In September 2025, Germany's BfArM stopped issuing new cannabis import permits. The law had not changed. The market had not closed. Germany had run out of quota: the 122 tonne estimate it filed with the International Narcotics Control Board for that year was exhausted, and until the number moved, nothing new could be licensed.
Cannabis import quotas are ceilings created by the estimates system of the Single Convention on Narcotic Drugs. Every government tells the INCB how much cannabis it expects to import, manufacture, consume and hold in stock for the coming year. The Board confirms those figures, and the confirmed total becomes the legal maximum that country may acquire. National regulators issue individual permits inside that ceiling, never above it.
For a Canadian Licensed Producer, the ceiling stays invisible until it binds. Your export authorisation is valid. Your buyer's purchase order is signed. The pallet still waits in Montreal, because a number filed in Bonn or Canberra ran out in the third quarter. That is the part of international supply that rarely appears in a distribution agreement.
How INCB estimates set every cannabis import quota
The system runs on three treaty obligations. Under Article 19 of the Single Convention, every party furnishes the INCB with annual estimates of the narcotic drug quantities it will need for medical and scientific purposes, including imports and stocks. Under Article 20, those same governments file statistical returns showing what actually happened the year before. Article 31 then requires a separate permit for each individual import and each individual export.
Once the Board confirms a country's estimates, the figures carry legal weight. Confirmed totals set the maximum quantity a state may acquire through import, manufacture, or a combination of the two. A regulator that licensed volume beyond the confirmed total would put its own country in breach of the treaty. That is why Australia's Office of Drug Control and BfArM behave like allocators rather than approvers.
Where the numbers get published
The INCB publishes final estimates for each year in December. Since 2 July 2025 it has also published monthly updates covering cannabis cultivation and production, which shortens the reporting lag exporters used to live with under a purely annual cycle. A government that needs more room can file a supplementary estimate mid-year and ask the Board to confirm an increase. Germany did that twice in 2025.
Where Canada sits inside the same system
Health Canada issues export permits under the Cannabis Act and the Cannabis Regulations, and Canada files its own estimates and statistical returns like every other party. A Canadian export permit is granted against a named destination and against an import permit the receiving country has already issued. Canada's job is to confirm the shipment is authorised at both ends. Its job is not to confirm that your buyer still has room inside their national ceiling.
So your buyer's ability to receive product is capped by a number they filed months before they ever met you. That number, not your batch data, decides whether the shipment moves in October.
Germany and Australia in 2025: one treaty, two directions
Germany imported roughly 72 tonnes of medical cannabis in 2024. Its estimate for 2025 was 122 tonnes. By September that allocation was gone, and BfArM confirmed to German trade press that no new import permits could be granted, while stressing this was not an import ban. Processing simply stopped moving. On 20 October 2025, after the Board confirmed an increase, the ceiling rose to roughly 192.5 tonnes and permits resumed.
Even the revised ceiling proved too small. Germany finished 2025 at about 201 tonnes imported, above its own twice-raised estimate, and carried the overshoot into a fresh re-estimation for 2026. Canada supplied 93,006 kg of that annual total, roughly 46 per cent, which makes Canadian LPs the largest single exposure group to any German quota pause. We looked at the demand side of that market in our guide to the German medical cannabis channel. First quarter 2026 imports came in at 50,539 kg, up about 34 per cent year over year.
Australia moved in the opposite direction on almost the same date. Its 2025 estimate opened at 101 tonnes. In October 2025 the INCB reduced it to 88 tonnes, citing utilisation well below what importers had forecast. The ODC had warned the sector only weeks earlier that unused and partly used permits were locking up capacity and slowing new applications.
| Market | 2025 estimate | Revision |
|---|---|---|
| Germany | 122 tonnes | Raised to about 192.5 tonnes, 20 Oct 2025 |
| Australia | 101 tonnes | Cut to 88 tonnes, Oct 2025 |
For a Canadian supplier the two revisions felt nothing alike. Germany meant roughly two months in which no new import permit could be issued to anyone. Australia meant smaller buyer allocations carried into the following year.
Those two decisions landed within about three weeks of each other. One ceiling moved because demand outran the forecast. The other moved because the forecast outran demand. In both cases the Canadian supplier learned about it after the decision was already made.
Where Canadian LPs actually lose shipments to quota
Most producers treat quota as a country-level statistic. It is not. It is an allocation held by one named importer, sitting inside a national number, tracked permit by permit. That is where shipments actually stall. Four checks cover the exposure.
