Cannabis and CBD around the world: three legal models

The majority of countries in the world maintain a total ban on cannabis, with no distinction as to use, pursuant to the international UN conventions on narcotics adopted in 1961, 1971 and 1988. Several countries in Asia and the Middle East apply particularly severe penalties, while other regions maintain a prohibition that is more moderate in its practical application.

Many countries, including several European Union member states, allow regulated medical access to cannabis, generally on prescription and for specific indications. France itself has been running an experiment along these lines since 2021, now being rolled out more widely. This intermediate model remains distinct from wellbeing CBD, which is not a matter of medical prescription.

A limited number of countries have legalised the recreational use of cannabis at national level, Uruguay having been the first in 2013, followed by Canada in 2018. Other countries apply policies of tolerance or decriminalisation without full legalisation, such as the Netherlands with its historic coffeeshop system, regulated but legally distinct from formal legalisation. Germany, for its part, adopted a partial legalisation law in 2024, limited notably to possession and personal cultivation. Our article on cannabis legalisation in Canada sets out one of these national frameworks in particular.

CBD occupies a place distinct from these three models: it rests on industrial hemp, a variety of cannabis selected for its very low THC content, grown legally in many countries including those that maintain the prohibition of recreational cannabis. In France, the marketing of CBD remains authorised for any finished product whose THC content is less than or equal to 0.30%, in line with the Conseil d'État decision of 29 December 2022, a framework independent of the debates on recreational legalisation being held elsewhere in the world.

Comparing these national frameworks directly remains risky: THC thresholds, authorised quantities and distribution channels differ markedly from one country to another. A product that is legal in a given country may remain strictly prohibited in France, including where it is described as "CBD" abroad, as soon as its THC content exceeds the French threshold.

Which country legalised recreational cannabis first?

Uruguay, in 2013, was the first country to legalise the recreational use of cannabis at national level, followed thereafter by several other states.

Is the Dutch coffeeshop system a form of legalisation?

No, not strictly speaking. It is a system of regulated tolerance, built up historically, but which does not have the same legal status as formal legalisation.

Is French CBD recognised in every country?

No. Each country applies its own THC threshold and its own rules. A CBD product that is compliant in France may be prohibited elsewhere, and vice versa.

Is France considering recreational legalisation?

No reform to that effect is currently under way. Only an experiment on medical cannabis is being rolled out more widely, distinct from any recreational use.