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Cannabis clubs in Uruguay: The challenges of regulation
Accepted Manuscript Title: Cannabis Clubs in Uruguay: The Challenges of Regulation Author: Rosario Queirolo Maria Fernanda Boidi Jos´e Miguel Cruz PII: DOI: Reference:
S0955-3959(16)30169-4 http://dx.doi.org/doi:10.1016/j.drugpo.2016.05.015 DRUPOL 1797
To appear in:
International Journal of Drug Policy
Received date: Revised date: Accepted date:
15-9-2015 2-5-2016 26-5-2016
Please cite this article as:http://dx.doi.org/10.1016/j.drugpo.2016.05.015 This is a PDF file of an unedited manuscript that has been accepted for publication. As a service to our customers we are providing this early version of the manuscript. The manuscript will undergo copyediting, typesetting, and review of the resulting proof before it is published in its final form. Please note that during the production process errors may be discovered which could affect the content, and all legal disclaimers that apply to the journal pertain.
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Cannabis Clubs in Uruguay: The Challenges of Regulation
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Dr. Rosario Queirolo Universidad Católica del Uruguay Montevideo, Uruguay [email protected]
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Dr. Maria Fernanda Boidi Insights Research and Consulting Montevideo, Uruguay [email protected]
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Dr. José Miguel Cruz Kimberly Green Latin American and Caribbean Center, Florida International University Miami, Florida, United States [email protected]
Acknowledgements:
The authors wish to thank Universidad Católica del Uruguay and the Open Society Foundations whose joint efforts funded data collection for this project. Special thanks go to Alejandra Triñanes and Mauricio Coitiño for their work as Research Assistants. We are grateful to two anonymous reviewers that helped us to better contextualize Uruguayan Cannabis Clubs and the differences among them and their counterparts in other parts of the world. Finally, our gratitude goes to all the authorities and members of cannabis clubs who opened their doors to our project. This paper is our sole responsibility.
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Conflict of Interest: There are no conflicts of interest posed by either the authors or the submission of this manuscript.
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Cannabis Clubs in Uruguay: The Challenges of Regulation
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Abstract
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Background: The Uruguayan Cannabis Clubs (UCCs) constitute one of three ways to obtain marijuana under the new marijuana regulation laws. These organizations, formed by up to 45 adults and with a legal limit to grow up to 99 plants, appear to provide a safe method of procuring marijuana in a country that is trying to regulate aspects of marijuana production and distribution. This article describes the operations of the UCCs and the challenges these organizations face. Methods: The paper draws on data from indepth interviews conducted with representatives of UCCs and conversations with government officials conducted between March and August of 2015. We collected information about membership, facilities and forms of organization, methods of marijuana cultivation and distribution, and activities within the community. Results: This article describes how UCCs are formed, their resources, rules for marijuana production and distribution; and their relationships with government institutions and the community. Data show that UCCs face four main challenges: compliance with the extant regulation, financial sustainability, tolerance from the community, and collective action dilemmas. Conclusions: Organizational challenges are as frequent in Uruguay as in other country where cannabis clubs exist, however this paper shows that in order to be sustainable, UCCs need to address issues of collective action, financial sustainability, and possible competition with marijuana distribution via pharmacies that could diminish membership. In the case of Uruguay, UCCs are part of regulation effort, though they may not be preferred over other legal alternatives already in place.
Keywords:
Marijuana, cannabis social clubs, Uruguay, regulation, supply side, activism
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Background
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Cannabis clubs constitute one of three ways in which the new Uruguayan law (Law 19,172) regulates production, distribution and consumption of marijuana and allows
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nationals to obtain cannabis. Other modes of access include self-cultivation and purchasing marijuana at pharmacies. Currently, these three methods are mutually
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exclusive and individuals must choose one legal way to obtain marijuana, and register with the Uruguayan IRCCA (Instituto de Regulación y Control del Cannabis). Sales
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through pharmacies are yet to be implemented, hence users can obtain legal marijuana either as cannabis club members or as registered home producers.
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The Uruguayan experience is unique because this is the first time that cannabis social clubs (CSCs) have operated in a post-cannabis regulation regime; all other
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examples have operated in pre regulated regimes. Marijuana can be acquired through
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CSCs where cannabis production is illegal (Bewley-Taylor, Blickman, & Jelsma, 2014;
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Caulkins, Hawken, Kilmer, & Kleiman, forthcoming; Decorte, 2014; Parés Franquero & Bouso Saiz, 2015). However when other legal options are available, CSCs might not be the preferred mode of acquisition. Uruguay provides a unique pilot site for this to be tested.
CSCs are considered legal private organizations of adult users who cultivate
cannabis collectively for their own consumption, with no motivation for profit (Barriuso, 2011; Decorte, 2014; Kilmer, Kruithof, Pardal, Caulkins, & Rubin, 2013; Parés Franquero & Bouso Saiz, 2015; Room, Fischer, Hall, Lenton, &Reuter, 2010). Governments allow CSCs through decriminalization policies, court rulings, legal black holes or simply by lack of enforcement of prevailing drug laws (Bewley-Taylor, Blickman, &Jelsma, 2014; Decorte, 2010; Potter, 2010; Decorte, Potter & Bouchard, 4 Page 4 of 29
2011). When consumption is legal but production remains illegal, CSCs are considered an efficient way to undermine the power of black markets. Cannabis producers organize themselves in informal networks to maximize their production, and avoid buying
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marijuana from dealers (Decorte, 2014). CSCs exist in Argentina, Colombia, Chile, and several European countries such as
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Spain, Belgium, United Kingdom, France, Slovenia, Italy, The Netherlands and Switzerland (Bewley-Taylor, Blickman, & Jelsma, 2014, Decorte 2014). In Canada, a
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particular form of club, named “compassion clubs” has been developed for patients who
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use medical marijuana (Capler 2010; Feldman & Mandel 1998; Hathaway & Rossiter 2007).
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Their organizational structure and expansion mostly depends on the marijuana regulations in place in each country. The most widely known experience is “The
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Spanish Model,” which was initiated in the early 1990s (Parés Franquero & Bouso Saiz,
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2015) and has expanded in the regions of Catalonia and the Basque country. Although CSCs are widespread in Spain, with more than 900 groups established across the
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country, there is still uncertainty regarding their legal status (Arana & Sanchez, 2011; Aviles 2015; Kilmer, Kruithof, Pardal, Caulkins, & Rubin, 2013). As of 2015, CSC clubs in Catalonia are frequently inspected, suspended, or even closed down by city officials.
In countries where production, commercialization and consumption of marijuana are
not entirely legal, CSCs offer several advantages. Clubs can control the quality of the product, create jobs, and reduce risky consumption (Decorte, 2013; Caulkins, Hawken, Kilmer, & Kleiman, forthcoming). A possible caveat, however, is that CSCs could be used as a cover for profit-driven business operations.
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In Uruguay, CSCs are a novelty and did not exist in pre-cannabis regulation times. Furthermore, the first draft of the regulation did not take CSCs into account. Uruguayan activists connected with the ENCOD network (European Coalition for Just and
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Effective Drug Policies) and international activists pushed for their incorporation (La Diaria, 2012) in Law 19,172. The legal context in which CSCs operate in Uruguay is
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safer than other contexts. While in other countries CSCs function in a grey legal zone, in Uruguay they are one of the legal ways to obtain marijuana under the new regulation.
