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German Cannabis Business Association (BvCW) – Potential Cannabis Supply Shortages Due to COVID-19 Crisis
BvCW Proposes Easing Prescription Guidelines and Documentation Requirements for Medical Cannabis

Berlin, 2020-03-30: The German Cannabis Business Association (BvCW) has proposed short-term measures and amendments to the Narcotic Prescription Ordinance (BtM-VV) to the Federal Ministry of Health in order to reduce potential supply shortages and the risk of infection in the handling of medical cannabis.

Dr. Stefan Meyer, President of the BvCW, stated: “We are concerned that patients’ right to a pain-free life—especially that of palliative care patients—is at risk during the current COVID-19 crisis. But not only them; individuals with conditions such as tremors also face the danger of losing their ability to live independently without THC flowers. Therefore, we urge the federal government to take immediate action to ensure the continued supply of cannabis for patients. This includes less infection-prone methods of supply for both patients and their physicians. We have submitted feasible, short-term proposals to the Minister of Health.

In the letter sent to Minister Spahn, the Federal Commissioner for Patients’ Affairs Prof. Dr. Schmidtke, and the Federal Drug Commissioner Daniela Ludwig, the BvCW wrote:

The situation for cannabis patients is becoming increasingly critical. At present, administrative processes are proceeding very slowly or not within the required timeframe. Logistics providers are also under tremendous strain. As a result, the COVID-19 crisis is currently causing supply shortages in the medical cannabis sector.

We have received reports that the first patients have been unable to obtain their medication (cannabis flowers) from pharmacies because pharmacies lack sufficient protective clothing and equipment.

This equipment is essential under current regulations, as pharmacies are required to repackage the cannabis flowers, which are delivered in sealed containers, and transfer them into new containers after visual inspection. In some cases, thin-layer chromatography is also used for quality control. To prevent potentially infected pharmacists from passing the virus to vulnerable patients, these procedures must be performed using protective gear. If these materials (disinfectants, gloves, face masks, and body protection) are only partially or not at all available, there is a serious risk that pharmacists could infect the high-risk group of cannabis patients. Thus, it is understandable that pharmacists without the necessary protective equipment are refusing to dispense cannabis (in order to protect the patients).

In addition to this issue, patients are currently forced to pick up their prescriptions in person from doctors and present them in person at pharmacies, which poses significant health risks.

To adequately address and minimize these issues, we believe the following special measures could be introduced for the duration of the COVID-19 crisis:

  • Initial and follow-up prescriptions for cannabis should no longer require in-person visits but be handled via video consultation.
  • Delivery of these specific medications should be carried out by courier, taxi, or DHL Express, so at-risk patients don’t have to expose themselves to dangers in pharmacies or clinics.
  • Reduction of bureaucratic and documentation requirements to facilitate rapid assistance.
  • Submission of documents digitally (e.g., as *.pdf files) to eliminate paper-based processes, which are slower and carry a risk of virus transmission.
  • To prevent supply shortages, consideration should be given to simplifying the importation process for cannabis.

These proposals, collectively, would significantly relieve the burden on cannabis patients, who are already severely impacted.

The full letter is available as a PDF file here.
The press release is available as a PDF file here.