Europe's Cannabis Models Compared: Six Countries Side by Side

Headlines tend to call all six countries "legal", but the rules underneath are very different. A visitor can walk into a Dutch coffeeshop in some cities; the same visitor has no legal way to buy in Berlin or Valletta. This guide lines the models up using official sources and the European Union Drugs Agency (EUDA) as the overview.

The six models in one table

Each row reflects national law or official guidance as we found it in September 2026. Follow the links in the last section for full country guides.

The pattern is clear from the right-hand columns. Across all six, the only places where an adult hands over money and receives cannabis in a regulated setting are Dutch coffeeshops, Swiss pilot outlets and, as a membership contribution rather than a sale, German and Maltese associations.

Model 1: home grow plus clubs (Germany, Malta)

Germany and Malta let adults grow at home and get cannabis from non-profit associations, the only two of the six to do both, according to the EUDA's 2026 report.

Germany

• Adults may carry 25 g in public and keep 50 g at home, with 3 living plants per adult (Federal Ministry of Health).
• Associations may have up to 500 members; members may receive up to 25 g a day and 50 g a month.
• Membership requires age 18+ and at least six months' residence in Germany.
• The official evaluation (EKOCAN) published its second interim report on April 1, 2026; the final report is due by April 1, 2028.

Details, including how to join a club, are in our Germany 2026 guide and how to join an Anbauvereinigung.

Malta

• Chapter 628 of the laws of Malta, enacted in 2021, set up the Authority for the Responsible Use of Cannabis (ARUC), which licenses associations.
• ARUC lists up to 7 g in public and up to 50 g of dried cannabis at home as partially decriminalized, and 4 plants per household.
• Associations are capped at 500 members, all Malta residents aged 18+, with supply of up to 7 g a day and 50 g a month.
• ARUC restricts members aged 18 to 21 to products under 18% THC.

See how Malta's association model works.

Model 2: home grow only (Luxembourg, Czechia)

Luxembourg and Czechia remove penalties for growing a few plants at home but offer no legal way to buy cannabis.

Luxembourg's Grand Ducal Police say adults may grow up to four plants per household, at home, from labelled seeds, and consume only at home and not in front of minors. Carrying, buying or possessing 3 g or less in public still costs a €145 fine. Our Luxembourg guide explains what this means for visitors.

Czechia's criminal code reform took effect in January 2026. It allows up to three plants, 100 g of dried cannabis at home and 25 g in public; four or five plants is a misdemeanour and more than 200 g at home a crime. Proposals for a regulated market were rejected. The Czech guide also covers the HHC ban and medical access.

Model 3: tolerated retail (Netherlands)

The Netherlands never legalized cannabis; it chose not to prosecute small sales under strict conditions.

According to the Dutch government, coffeeshops may not sell more than 5 g per person per transaction or hold more than 500 g in stock, and may not serve minors or advertise. Possession of up to 5 g and growing up to five plants are generally not prosecuted. Since January 1, 2013, the national rules restrict sales to registered Dutch residents, though enforcement is left to each municipality.

The Controlled Cannabis Supply Chain Experiment tackles the old "back door" problem, where shops could sell but not legally buy stock. Its experimental phase started on April 7, 2025 in Almere, Arnhem, Breda, Groningen, Heerlen, Maastricht, Nijmegen, Tilburg, Voorne aan Zee and Zaanstad, runs for four years and can be extended by 18 months. See our reports on first results and prices and residency rules by city.

Model 4: research pilots (Switzerland)

Switzerland allows legal adult-use sales only inside time-limited scientific trials.

1. Legal basis
   Article 8a of the Narcotics Act took effect on May 15, 2021 and expires ten years later.
2. Who takes part
   Adults who already use cannabis and live in the canton running a trial, according to the Federal Office of Public Health (FOPH/BAG).
3. Scale
   About 10,400 adults took part in seven trials as of June 2025, according to the BAG-commissioned evaluation, including Basel, Bern, Lausanne and Zurich.
4. Next step
   A National Council committee approved a draft regulation law in February 2025; after consultation it went back to a subcommittee in May 2026.

Outside the trials, possessing up to 10 g for own use is not punishable and adult consumption is fined CHF 100. More in our Swiss pilot trials guide.

How the models have moved since 2021

1. 2021-05-15

   Switzerland's pilot trial article enters into force.

2. 2021-12

   Malta enacts Chapter 628 and creates ARUC.

3. 2023-07

   Luxembourg's home grow law takes effect.

4. 2024-04-01

   Germany's KCanG takes effect; associations follow on July 1.

5. 2025-04-07

   Dutch supply experiment enters its experimental phase.

6. 2026-01

   Czechia's home grow and possession limits take effect.

Limits of this comparison

Tables flatten detail, and three gaps matter most.

• Home grow is barely measured. The EUDA notes that home growing in Germany, Luxembourg and Malta is not systematically monitored.
• Evaluations are early. Germany and Luxembourg had published interim evaluations by the end of 2025; none is final.
• Local rules differ. Dutch residency checks, German state enforcement and Swiss cantonal trials vary by place.

For countries outside this group, start with where cannabis is legal in 2026, and check the national regulator before travelling with or growing cannabis.