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It can be said that this collective approach is appealing to consumers because it contends
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with two other forms of cannabis procurement: pharmacies and home cultivation. Contrary to contexts with limited or non-existent marijuana regulation such as
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Spain, where CSCs became widespread because they were able to operate in a grey zone, membership of Uruguayan Cannabis Clubs (UCCs) is the least preferred option
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among frequent consumers. In Uruguay consumers can choose from three legal options
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for acquiring marihuana, but in Spain CSCs are the only legal option. The situation in Belgium has similarities with the Uruguayan case. While CSCs in Belgium operate in a
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non-regulated cannabis market and are prone to intervention by law enforcement as in Spain, they have not became widespread because consumers can cross the border and buy legal marihuana in Netherlands’ coffee shops.1 In other words, unlike the Spanish, Belgians and Uruguayans have alternatives to CSCs to buy legal marihuana.
According to a recent survey of frequent consumers in Montevideo, of those
users who consume marijuana at least weekly and plan to become registered consumers, only 13 % expressed their intention to become a member of a CSC; the rest either plan
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We thank one of the anonymous reviewers for making the point on the importance of activists for the inclusion of CSC in the Uruguayan regulation. Also, one reviewer explained to us how coffee shops in the Netherlands attract consumers from Belgium and might be part of the explanation that CSC have not became more widespread.
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to buy marijuana at pharmacies (56%)2 or grow their own plants at home (30%)3 (Boidi, Queirolo & Cruz, 2015). It is unsurprising that CSCs are the least preferred option in a country where marijuana is legal and there are alternatives sources of supply. Based on
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interviews with club members and authorities, this paper describes the initial functioning of CSC in Uruguay and points out the personal motivations for opening a
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cannabis club, perceived advantages, as well as problems faced by these organizations.
Because there is no previous study of Uruguayan CSCs, this is an exploratory
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research project and intends to serve as a baseline for future work. The Uruguayan
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experience with CSCs is a special case due to the regulated context and, as a result, the description we present can help the academic community and policy makers in Uruguay
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and elsewhere to evaluate the CSC phenomenon in regimes where cannabis is highly
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regulated.
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Regulation of Cannabis Clubs
To form a legal Cannabis Club in Uruguay, members have to fulfill three
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bureaucratic requirements. First, they need to get approval to run a non-profit organization (making it explicit that its sole purpose is to cultivate and distribute cannabis among its members). Secondly, they must register with the Ministry of Education and Culture. Thirdly, once the members get approval, their newly-formed organization must register with the IRCCA (IRCCA, 2014). In order to complete the first step, approval to run non-profit organization, they
need to comply with a number of legal requirements: they must show evidence of a foundational board of at least 15 original members and obtain the seal of a certified 2
Buying at pharmacies is not available as of January 2016. The government has carried out a public bid and decided which companies will produce cannabis, but it will take several months to have the marihuana at the pharmacies. 3 This preference distribution comes from a Respondent Driven Sample (RDS) study of frequent marijuana consumers (consume at least one a week) of age 18 or more, who live in the Montevideo metropolitan area. The study surveyed 294 individuals. Data collection took place during November and December 2014.
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public notary. Officers of the organization must be appointed from these 15 members and include a board with a President, Secretary and Treasurer plus three alternates as well as an Auditing Committee which includes all the above.
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After registering as a non-profit with the Ministry, the club needs to register with the IRCCA. This procedure requires the club founder to set an appointment with the
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Support Office of the Uruguayan Postal Service to begin the registration process.4 The authorized representatives for the registration process are the regular board members
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who must identify themselves at the time of registration. The Uruguayan Postal Service
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official will digitalize the club’s information as well as the founders’ personal data according to the requirements set down by the IRCCA. The information collected in the
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IRCCA form includes address and contact details, basic crop information, Technical Manager’s personal data, and opening hours. Club authorities must present the articles
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of incorporation and the founding charter of the club, along with the founding members’
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personal data. This information is considered sensitive, and once entered, will only be accessible to IRCCA staff.
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At the time of registration, the club must submit a list of documents, including
notarized and duly approved bylaws that are also authorized by the Ministry of Education and Culture; notarized copy of the minutes listing all personal data of the founding members of the club; date of birth and proof of address of each founding member; and proof of address or utility bill on behalf of the non-profit organization; documents certifying ownership, lease, possession or any other title by which the nonprofit organization is authorized to be headquartered at the property where the crop is to be grown. Additionally, the government requires a Crop Plan describing technical and
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The Postal Service has been chosen by the Uruguayan authorities as the institution to register all cannabis users because of its presence throughout the country. Individual growers register there, as do members of UCCs, through the club authorities. It is expected that once the sales through pharmacies mechanisms is in place, consumers will also have to register at the Post offices
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security protocols of the plantation development and a plan for the distribution of cannabis to club members. These are reviewed by the IRCCA who then conduct an on-site inspection to
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determine: Club operations: 1) days and times of activity; 2) adjacent areas (occupation or
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use of adjacent areas with chairs, tables or canopies is forbidden, and hygiene must be maintained in these areas); 3) any club activity out of the designated time reserved for
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such activities is prohibited, except for maintenance and cleaning; 4) advertising,
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promotion and sponsorship on facades is prohibited; 5) crop plan and delivery system reports; and 6) the club must respect a minimum distance of 150 meters from any
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educational facility for students under 18 and/or addiction treatment centers. Regarding infrastructure, the club is required to have a space exclusively
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devoted to cultivation, and signs identifying the club as such a facility are prohibited.
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Security is another important issue: Cultivation space should be secured. Plants cannot be taller than the height of the walls bordering the club’s grounds, and access to outside
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plants is forbidden. In addition, clubs need to have a security system covering points of entry, exits and perimeter openings. Club monitoring equipment must be in operational order at all times and access to club premises by minors is forbidden. If one or several of these requirements are not met, the inspection shall point out the corrections to be made. The whole process can take more than a year. Up to August 2015, around 20 UCCs had started this process; seven have
registered with the Ministry of Education and Culture, but only two have been inspected and authorized by the IRCCA. In spite of this detailed regulation, several questions remain open. One frequent concern of clubs is what should be done with the excess marijuana. It is not clear whether it should be disposed of or stored or whether it could
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be used in the manufacture of lotions and/or oils. Moreover, the process is quite complex and many UCCs have found it difficult to submit their documents and set up their cultivation sites. Most experienced clubs, which are the offspring of the activist
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movement, have offered to guide new clubs through the lengthy and sometimes confusing registration process.
