Statement by Cantourage Group SE on the Draft Bill of the Federal Ministry of Health Amending the Medical Cannabis Act

August 1, 2025

Statement by Cantourage Group SE on the Draft Bill of the Federal Ministry of Health Amending the Medical Cannabis Act

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Preamble
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The Federal Ministry of Health (BMG) seeks to significantly restrict access to medical cannabis therapy. As justification, it cites the sharply increased import volumes of medical cannabis flowers into Germany, while prescriptions of cannabis flowers reimbursed by statutory health insurance (GKV) have only risen slightly. This discrepancy has prompted the BMG to place self-paying cannabis patients on telemedicine platforms under a general suspicion of drug misuse. Such a conclusion is in no way supported by empirical evidence. Instead, it contributes to the further stigmatization of medical cannabis patients and—if translated into law as currently envisioned—will drive hundreds of thousands of patients back into illegality. The main beneficiary would be Germany’s black market for cannabis, which would be revived on a large scale.

It appears that under new conservative leadership, the BMG is attempting to exploit the publicly serious accusation of drug misuse to push through political ideology without any factual basis—thereby endangering the health of cannabis patients, thousands of jobs in Germany, and hundreds of millions of euros in tax revenues. With this statement, we outline the advantages of the current legal framework, the risks associated with the proposed legislative draft, as well as our position, demands, and constructive recommendations.

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Introduction
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With its draft bill dated 18 June 2025, the BMG plans far-reaching restrictions on the supply of medical cannabis. It proposes that first-time prescriptions may in future only be issued following an in-person medical consultation. At the same time, telemedical access is to be largely excluded, and mail-order pharmacy distribution prohibited.

The BMG thus seeks to amend a law that it itself only enacted in April 2024: when the Cannabis Act entered into force, medical cannabis was removed from the scope of the Narcotics Act. Several hundred thousand people in Germany now receive medical cannabis—among them, self-paying patients constitute the largest group. These self-paying patients increasingly rely on digital platforms to access their treatment.

Cantourage fundamentally supports any measures that serve evidence-based, pharmaceutically controlled care. However, we are deeply concerned that this draft disadvantages patients, undermines the security of supply, and hinders the development of an emerging industry.

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Reasons for the Increase in Patient Numbers

The rise in the number of cannabis patients can be attributed to several factors. Although treatment with medical cannabis has been legal in Germany since 2017 and is, in principle, open to all indications, cannabis therapy had not been widely practiced. Legalization and the associated reclassification of medical cannabis have increased awareness, visibility, and understanding of this form of therapy. Until last year, many patients simply did not know that cannabis could be a viable therapeutic option for a wide range of medical conditions.

The same applies to physicians. In December 2023, Cantourage conducted a nationwide study, contacting 400 general practitioners across Germany’s 20 largest cities to request a consultation for cannabis therapy. The inquiry presented a fictional case of a patient suffering from insomnia. Only 27 physicians were open to consultation. Several stated that they lacked experience with medical cannabis and therefore did not prescribe it; others were unaware that they were even permitted to do so for sleep disorders. This indicates that prior to the reclassification, it was extremely difficult for patients to find a physician willing and able to prescribe medical cannabis—even when they had a qualifying diagnosis.

Legalization has thus enabled hundreds of thousands of people—many of whom had been self-medicating illegally and without medical supervision for years—to access safe, quality-controlled products. These new restrictions would reverse that progress. The resulting health and social risks would be substantial. A recent survey commissioned by the Bloomwell Group found that 42 percent of patients would turn to illegal sources if telemedicine were restricted. A 2024 study by Avaay showed that 80 percent of products available on the black market are contaminated. Restricting the legal market drives patients into illegality and creates higher long-term costs for the healthcare system.

The BMG’s justification for the proposed amendments is, at the very least, questionable. It cites data from the Federal Institute for Drugs and Medical Devices (BfArM), according to which imports of cannabis flowers for medical purposes increased by 170 percent from the first to the second half of 2024. During the same period, prescriptions of cannabis flowers covered by statutory health insurance rose by only 9 percent. Instead of recognizing this as evidence that, eight years after legalization, obtaining reimbursement for this therapy from the GKV remains unnecessarily complex, the BMG places self-paying patients under blanket suspicion of abuse. Despite valid medical prescriptions—which are required for the purchase of medical cannabis—the BMG presumes to question the medical necessity of treatment and, in doing so, discriminates against an entire group of patients.

