The legal status of cannabis in Canada, Germany, and South Africa: A scoping review

Abstract

Introduction: The legalisation of cannabis presents significant legal and policy challenges. While some countries have adopted structured, evidence-based reforms, South Africa remains within a fragmented and unclear framework. This study provides a comparative analysis of legalisation frameworks in Canada, Germany, and South Africa examining the impacts of each country’s model. Background: A comparative analysis was undertaken of cannabis legalisation frameworks in Canada, Germany, and South Africa to assess their regulatory approaches and their impacts on legal clarity, regulatory completeness, economic opportunities, and the management of illicit cannabis activities. Method: A structured scoping review was conducted using peer-reviewed articles, legal frameworks, and non-peer-reviewed policy documents. A five-stage review process guided data selection and analysis, focusing on legal themes, regulatory trends, and evidence gaps. Stakeholder consultation was excluded from the scope of the study.