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Methods
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Data presented here come from two main sources: documentary research and interviews with club officials and members. Through documentary research, our team
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collected official documents (laws and regulations, as well as guidelines provided by the IRCCA) and information published on diverse national media outlets on marijuana
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regulation in general and cannabis clubs in particular. Data collection activities started
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in March 2015 and were completed in August 2015. The three PIs of the project were
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directly involved in fieldwork activities with three well-trained Research Assistants. Due to the classification of their registry as sensitive information, there is no
publicly available record of cannabis clubs. From information available in the media and directly from the clubs themselves, we estimate that about 20 organizations have started the process to become fully-fledged cannabis clubs. Of these 20, only two have completed stages one and two and have been granted authorization to proceed further. This has been confirmed by the club themselves and by the IRCCA. All the others are at different stages of the registration process and moving at different speeds. For this stage of our project, we targeted as many clubs as possible, establishing relationships with them through a variety of mechanisms. For example, we used existing bonds within the pro-marijuana regulation activist coalition; we relied on 10 Page 10 of 29
references from other clubs; and finally, we used our existing connections from a previous study of frequent marijuana consumers (Boidi, Queirolo & Cruz, 2015). Unlike Belgian clubs (Decorte, 2014), UCCs do not have a large Internet presence,
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which makes them difficult to find and contact. For example, only two have a Facebook account. Most do not have an official email address. In total, we were able to reach and
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collect extensive information about eight of the 20 organizations through interviews with their officials and members.
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In all cases, we interviewed authoritative voices for the clubs: members of the
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board, chief gardeners or highly involved members.5 We interviewed one person per club, all men. Four of the clubs allowed us to visit to conduct face-to-face interviews
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and they showed us their plantations, even allowing us to take pictures. Three other clubs preferred not to disclose the club location, and we met their representatives in
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another venue. One of the clubs granted an interview at the last minute and for practical
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reasons this was done by phone.
We were unable to contact all prospective UCCs, either because they were
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unreachable through our networks, or because they refused to provide information and wished to remain anonymous, even declining a confidential interview. These groups are essentially interested in becoming UCCs as a way to get marijuana. During interviews, UCCs representatives were asked a series of questions from an open-ended questionnaire. These dealt with the history of the club and membership conditions, the organizational structure and finances, their cannabis production system, the way in which they distributed their product, any other activities in addition to producing and 5
For four of the clubs surveyed, we interviewed a member of the Club Board of Directors. In two cases, the interview was granted by the Chief Gardener, which turns to be the person with the most knowledge about the club daily activities (in many cases this individual also functions as the club administrator). One of the clubs with a more activist profile has a speaker to talk to media and researchers, and we interviewed this person. In the remaining club, we interviewed a club member with full knowledge of the club activities; this member was granted permission from the club authorities to speak on their behalf.
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distributing cannabis; their relationships with other UCCs, the IRCCA, the police and neighbors; their future plans and the advantages and challenges of being part of the cannabis club. The questionnaire replicates some questions asked in the study on
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Belgian clubs (Decorte, 2014). For those UCCs whose facilities were open to visits, we also toured their facilities, and assessed infrastructure, security installations and
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indoor/outdoor production systems.
Most of the eight surveyed cannabis clubs were located in Montevideo, the capital
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city. Only two were located outside the capital: one in Florida (near the center of the
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country) and another one in Maldonado (in the Eastern region).
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Results
According to the UCCs representatives, cannabis clubs have two main purposes:
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granting access to marijuana and activism. It is clear that the UCCs have the goal of
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providing legal, affordable, high-quality, and readily available marijuana with co-
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production providing a solution to the underproduction that single growers can face.6 But this is not the only purpose of UCCs. For some activism is crucial. Several clubs want to raise awareness and share knowledge about cannabis among their members and society in general.
These different goals establish an important distinction among cannabis clubs.
On the one hand, there are clubs that are only concerned with getting access to good quality marijuana; these tend to be very private, difficult to access and have a closed membership formed by friends and relatives. We were not unable to interview most of them, but based on our attempts to collect some information, we can assume that they
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This is the ideal scenario, but it does not always work that way. Interviewees reported the real experiences of the clubs, e.g. in one all the plants were stolen and in another one all plants died.
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account for half of the groups that started the process of becoming official UCCs. Most were assisted by AECU (Asociación de Estudios Canábicos del Uruguay) in the initial stages but they are organized in different ways. There is a second type of UCC where, in
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addition to providing access to marijuana, activism plays an important role. These clubs are open and easy to reach, and eager to explain the advantages and problems they face.
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Some are organized as cooperatives with members who pay with work when they do
not have money, to clubs with paid staff and expensive membership fees. In spite of this
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variation, most of have ties with the IRCCA, other clubs, and the Federation of
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Growers.
In light of this, results are presented in six subsections: Origins, Membership,
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Clubs Facilities and Organization, Cannabis cultivation, Cannabis Distribution, and
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Activities. Detailed information is provided in Table 1.
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Origins
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[TABLE 1 AROUND HERE]
The organizations that became the current cannabis clubs followed different
paths to becoming fully established. The first clubs, and most of those that show greater institutional strength, stemmed from parent organizations linked to some form to cannabis-related activism. Club A stemmed from Movida Cannábica Florida (Florida Cannabis Movement), the first pro-cannabis movement located outside Montevideo. Club B was formed by members of the pro-regulation organization Pro-Derechos, and Club C was formed by members of the Asociación de Estudios Canábicos de Uruguay (AECU, Uruguayan Cannabis Studies Association). Finally, Club E was formed by members of the Red de Usuarios de Drogas (Network of Drug Users). Not surprisingly,
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these clubs are also the ones engaged in additional activities, from activism to cannabis cultivation and distribution. Another type of club according to origin is that formed by groups of friends
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whose aim is to secure access to safe and affordable marijuana: Club F, Club G, and Club H fall into this category. Though similar, Club D is not entirely of this kind, as it
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was formed by the initiative of a single individual.
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Membership
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The law cites that a cannabis club should have between 15 and 45 members. All the clubs that we surveyed complied with the regulation. However, not all had reached
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their maximum membership. Some had 17-18 members, such as Club A and Club G, and still had room for new members. The rest has reached their maximum membership
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and operated a waiting list for new members. Most members were young people,
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between 18 and 40 years of age and male. Only Club B and Club G had an evenly split membership between males and females. There are clubs mainly formed by lower- and
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middle-class people, such as Club A and Club E, while in others the membership is from upper-middle class (Club B and Club C). This distinction is relevant because most of the upscale clubs are ones in which activism is less relevant and the main goal is access to marijuana. In other words, the access-activism distinction seems to be related to socioeconomic level.
Members are recruited following two main criteria: personal acquaintance and
recommendation. In order to be admitted to a club, new members must be introduced by an existing member. As a result, clubs membership is cultivated principally by friends and relatives. In addition, commitment to collective work (Club E) or activism (Club B) is essential for some clubs. For others, like Club D, there are no such requirements. In
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most clubs, members use marijuana for recreational purposes and on a daily basis. There are some clubs where a few members use marijuana for medical reasons.7
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Club Facilities and Organization In half of the surveyed clubs, the location was rented, and in the other half the
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property (either the house or the land itself) was owned by a member. Clubs that rented
their location are those with middle- and high-income members, while those that own
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the site were clubs with lower- and middle- class members. Following the same
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distinction, more up-scale clubs had paid personnel: in most cases a Gardener and one Administrator. In clubs with less affluent members, there were no employees and
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membership fees could be paid with work.8 Also in Club C, if a member worked for the club, that person received a discount on their monthly membership fee.
