exceed €1 billion.
Other analysts suggest the market could be far bigger. In a brief report published in May by Whitney Economics, it was suggested that medical patients have remained consistent at between 200k-300k.
However, the rise of telemedicine clinics with liberal prescription policies has meant that a new category, ‘self-paying telemedicine patients’ (those accessing the medical market for self-medication or adult-use purposes) could now number between 500k-600k, bringing the total close between 700k-900k patients utilising this legal framework to access cannabis.
Notably, the firm suggested that not only had the legal market peaked, but that oversupply could soon become a major issue, mirroring the price collapses seen across North America over the last decade.
Price dynamics according to THC content – Source: Grünhorn Group
This was supported by recent analysis from German operator Grünhorn, which cautioned of a ‘structural oversupply’ changing the economic rules of the game in the supply market.
Alongside a 120% growth in imports, the number of specialist cannabis pharmacies quintupled, rising from around 50 to over 250 within a year. This expansion has led to intensified competition and price pressure: the average taxed price per gram fell from €9.98 to €8.77, a nearly 12% drop, with low-THC products seeing sharper price declines (–24%) compared to high-THC products (–10%).
What happens if telemedicine is restricted?
With the eventual outcome of this draft bill still fluid, it’s difficult to predict the impact it could have on the booming market.
As reported last week, looking to Poland for answers would suggest an immediate drop in patient numbers of around 50%, but a like-for-like comparison falls short due to both market’s idiosyncrasies.
That said, as seen in Poland, it’s highly likely that whatever happens will reduce access for some of the country’s most vulnerable patients.
Niermann explained: “Indeed, this proposal would spell the end of the industry as we’ve come to know it since April 1, 2024. In particular, it would affect seriously ill patients, who would have to make their way back to the doctor and the pharmacy in person.”
He goes on to suggest that the swathe of telehealth clinics will probably ‘have to switch back to the model that was in place before April 1, 2024, an “Algea-Care” 1.0 version, so to say’.
“Since cannabis was still a narcotic at that time, at least the first visit always had to take place on site.”
Source: Bloomwell Group
Whitney Economics’ report, which predicted incoming efforts to limit access before the draft bill was published, expects this move to slow the growth of the legal market.
“In other words, legal participation may have already peaked without additional reform. If supply trends on the importation continue and the imports double or triple, Germany could be faced with an increase in supply that is greater than the amount that the legal consumers can consume.
If this oversupply continues, the report suggests capacity could cover ‘60% of the total market “(illicit and legal) within the next two to three years’, driving further price compression and profitability.
Bloomwell Group, in its recent monthly ‘Cannabis Barometer’ report, said that at its clinic prescriptions filled between May and June 2025 were up over 1000% year-on-year.
In a survey of around 2700 German cannabis consumers, Bloomwell also found that restricting digital access would push ‘the majority’ of respondents back to the illicit market.
It found that nearly 57% of respondents now accessing digital therapy were purchasing from the illicit market before the law change. Furthermore, over 41% of patients said they would be forced to return to the illicit market without digital access, with only 23% stating they’d approach a General Practitioner.
Bloomwell’s Co-Founder and CEO, Niklas Kouparanis: “The premise that at politicians are seriously considering slowing digital innovation in an already overburdened healthcare system, re-criminalising patients, threatening jobs, and forfeiting tax revenue is beyond absurd – and would be laughable if the consequences for patients and public health weren’t so serious.”
The post Has Germany’s Medical Cannabis Market Peaked? New Laws, Surging Supply, and Industry Unrest appeared first on Business of Cannabis.
Continue reading...