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Patient Numbers Abroad

A look at other industrialized nations where medical cannabis is legal demonstrates that, even though patient numbers in Germany have increased since April 2024, they remain modest by international standards. In Israel, where medical cannabis has been legal since 1999, approximately two percent of the population are medical cannabis patients. In the U.S. state of Colorado, 62,320 registered patients were recorded in December of last year—about 1.02 percent of the population. Notably, Colorado also has a functioning recreational cannabis market, meaning there is no incentive for patients to misuse medical cannabis for non-medical purposes. In Germany, the proportion of patients treated with medical cannabis remains below one percent of the population. This international comparison makes clear that medical use in Germany cannot reasonably be interpreted as indicative of recreational misuse.

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The Importance of Telemedicine and Mail-Order Pharmacies

Since its regulatory reclassification, telemedicine has become a cornerstone of medical cannabis care. Digital platforms allow patients—regardless of location, mobility, or socioeconomic status—to begin a physician-supervised cannabis therapy. Particularly in rural areas or for individuals with limited mobility, telemedicine often represents the only realistic means of obtaining necessary treatment.

Another key factor is pharmaceutical safety. While black market products are completely unregulated, pharmacy-dispensed preparations meet the highest pharmaceutical standards. Cultivation, processing, and distribution take place under controlled conditions; product purity is monitored throughout the supply chain. Combined with physician oversight via telemedicine, this ensures a safe, transparent, and medically responsible pathway of care.

International comparative studies have concluded that digital healthcare solutions such as telemedicine are equally as effective as in-person care and can reduce healthcare costs in the long term. The proposed abolition of this access route therefore contradicts not only medical logic but also the broader goals of health policy modernization.

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Impact on Society, Politics, and the Economy

If the proposed draft were enacted, the consequences would be felt across multiple dimensions. Socially, a large portion of the population would lose access to medical cannabis or face severe restrictions. Particularly affected would be the hundreds of thousands of self-paying patients in Germany. This group not only sustains the supply system but also helps diversify and stabilize the market through their demand. Restricting their access would force many to resort to illegal sources or abandon their therapy altogether—an outcome that would be both medically harmful and socially regressive.

Politically, such a reversal would damage public confidence in the government’s policymaking. The law introduced in 2024 was hailed as a forward-looking step toward a modern healthcare system. For the same ministry to undermine it barely a year later—while its evaluation is still ongoing—undermines democratic legislative integrity.

From a healthcare policy perspective, the draft is contradictory. On one hand, the federal government regularly emphasizes the need for digital transformation in healthcare. On the other, it now seeks to dismantle precisely the structures that make such transformation possible.

Economically, the repercussions would be severe. According to a 2024 market analysis, Germany’s legal medical cannabis market is projected to reach a volume of approximately USD 4.6 billion by 2034. Companies have made significant investments based on legalization. Currently, around 2,500 pharmacies—roughly 15 percent of all pharmacies nationwide—dispense medical cannabis. Closing central distribution channels now would trigger severe market contractions, threatening the viability of many businesses and pharmacies.

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Threat to Jobs and Tax Revenues

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Position of Cantourage Group SE and Specific Demands

Preservation of Telemedical Access
Cantourage calls for the full preservation of telemedical access in medical cannabis therapy. This approach has proven effective, safe, and well-documented in practice. It ensures access to treatment for patients with limited mobility and those living in rural areas. Telemedicine must not be reduced to a supplementary role but maintained as an equal pillar of care. Reasonable safeguards could include limits on quantities and THC concentrations for cannabis flower treatments.
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Continuation of Pharmacy Mail Orders
Cantourage advocates maintaining the mail-order distribution of medical cannabis through licensed pharmacies. This channel meets all pharmaceutical requirements regarding storage, documentation, and transport. It guarantees that patients without local access can still obtain high-quality medicines. Restricting this route would endanger supply security, particularly in rural areas and for chronically ill individuals.
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Simplification of Health Insurance Reimbursement
Cantourage calls for a simplification of the reimbursement process for medical cannabis therapy through statutory health insurers. The low increase in reimbursement rates must not be used to accuse self-paying patients of misuse. Instead, policymakers should take this as an opportunity to review and streamline the dysfunctional reimbursement process.
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Recognition of the Role of Self-Paying Patients
We urge policymakers to acknowledge the essential role that self-paying patients play in the current system. These individuals finance their treatment independently, relieving the burden on statutory insurers. Their demand has enabled the development of a diverse, affordable market that benefits all patients—including those covered by the GKV. Regulatory interventions that ignore this reality endanger market dynamics and diminish overall quality of care.
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Evidence-Based and Differentiated Regulation
We advocate for differentiated rather than blanket regulatory tightening. The draft’s underlying assumption of widespread misuse is not supported by reliable data. New legal measures must be based on solid evidence and aligned with social realities and proven models of care. Effective oversight should include digital documentation tools, physician education, and quality-oriented monitoring mechanisms.

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