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Fees varied considerably. The total amount of marijuana that a member is legally
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allowed to obtain is up to 40 grams per month. The fees for that quantity varied from 26 to 92 dollars per month.9 In most cases, the payment is fixed but there are exceptions.
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Club E has a voluntary contribution, but the ideal fee is fixed at 40 dollars per month. Some clubs like Club D have a differential fee depending on the amount of marijuana used: 64 dollars per 40 grams, 40 dollars per 25 grams, and 16 dollars per 10 grams. In some clubs, membership fees are mandatory, but in others, members pay for the amount they consume.
Cannabis Cultivation
Cannabis clubs in Uruguay combine indoor and outdoor cultivation. There are exceptions where only indoor (Club C) or outdoor (Club D) cultivation is performed. 7
The regulation for medical marijuana production was passed after the recreational marijuana regulation. As a result, even less is known about it. 8 For example, members can work in harvesting, drying and curing. 9 Fees are charged in Uruguayan pesos. For comparative reasons, we converted Uruguayan pesos to the value of the dollar in August 2015.
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Outdoor production is used during the warm season and indoor production is employed during winter. Alternating cultivation systems is a technique growers use to avoid a drought period. The Uruguayan regulation allows the UCCs to have up to 99 flowering
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plants at any one time. Clubs declared that they had from 20 to 99 plants at time of our interviews. The declared productivity of the plants also varies depending on the club:
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from 50 to 200 grams per plant in indoors facilities, and from 350 grams to 3 kilograms for outdoor cultivation. This variance in productivity seems to be an indicator of
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productivity in other more experienced farm activities.
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inexperience in marijuana cultivation. It is difficult to find such differences in per plant
There was also little knowledge about levels of cannabinoids THC and CBD in
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the marijuana. Most of the clubs reported a THC level of around 15% or higher, but say this is just an estimate. Few UCCs have gone through the process of testing the flowers
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and the only information they have is that provided by the seed producer. Only one club
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declared that they had knowledge of CBD levels. The clubs with members who consume for medical purposes did not have information regarding CBD despite that
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chemical being the most useful component for medicinal users.
Cannabis Distribution
The ways in which clubs distribute marijuana to members also differed
significantly. Most of the clubs dispensed only at harvest time; others do it monthly; and a third group did it upon request or at any time they could. This complicates matters for inspection because the regulation states that each member may only get access to a maximum of 40 grams per month. In the clubs where distribution is on request, quite often members stopped by several times per month, and in order to comply with the law, the UCC should register amount taken by the member until 40 grams is reached.
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Currently, only two clubs were producing enough to provide each member with 40 grams.
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Activities
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As noted, there is an important distinction between cannabis clubs whose sole purpose is to provide marijuana to members, and those where activism is crucial. In this
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second group, in addition to social meetings, UCCs organized activities related to risk reduction, prevention, and education. Club B, for example, required members to
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participate in educational and promotional activities. Club E is defined, more than just as a club, but rather as a cooperative of producers in which each one brings what he or
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she has: expertise, manpower, money, etc. Resources are then used to carry out music workshops, courses on cannabis home cultivation, or risk reduction events.
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CSCs are promoted as a harm-reduction policy in countries where marijuana has
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not been fully regulated because they produce a less dangerous substance than that
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available on the black market. Cannabis clubs provide information on the potency and effects of their varieties as well, thereby allowing users to have more control over their levels of consumption (Belackova, Tomkova & Zabransky, 2015). In Uruguay, where the marijuana market is regulated, several UCCs also play that role.
Challenges and Problems faced by UCCs There were several challenges mentioned by the UCCs representatives in interviews. We group those into four categories: compliance with the regulation, financial sustainability, tolerance from the society, and collective action dilemmas. It is easy to see from the long description in the Background section that complying with the
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procedures to become a full-fledged UCC is a difficult task, or at least an endeavor that needs patience and some proficiency. In addition, several club representatives complained about the lack of guidance from government authorities. Part of this may be
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explained by the scarcity of a Human Resources department at the IRCCA, which leads to long delays in answering requests and questions. Apart from demanding more and
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faster responses from officials in charge of controlling the regulation, interviewees were uncertain about what was to come, and expressed concern about the enforcement of the
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regulations.
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Financial sustainability was another concern. There were several cannabis clubs underestimated their operation costs and have since found themselves in dire financial
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straits. Moreover, the UCC representatives questioned the limit of 45 members per club and argued that it is very difficult to cover fixed costs while keeping a reasonable
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membership fee. Among these fixed costs, interviewees mentioned rent, gardening and
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administrative staff salaries. They also highlighted the burden of security systems (alarms, video cameras, electric and regular fences). Some of these problems could be
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solved by increasing club membership, as is done in Spain, where CSCs have hundreds, even thousands of members who share the collective cost burden. An alternative solution presented by a number of UCCs was to share the land for cultivation among three UCCs and thereby lighten the high costs of renting and security. However, the IRCCA denied their request and ruled that UCCs needed to be separated by a distance of 1000 meters. Thirdly, there were concerns related to the misunderstanding in society about UCCs which has led, in some cases, to neighbors filing police reports. Police responses to a neighbor’s claim were also full of ambiguities and lacked any standard procedure. However, in August 2015, a police protocol was finally approved. It states
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that no police action can take place without a judicial order. Activists played a crucial role in this measure.10 Finally, UCCs have faced certain “collective action dilemmas”.
Those
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dilemmas were more important for organizations in which activism was a goal. Several of the UCCs thought that members should contribute not only with fees but also with
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voluntary work. However while participation in activism and volunteering for work in cultivation and care was easy to obtain in the beginning, later people started to make
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excuses. In order to avoid the free-rider problem, some UCCs started to charge a lower
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fee to those who contributed manpower, generating a positive incentive to participate. One of the interviewees summarized this in a very clear way saying that “Reality tops
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fiction… and ideology as well”. .
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Conclusions
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In Uruguay, cannabis clubs are one of the three legal ways in which users can
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obtain marijuana. They enjoy a supportive legal framework in which to operate that makes them less vulnerable than in others countries where they have become a popular alternative source. Despite different legal framework for CSCs in Spain, Belgium, and Uruguay; these organizations share some problems, although certain challenges are exclusive to the Uruguayan experience. The following contains a preliminary SWOT analysis of UCCs. 11
Starting with the strengths: the most important strong point is the CSCs’ legal status in Uruguay. Contrary to the grey legal realm occupied by associations in countries where marijuana has not been fully regulated, the UCCs and their members 10
“Protocolo de Actuación Policial sobre Ley de Marihuana y sus Derivados”. Retrieved 10 September 2015 from http://www.infodrogas.gub.uy/images/stories/pdf/Protocolo_policial_cannabis.pdf. 11
Following an appropriate comment made by one of the reviewers, we focused the analysis on strengths, weaknesses, opportunities and threats.