1. Allocation position, not national headroom
A national ceiling with 40 tonnes of visible headroom tells you nothing if your importer has already committed its own forecast. Ask what volume the buyer filed for the year, how much of it they have drawn down, and how many open permits they hold. Importers who over-forecast get corrected, and the correction lands on their suppliers.
2. Calendar clustering
Permit applications bunch into the second half of the year, which is precisely when ceilings tighten. Germany's pause landed in September. Australia's cut landed in October. A shipment planned for the fourth quarter carries materially more quota risk than the identical shipment planned for the second, and none of that risk has anything to do with your product.
3. Utilisation clawback
Australia now ties next year's allocation to this year's behaviour. Importers who fail to bring in at least 75 per cent of their approved volumes see the following year's forecast reduced to match what they actually imported, and repeat offenders can face caps. By April 2026 the ODC confirmed that 89 per cent of importers had their 2026 estimates adjusted. Under-shipping a buyer shrinks the room that buyer can offer you next year.
4. The quota sits underneath the permit chain
The mechanics of the two-permit sequence are covered in our guide to the cannabis import permit chain: the destination authority issues first, Health Canada matches against it. What that guide does not price in is the layer beneath. An importer cannot be issued a permit at all if the national allocation behind it is spent, which is why a permit application can be complete, accurate, and still go nowhere for eight weeks.
So read the quota position before you read the permit timeline. A producer who books rooms and harvest slots off a buyer's verbal forecast, without ever seeing where that buyer sits against the national ceiling, is not managing supply. That is guessing. Our walkthroughs of the Health Canada export permit process and narcotics import permit lead times cover the paperwork once the room exists.
What to ask a buyer before committing production
Four questions separate a supply relationship that survives a quota event from one that does not. Put them in writing before you commit rooms, harvest slots, or a fixed volume to a contract.
- What volume did you forecast to your regulator this year, and how much of it is still unused?
- How many open import permits are you holding, and when do they expire?
- If your national estimate is revised down, where does our volume sit in your priority order?
- Who tells us, and how fast, if permit issuance pauses?
The last one carries the most weight. Germany's September pause reached trade press within days, but the producers who handled it well were the ones whose importers called them directly and re-sequenced shipments into the following quarter, rather than leaving finished product to age in storage while the number was renegotiated.
Quota pressure also rewards readiness. When a ceiling reopens on a Monday and every importer wants product moving by Friday, the supplier who can release inside a two-week window takes the volume. Current batch release, valid analytical panels, and export documentation already assembled stop being hygiene factors and start being the deciding factor.
AlphaLeaf is a Montreal-based Health Canada Licensed Producer of indoor-grown, hand-trimmed cannabis flower with refined genetics and full batch traceability. We hold export authorisation under the Cannabis Act and keep ISO/IEC 17025 tested batch data and release documentation in a state that lets a European or Australian importer file inside a narrow permit window instead of waiting on paperwork.
If you are qualifying Canadian supply for 2026, our international supply page sets out the markets we are authorised into, and the export team is reachable through the contact page. Ceilings will move again this year. They always do. The question is whether your supplier is ready when they move.
Frequently Asked Questions
What is a cannabis import quota?
A cannabis import quota is the maximum quantity of cannabis a country may bring in during a calendar year under the 1961 Single Convention on Narcotic Drugs. The figure comes from estimates the government files with the INCB. Once the Board confirms it, national regulators cannot issue import permits beyond that ceiling.
Who sets cannabis import quotas?
The importing government files its own estimate and the INCB confirms it. Domestic regulators then administer individual permits inside the confirmed ceiling: BfArM in Germany, the Office of Drug Control in Australia, and Health Canada on the Canadian export side.
Can a country raise its cannabis import quota during the year?
Yes. A government can file a supplementary estimate and ask the INCB to confirm an increase. Germany did this twice in 2025, moving its ceiling from 122 tonnes to roughly 192.5 tonnes on 20 October 2025 after the original allocation was exhausted in September.
What happened to Germany's cannabis import quota in 2025?
Germany exhausted its 122 tonne allocation by September 2025 and BfArM paused approval of new import permits for roughly two months. The ceiling was raised to about 192.5 tonnes on 20 October 2025. Actual imports still finished the year near 201 tonnes, above the revised figure.
Why did the INCB reduce Australia's cannabis import quota?
The INCB cut Australia's 2025 quota from 101 tonnes to 88 tonnes in October 2025 because actual imports were running well below what importers had forecast. Unused and partly used permits were holding capacity that other applicants could not reach.
Does a Health Canada export permit guarantee a shipment can enter the destination country?
No. Health Canada issues an export permit against an import permit the receiving country has already granted. If that country's quota is exhausted or its regulator has paused issuance, no import permit exists and the Canadian export permit cannot be used.
