Cannabis in Malta: Prospects for 2025 and beyond | Karen Mamo

Karen Mamo is a harm reduction expert and has been asked by MaltaToday for her views on the state of cannabis use in Malta

The partial decriminalisation of cannabis in December 2021 and the licensing of more than 10 Cannabis Harm Reduction Associations (CHRAs) brought significant benefits for resident cannabis consumers in Malta. It ensured fewer criminal consequences for possession and cultivation, while providing users with labelled cannabis flowers, including a potency gradient and clear health warnings. 

But, unfortunately, the 2024 ban imposed by the Authority for the Responsible Use of Cannabis (ARUC) on the use of herb vaporisers, a less risky method of consumption, within cannabis associations, and missed opportunities for training and talks on harm reduction, precluded registered members from a unique opportunity to access, from the very beginning, pragmatic harm reduction principles and practices. 

Worryingly, the ARUC has recently said it is analysing the creation of ‘smoking lounges’ within the premises of cannabis associations. It is imperative to underline that smoking is one of the most harmful ways to consume cannabis, and when this is done with the concurrent combustion of nicotine, risks to health increase. This includes a heightened propensity for increased consumption and ultimately dependence. It is not clear why ARUC is promising to introduce a risky practice instead of promoting the responsible use of cannabis through appropriate harm reduction tools. 

The authority may also be considering allowing CHRAs to produce hash and edibles. If this materialises, it will be a very important step to further oppose the monopoly of criminal organisations in the illegal trafficking of cannabis. However, if the Maltese regulatory framework is looking at the Canadian model, one hopes that great caution will be adopted if and when a discussion on introducing cannabis concentrates is carried out. 

Cannabis concentrates made using solvents, such as shatter and other types such as Rosin and “butane hash oil,” contain relatively elevated levels of THC. These products should be used with caution and ideally only by experienced cannabis users. When considering that these products are not yet in high demand by local consumers, a regulatory shift might be a sign of increased influence by profit-oriented entrepreneurs. This reality risks pushing the Maltese reform away from its harm reduction potential, and closer towards a top-down ‘commercially driven’ evolutionary industry. 

To better understand potential future scenarios in Malta, one may look at research from other countries and different regulatory experiences. In Cannabis Social Clubs in Contemporary Legalization Reforms: Talking Consumption Sites and Social Justice, Belackova and colleagues look at the core principles of Cannabis Social Clubs, and recognise that these recreational spaces harbour an increased potential to reduce adverse health-related outcomes, particularly in relation to benefits of on-site cannabis consumption and peer-to-peer exchange of best practices. 

They underline that the co-design of harm reduction policies by consumers and regulators has now become recognised as a best practice in the development of drug, alcohol, and mental health programmes. Interestingly, when looking at recent developments from Canada, researchers observe a worrying increase in participation and pressure by profit-oriented entrepreneurs as opposed to the socially oriented grass-roots organisations. The researchers warn that this is disrupting the development of social justice tools and negatively impacting the overarching goals of human rights driven drug policy reform.  

Recommendations to re-align Maltese cannabis reform with its human rights purpose and social justice potential 

1. Development and sustainability of a safe space within Cannabis Harm Reduction Associations: 

It would be a waste of taxpayers' money if educational campaigns remain frozen under the preventive umbrella and do not provide practical tools to prioritise the health, social, and legal rights of people who use cannabis. In 2025, it will be imperative for the ARUC to equip itself with a pool of human rights professionals, including people with living experiences of cannabis, committed to advance an inclusive interpretation of harm reduction and facilitate the co-design of non-judgmental policies and educational campaigns. To protect the reform from predatory practices, professionals engaged by the ARUC should be ready to defend the human rights of people who use cannabis, and remain steadfast against political pressure and/or influence from profit-oriented entrepreneurs. 

2. Practical harm reduction, environmental and social justice tools 

Throughout the new year, one augurs that CHRAs will be provided with additional tools to fulfil their full harm reduction potential, including the possibility to produce hash and edibles (only from flowers) and the possibility for members to be introduced to less risky methods of consumption such as herb vaporisers. Moreover, to further advance long-term sustainability CHRAs should be provided with financial assistance and grants to encourage environmentally sustainable practices - reduce, reuse, recycle - from seed to distribution. As identified by Belackova and colleagues, social equity opportunities are too part and parcel of a harm reduction and not-for-profit model. Examples of social equity include the distribution of cannabis surplus (at no cost) to people using cannabis as an exit tool from substances with a higher margin of risk such as heroin, cocaine and synthetic cannabinoids, and/or vulnerable groups facing serious socio-economic challenges, such as homelessness. These measures restore dignity, and empower communities to explore alternative avenues, ultimately being best positioned for innovative social change.  

3. Advancing regulatory oversight, transparency, accountability, and good governance 

The proper adoption of these monitoring tools is pivotal to ensure the cannabis reform is fulfilling its immediate and long-term human rights goals. Proper regulatory oversight will rest squarely on independent academic and professional collaborations, ideally established with reputable foreign institutions. To mention just a few examples: Correlation European Harm Reduction Network (C-EHRN), the Transnational Institute (NL), the Pompidou Group (Council of Europe), the Trimbos Institute (NL), the European Society for Social Drug Research (BE), and the European Union Drugs Agency. Furthermore, both legislative and regulatory bodies tasked with implementing the cannabis reform should follow the EU Drugs Strategy (2021-2025) Strategic Priority 7.3 and ensure meaningful representation and funding of civil society organisations representing the cannabis community. 

Thank you! 

As we share our blessings for a peaceful and prosperous New Year, I invite you to join me in a round of applause for the people cultivating cannabis at home, for those forming a cannabis harm reduction association, and for those joining these associations. Thank you! you remain key to promote the responsible use of cannabis, and ultimately, a more just and harmonious society. 

Karen Mamo holds an MSc in Addiction Studies and an MSc/MA in Conflict Resolution and Mediterranean Security.  Since 2019, she has been promoting an educational initiative called Harm Reduction Malta. Between February 2023 and November 2024, she occupied the role of Policy, Research and Harm Reduction Manager with the Authority for the Responsible Use of Cannabis.