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are protected by comprehensive regulation, and until now, no significant problems with police or the judicial system have been reported. One of the main arguments for becoming a UCC member is the possibility of
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access to a high-quality product. No doubt this is one of the main opportunities that CSCs have in Uruguay and elsewhere – namely that they can keep strict control of the
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substance they are producing and control distribution among members. In Uruguay, we consider this dynamic as an opportunity rather than strength because most of the
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interviewed members still did not have enough information about the varieties and
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quality of the marijuana they were consuming. Employment and taxes are also opportunities, but currently UCCs have more financial problems than economic
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advantages.
They also share the threat of becoming a for-profit enterprise- something that is
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explicitly prohibited in Uruguay as well as in other countries where CSCs first emerged.
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The suspicion that CSCs can hide a profitable marijuana business is always present. This partly explains the Uruguayan limitation on club membership (up to 45) and the
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amount of marijuana that each member can receive (40 grams a month). Organizational aspects are highlighted as weaknesses in Uruguay as well as in
Belgium and Spain (Arana &Sanchez 2011, Decorte 2014). Challenges range from defining an appropriate delivery system to providing a high-quality product. Moreover, as a result of the dual purpose of some clubs (access to marijuana and activism), CSCs have to establish appropriate membership duties. It is not uncommon to find problems concerning collective action in social organizations, and CSCs are no exception. Other weaknesses faced by clubs in Uruguay are specifically related to country regulations, context and institutions. The creation of a UCC is complicated, the founding members need to constitute an assembly of 15 people and start collecting all
20 Page 20 of 29
the paperwork needed to become an official cannabis club. Until now, delays from one step to the next have been significant. For example, representatives declared that after being registered with the Ministry of Education, it can take months to be registered with
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the IRCCA. This is a design flaw of the regulations and a bureaucratic nightmare. Interviewees also mentioned that regulations have considerable gaps and can require
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further guidance from the IRCCA in order to continue with the registration process. To add insult to injury, those answers can take considerable time to arrive. This is also a
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problem of institutional design, because the IRCCA does not have the resources to
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prevent delays and provide guidance in a timely manner. At time of writing, the registry had been opened for 10 months but only two of 20 UCCs that started the process had
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obtained official authorization12.
These two sets of problems - difficulties with regulation and challenges related
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to the institutional design - can be easily tackled. Regulations can be modified in order
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to make the paperwork process more efficient, and an adequate budget can be provided to the agency in charge of the regulation. With regard to the institutional design
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challenges, it is important to remember that the marijuana regulation law made its first steps in a changing political context. It was passed at the beginning of a presidential campaign and its implementation began almost at the same time as changing of the guard from one administration to the next13, which surely had an impact on the speed of implementation of the new laws. The problems mentioned are easy to solve. But our survey of UCCs, highlights
two weaknesses and a risk that calls into question whether UCCs could become a popular and sustainable model, as is the case in other parts of the world. Starting with the weaknesses, we note that in order to accomplish their goal of providing marijuana to 12
Cannabis clubs registry was opened on the 30th of October, 2014. Though government remained in the same political party, the left of center Frente Amplio, a new President with a different agenda was elected and a new Secretary of the National Bureau of Drugs has been appointed.
13
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members, clubs in Uruguay need to adjust their views of collective action, which stand in harsh contrast to reality. Some of the UCCs were created with the idea that every member would take an active role in club activities, but the experience reported by the
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interviewees is very different. If they fail to live up to expectations, it is highly probable that some UCCs will disappear. Second, certain restrictions in the current regulations
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make it even more difficult to survive, particularly that which limits membership to 45.
Fixed costs are quite high for some UCCs that cannot charge expensive membership
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fees. An alternative proposal to share fixed costs among a small group of UCCs was
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overturned by the IRCCA.
Additionally, we uncovered an important risk to the expansion of CSCs in
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Uruguay. Due to the fact that UCCs are just one of the legal options available to acquire marijuana in Uruguay, they have to “compete” with home cultivation and sale
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of the product at pharmacies. Home growing is not a simple process, so it is not
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necessarily an option for everyone. It takes time, dedication, and lots and lots of physical space that the average person does not have in their apartment or home.
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Purchasing at a pharmacy is the opposite: it is the easiest way to access marijuana and the impact that pharmacies could have on UCC membership is uncertain. Once marijuana becomes available at pharmacies, and if the product offered is of high quality, many UCC members may move to that method of procuring marijuana, thereby undermining the clubs’ sustainability.
[TABLE 2 AROUND HERE]
The future of CSCs is different in contexts where cannabis regulation does not exist than in countries where regulation is already in place. While in the first scenario
22 Page 22 of 29
we have prolific collective organizations with extensive memberships, in post-regulated regimes such as Uruguay, the whole enterprise may turn into nothing more than a secondary way to acquire marijuana, only used by a handful of activists. By describing
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the current situation of UCCs, this article should serve as a baseline study against which to monitor the evolution of CSCs and understand their role in cannabis use in different
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regulatory contexts.
23 Page 23 of 29
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References
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Arana, X., & Sanchez, V. M. (2011). Cannabis cultivation in Spain – The case ofcannabis social clubs. In T. Decorte, G. Potter, & M. Bouchard (Eds.), World wideweed: Global trends in cannabis cultivation and its control (pp. 163–177). London:Ashgate.
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Barriuso, M. (2011). Cannabis social clubs in Spain: A normalizing alternative underway.Series on legislative reform of drug policies, nr. 9.
M
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Belackova, V., Tomkova,A., &Zabransky T. (2015) “Qualitative Research in Spanish Cannabis Social Clubs: The Moment You Enter the Door, You Are Reducing Harms” Paper presented at the 9th Conference of the International Society for the Study of Drug Policy (ISSDP). Ghent, Belgium. May 19-22, 2015
te
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Bewley-Taylor, D., Blickman, T. &Jelsma, M. (2014).The rise and decline of cannabis prohibition. The history of cannabis in the UN drug control system and optionsfor reform. Amsterdam/Swansea: Global Drug Policy Observatory/TransnationalInstitute.
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Boidi, M.F, Queirolo. R.& Cruz, M. (2015) “Marijuana Consumption Patterns among Frequent Consumers in Montevideo.” Paper presented at the 9th Conference of the International Society for the Study of Drug Policy (ISSDP). Ghent, Belgium. May 1922, 2015 Capler, N.R. (2010) “Canada Compassion Clubs.” In Holland, J. (Ed.). The pot book: A complete guide to cannabis. Inner Traditions/Bear & Co. Caulkins, J. P., Hawken, A., Kilmer, B., &Kleiman, M. (forthcoming). Marijuana Legalization: What Everyone Needs to KnowRG. 2nd Edition.Oxford University Press.
Decorte, T. (2010). Small scale domestic cannabis cultivation: An anonymous websurvey among 659 cultivators in Belgium. Contemporary Drug Problems, 37(2),341–370. Decorte, T., Potter, G., & Bouchard, M. (2011). World wide weed: Global trends incannabis cultivation and its control. London: Ashgate.
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Decorte, T. (2014). Cannabis social clubs in Belgium: Organizational strengths and weaknesses, and threats to the model. International Journal of Drug Policy, http://dx.doi.org/10.1016/j.drugpo.2014.07.016 Feldman, H. W. & Mandel J. (1998) Providing Medical Marijuana: The Importance of Cannabis Clubs, Journal of Psychoactive Drugs, 30:2, 179-186
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Hathaway, A. D. & Rossiter, K. (2007) Medical Marijuana, Community Building, and Canada’s Compassionate Societies , Contemporary Justice Review, 10 (3), 283-296,
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IRCCA (2014). “Condiciones para la habilitación de los clubes de membresia. Funcionamiento, infraestructura y seguridad”. IRCCA: Montevideo.
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Kilmer, B., Kruithof, K., Pardal, M., Caulkins, J. P., & Rubin, J. (2013). Multinationaloverview of cannabis production regimes.Rand Europe – WODC – Dutch Ministryof Security and Justice. La diaria (2012, September 19). “En los papeles”. La diaria.
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Parés Franquero, O. & Bouso Saiz, J.C. (2015). Innovation Born of Necessity: Pioneering Drug Policy in Catalonia. New York: Global Drug Policy Program, Open Society Foundations.
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Potter, G. (2010). Weed, need and greed: A study of domestic cannabis production.London: Free Association Books.
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Room, R., Fischer, B., Hall, W., Lenton, S., &Reuter, P. (2010). Cannabis policy: Movingbeyond stalemate. Oxford: Oxford University Press.
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ip t Luz Verde
Location
Florida
Montevideo
Montevideo
Parent organization
Movida Cannabica Florida
PRODerechos
AECU
Current members
17
45
45
Recruitment
Trust/recom mendation
Trust/recom mendation
Waiting list?
No
Age
20-30
Gender
70% male
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El Piso
Manga Rosa
Pájaros Pintados
Gogollo Alegre UruRoots
Montevideo
Montevideo
Montevideo
Montevideo
Maldonado
NONE
Red de Usuarios de Drogas
NONE
NONE
NONE
45
15
45
18
35
Trust/recom mendation
No requirement
Trust/ Trust/recomme Trust/recomme Trust/recomme Commitment ndation ndation ndation to collective work
Yes
Yes
No
Yes
No
NO
18-38
20-30/40-60
20-30
19-44
25-35
30-40
Less than 35
40% male
80% male
70% male
87% male
89% male
60% male
86% male
ed
ce pt
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Yes
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CLUC
M an
Cofradia Hoja Roja
Page 26 of 29
ip t Marijuana consumption
Daily, recreational
Daily, recreational
Daily, recreational + 1 medical
No data
Paid personnel
No
1 Gardener
1 Gardener
1 Gardener/
Member monthly fee
UDS 40
yes
no
Middle class
Middle class
Middle and upper class
Daily, recreational and medical
No data
Varied
Varied
No
No
No
No
Low
Middle class
Middle class
M an
ed USD 92
ce pt
UDS 26
Ac
Can fee be reduced with
1 Administrato r
Low and
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Middle and upper middle class
Low and
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Middle class
Middle and upper middle class
SES
Administrato r
USD 64 (40grs) USD 40 (25 grs)
Voluntary USD 2 per gram, USD 50 contribution. up to 40 grams per month Ideal would be USD 40
USD 80
yes
no
USD 16 (10grs)
yes
no
no
yes
Page 27 of 29
ip t cr At harvest
Monthly
Quantity
Equally distributed among members
Equally distributed among members
Equally distributed among members
Anytime
On demand
M an
At harvest
Per request (members pay per what they get)
Per request
Monthly
When available Monthly
Per request
40 grams
40 grams
Ac
ce pt
ed
Frequency
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manpower?
Page 28 of 29
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Table 2.Preliminary SWOT Analysis for UCCs
Strengths
Legal framework
Organization Regulations and Institutional design Collective action problems High fixed costs
Opportunities
High quality product Control the product Revenues Taxes
ce pt
Become a for-profit enterprise Selling in pharmacies
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Threats
ed
Weaknesses
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S0955-3959(16)30169-4 http://dx.doi.org/doi:10.1016/j.drugpo.2016.05.015 DRUPOL 1797
To appear in:
International Journal of Drug Policy
Received date: Revised date: Accepted date:
15-9-2015 2-5-2016 26-5-2016
Please cite this article as:
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Cannabis Clubs in Uruguay: The Challenges of Regulation
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Dr. Rosario Queirolo Universidad Católica del Uruguay Montevideo, Uruguay [email protected]
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Dr. Maria Fernanda Boidi Insights Research and Consulting Montevideo, Uruguay [email protected]
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Dr. José Miguel Cruz Kimberly Green Latin American and Caribbean Center, Florida International University Miami, Florida, United States [email protected]
Acknowledgements:
The authors wish to thank Universidad Católica del Uruguay and the Open Society Foundations whose joint efforts funded data collection for this project. Special thanks go to Alejandra Triñanes and Mauricio Coitiño for their work as Research Assistants. We are grateful to two anonymous reviewers that helped us to better contextualize Uruguayan Cannabis Clubs and the differences among them and their counterparts in other parts of the world. Finally, our gratitude goes to all the authorities and members of cannabis clubs who opened their doors to our project. This paper is our sole responsibility.
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Conflict of Interest: There are no conflicts of interest posed by either the authors or the submission of this manuscript.
2 Page 2 of 29
Cannabis Clubs in Uruguay: The Challenges of Regulation
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Abstract
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Background: The Uruguayan Cannabis Clubs (UCCs) constitute one of three ways to obtain marijuana under the new marijuana regulation laws. These organizations, formed by up to 45 adults and with a legal limit to grow up to 99 plants, appear to provide a safe method of procuring marijuana in a country that is trying to regulate aspects of marijuana production and distribution. This article describes the operations of the UCCs and the challenges these organizations face. Methods: The paper draws on data from indepth interviews conducted with representatives of UCCs and conversations with government officials conducted between March and August of 2015. We collected information about membership, facilities and forms of organization, methods of marijuana cultivation and distribution, and activities within the community. Results: This article describes how UCCs are formed, their resources, rules for marijuana production and distribution; and their relationships with government institutions and the community. Data show that UCCs face four main challenges: compliance with the extant regulation, financial sustainability, tolerance from the community, and collective action dilemmas. Conclusions: Organizational challenges are as frequent in Uruguay as in other country where cannabis clubs exist, however this paper shows that in order to be sustainable, UCCs need to address issues of collective action, financial sustainability, and possible competition with marijuana distribution via pharmacies that could diminish membership. In the case of Uruguay, UCCs are part of regulation effort, though they may not be preferred over other legal alternatives already in place.
Keywords:
Marijuana, cannabis social clubs, Uruguay, regulation, supply side, activism
3 Page 3 of 29
Background
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Cannabis clubs constitute one of three ways in which the new Uruguayan law (Law 19,172) regulates production, distribution and consumption of marijuana and allows
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nationals to obtain cannabis. Other modes of access include self-cultivation and purchasing marijuana at pharmacies. Currently, these three methods are mutually
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exclusive and individuals must choose one legal way to obtain marijuana, and register with the Uruguayan IRCCA (Instituto de Regulación y Control del Cannabis). Sales
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through pharmacies are yet to be implemented, hence users can obtain legal marijuana either as cannabis club members or as registered home producers.
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The Uruguayan experience is unique because this is the first time that cannabis social clubs (CSCs) have operated in a post-cannabis regulation regime; all other
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examples have operated in pre regulated regimes. Marijuana can be acquired through
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CSCs where cannabis production is illegal (Bewley-Taylor, Blickman, & Jelsma, 2014;
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Caulkins, Hawken, Kilmer, & Kleiman, forthcoming; Decorte, 2014; Parés Franquero & Bouso Saiz, 2015). However when other legal options are available, CSCs might not be the preferred mode of acquisition. Uruguay provides a unique pilot site for this to be tested.
CSCs are considered legal private organizations of adult users who cultivate
cannabis collectively for their own consumption, with no motivation for profit (Barriuso, 2011; Decorte, 2014; Kilmer, Kruithof, Pardal, Caulkins, & Rubin, 2013; Parés Franquero & Bouso Saiz, 2015; Room, Fischer, Hall, Lenton, &Reuter, 2010). Governments allow CSCs through decriminalization policies, court rulings, legal black holes or simply by lack of enforcement of prevailing drug laws (Bewley-Taylor, Blickman, &Jelsma, 2014; Decorte, 2010; Potter, 2010; Decorte, Potter & Bouchard, 4 Page 4 of 29
2011). When consumption is legal but production remains illegal, CSCs are considered an efficient way to undermine the power of black markets. Cannabis producers organize themselves in informal networks to maximize their production, and avoid buying
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marijuana from dealers (Decorte, 2014). CSCs exist in Argentina, Colombia, Chile, and several European countries such as
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Spain, Belgium, United Kingdom, France, Slovenia, Italy, The Netherlands and Switzerland (Bewley-Taylor, Blickman, & Jelsma, 2014, Decorte 2014). In Canada, a
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particular form of club, named “compassion clubs” has been developed for patients who
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use medical marijuana (Capler 2010; Feldman & Mandel 1998; Hathaway & Rossiter 2007).
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Their organizational structure and expansion mostly depends on the marijuana regulations in place in each country. The most widely known experience is “The
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Spanish Model,” which was initiated in the early 1990s (Parés Franquero & Bouso Saiz,
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2015) and has expanded in the regions of Catalonia and the Basque country. Although CSCs are widespread in Spain, with more than 900 groups established across the
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country, there is still uncertainty regarding their legal status (Arana & Sanchez, 2011; Aviles 2015; Kilmer, Kruithof, Pardal, Caulkins, & Rubin, 2013). As of 2015, CSC clubs in Catalonia are frequently inspected, suspended, or even closed down by city officials.
In countries where production, commercialization and consumption of marijuana are
not entirely legal, CSCs offer several advantages. Clubs can control the quality of the product, create jobs, and reduce risky consumption (Decorte, 2013; Caulkins, Hawken, Kilmer, & Kleiman, forthcoming). A possible caveat, however, is that CSCs could be used as a cover for profit-driven business operations.
5 Page 5 of 29
In Uruguay, CSCs are a novelty and did not exist in pre-cannabis regulation times. Furthermore, the first draft of the regulation did not take CSCs into account. Uruguayan activists connected with the ENCOD network (European Coalition for Just and
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Effective Drug Policies) and international activists pushed for their incorporation (La Diaria, 2012) in Law 19,172. The legal context in which CSCs operate in Uruguay is
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safer than other contexts. While in other countries CSCs function in a grey legal zone, in Uruguay they are one of the legal ways to obtain marijuana under the new regulation.
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It can be said that this collective approach is appealing to consumers because it contends
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with two other forms of cannabis procurement: pharmacies and home cultivation. Contrary to contexts with limited or non-existent marijuana regulation such as
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Spain, where CSCs became widespread because they were able to operate in a grey zone, membership of Uruguayan Cannabis Clubs (UCCs) is the least preferred option
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among frequent consumers. In Uruguay consumers can choose from three legal options
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for acquiring marihuana, but in Spain CSCs are the only legal option. The situation in Belgium has similarities with the Uruguayan case. While CSCs in Belgium operate in a
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non-regulated cannabis market and are prone to intervention by law enforcement as in Spain, they have not became widespread because consumers can cross the border and buy legal marihuana in Netherlands’ coffee shops.1 In other words, unlike the Spanish, Belgians and Uruguayans have alternatives to CSCs to buy legal marihuana.
According to a recent survey of frequent consumers in Montevideo, of those
users who consume marijuana at least weekly and plan to become registered consumers, only 13 % expressed their intention to become a member of a CSC; the rest either plan
1
We thank one of the anonymous reviewers for making the point on the importance of activists for the inclusion of CSC in the Uruguayan regulation. Also, one reviewer explained to us how coffee shops in the Netherlands attract consumers from Belgium and might be part of the explanation that CSC have not became more widespread.
6 Page 6 of 29
to buy marijuana at pharmacies (56%)2 or grow their own plants at home (30%)3 (Boidi, Queirolo & Cruz, 2015). It is unsurprising that CSCs are the least preferred option in a country where marijuana is legal and there are alternatives sources of supply. Based on
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interviews with club members and authorities, this paper describes the initial functioning of CSC in Uruguay and points out the personal motivations for opening a
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cannabis club, perceived advantages, as well as problems faced by these organizations.
Because there is no previous study of Uruguayan CSCs, this is an exploratory
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research project and intends to serve as a baseline for future work. The Uruguayan
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experience with CSCs is a special case due to the regulated context and, as a result, the description we present can help the academic community and policy makers in Uruguay
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and elsewhere to evaluate the CSC phenomenon in regimes where cannabis is highly
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regulated.
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Regulation of Cannabis Clubs
To form a legal Cannabis Club in Uruguay, members have to fulfill three
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bureaucratic requirements. First, they need to get approval to run a non-profit organization (making it explicit that its sole purpose is to cultivate and distribute cannabis among its members). Secondly, they must register with the Ministry of Education and Culture. Thirdly, once the members get approval, their newly-formed organization must register with the IRCCA (IRCCA, 2014). In order to complete the first step, approval to run non-profit organization, they
need to comply with a number of legal requirements: they must show evidence of a foundational board of at least 15 original members and obtain the seal of a certified 2
Buying at pharmacies is not available as of January 2016. The government has carried out a public bid and decided which companies will produce cannabis, but it will take several months to have the marihuana at the pharmacies. 3 This preference distribution comes from a Respondent Driven Sample (RDS) study of frequent marijuana consumers (consume at least one a week) of age 18 or more, who live in the Montevideo metropolitan area. The study surveyed 294 individuals. Data collection took place during November and December 2014.
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public notary. Officers of the organization must be appointed from these 15 members and include a board with a President, Secretary and Treasurer plus three alternates as well as an Auditing Committee which includes all the above.
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After registering as a non-profit with the Ministry, the club needs to register with the IRCCA. This procedure requires the club founder to set an appointment with the
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Support Office of the Uruguayan Postal Service to begin the registration process.4 The authorized representatives for the registration process are the regular board members
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who must identify themselves at the time of registration. The Uruguayan Postal Service
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official will digitalize the club’s information as well as the founders’ personal data according to the requirements set down by the IRCCA. The information collected in the
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IRCCA form includes address and contact details, basic crop information, Technical Manager’s personal data, and opening hours. Club authorities must present the articles
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of incorporation and the founding charter of the club, along with the founding members’
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personal data. This information is considered sensitive, and once entered, will only be accessible to IRCCA staff.
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At the time of registration, the club must submit a list of documents, including
notarized and duly approved bylaws that are also authorized by the Ministry of Education and Culture; notarized copy of the minutes listing all personal data of the founding members of the club; date of birth and proof of address of each founding member; and proof of address or utility bill on behalf of the non-profit organization; documents certifying ownership, lease, possession or any other title by which the nonprofit organization is authorized to be headquartered at the property where the crop is to be grown. Additionally, the government requires a Crop Plan describing technical and
4
The Postal Service has been chosen by the Uruguayan authorities as the institution to register all cannabis users because of its presence throughout the country. Individual growers register there, as do members of UCCs, through the club authorities. It is expected that once the sales through pharmacies mechanisms is in place, consumers will also have to register at the Post offices
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security protocols of the plantation development and a plan for the distribution of cannabis to club members. These are reviewed by the IRCCA who then conduct an on-site inspection to
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determine: Club operations: 1) days and times of activity; 2) adjacent areas (occupation or
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use of adjacent areas with chairs, tables or canopies is forbidden, and hygiene must be maintained in these areas); 3) any club activity out of the designated time reserved for
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such activities is prohibited, except for maintenance and cleaning; 4) advertising,
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promotion and sponsorship on facades is prohibited; 5) crop plan and delivery system reports; and 6) the club must respect a minimum distance of 150 meters from any
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educational facility for students under 18 and/or addiction treatment centers. Regarding infrastructure, the club is required to have a space exclusively
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devoted to cultivation, and signs identifying the club as such a facility are prohibited.
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Security is another important issue: Cultivation space should be secured. Plants cannot be taller than the height of the walls bordering the club’s grounds, and access to outside
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plants is forbidden. In addition, clubs need to have a security system covering points of entry, exits and perimeter openings. Club monitoring equipment must be in operational order at all times and access to club premises by minors is forbidden. If one or several of these requirements are not met, the inspection shall point out the corrections to be made. The whole process can take more than a year. Up to August 2015, around 20 UCCs had started this process; seven have
registered with the Ministry of Education and Culture, but only two have been inspected and authorized by the IRCCA. In spite of this detailed regulation, several questions remain open. One frequent concern of clubs is what should be done with the excess marijuana. It is not clear whether it should be disposed of or stored or whether it could
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be used in the manufacture of lotions and/or oils. Moreover, the process is quite complex and many UCCs have found it difficult to submit their documents and set up their cultivation sites. Most experienced clubs, which are the offspring of the activist
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movement, have offered to guide new clubs through the lengthy and sometimes confusing registration process.
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.
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Methods
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Data presented here come from two main sources: documentary research and interviews with club officials and members. Through documentary research, our team
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collected official documents (laws and regulations, as well as guidelines provided by the IRCCA) and information published on diverse national media outlets on marijuana
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regulation in general and cannabis clubs in particular. Data collection activities started
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in March 2015 and were completed in August 2015. The three PIs of the project were
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directly involved in fieldwork activities with three well-trained Research Assistants. Due to the classification of their registry as sensitive information, there is no
publicly available record of cannabis clubs. From information available in the media and directly from the clubs themselves, we estimate that about 20 organizations have started the process to become fully-fledged cannabis clubs. Of these 20, only two have completed stages one and two and have been granted authorization to proceed further. This has been confirmed by the club themselves and by the IRCCA. All the others are at different stages of the registration process and moving at different speeds. For this stage of our project, we targeted as many clubs as possible, establishing relationships with them through a variety of mechanisms. For example, we used existing bonds within the pro-marijuana regulation activist coalition; we relied on 10 Page 10 of 29
references from other clubs; and finally, we used our existing connections from a previous study of frequent marijuana consumers (Boidi, Queirolo & Cruz, 2015). Unlike Belgian clubs (Decorte, 2014), UCCs do not have a large Internet presence,
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which makes them difficult to find and contact. For example, only two have a Facebook account. Most do not have an official email address. In total, we were able to reach and
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collect extensive information about eight of the 20 organizations through interviews with their officials and members.
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In all cases, we interviewed authoritative voices for the clubs: members of the
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board, chief gardeners or highly involved members.5 We interviewed one person per club, all men. Four of the clubs allowed us to visit to conduct face-to-face interviews
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and they showed us their plantations, even allowing us to take pictures. Three other clubs preferred not to disclose the club location, and we met their representatives in
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another venue. One of the clubs granted an interview at the last minute and for practical
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reasons this was done by phone.
We were unable to contact all prospective UCCs, either because they were
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unreachable through our networks, or because they refused to provide information and wished to remain anonymous, even declining a confidential interview. These groups are essentially interested in becoming UCCs as a way to get marijuana. During interviews, UCCs representatives were asked a series of questions from an open-ended questionnaire. These dealt with the history of the club and membership conditions, the organizational structure and finances, their cannabis production system, the way in which they distributed their product, any other activities in addition to producing and 5
For four of the clubs surveyed, we interviewed a member of the Club Board of Directors. In two cases, the interview was granted by the Chief Gardener, which turns to be the person with the most knowledge about the club daily activities (in many cases this individual also functions as the club administrator). One of the clubs with a more activist profile has a speaker to talk to media and researchers, and we interviewed this person. In the remaining club, we interviewed a club member with full knowledge of the club activities; this member was granted permission from the club authorities to speak on their behalf.
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distributing cannabis; their relationships with other UCCs, the IRCCA, the police and neighbors; their future plans and the advantages and challenges of being part of the cannabis club. The questionnaire replicates some questions asked in the study on
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Belgian clubs (Decorte, 2014). For those UCCs whose facilities were open to visits, we also toured their facilities, and assessed infrastructure, security installations and
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indoor/outdoor production systems.
Most of the eight surveyed cannabis clubs were located in Montevideo, the capital
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city. Only two were located outside the capital: one in Florida (near the center of the
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country) and another one in Maldonado (in the Eastern region).
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Results
According to the UCCs representatives, cannabis clubs have two main purposes:
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granting access to marijuana and activism. It is clear that the UCCs have the goal of
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providing legal, affordable, high-quality, and readily available marijuana with co-
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production providing a solution to the underproduction that single growers can face.6 But this is not the only purpose of UCCs. For some activism is crucial. Several clubs want to raise awareness and share knowledge about cannabis among their members and society in general.
These different goals establish an important distinction among cannabis clubs.
On the one hand, there are clubs that are only concerned with getting access to good quality marijuana; these tend to be very private, difficult to access and have a closed membership formed by friends and relatives. We were not unable to interview most of them, but based on our attempts to collect some information, we can assume that they
6
This is the ideal scenario, but it does not always work that way. Interviewees reported the real experiences of the clubs, e.g. in one all the plants were stolen and in another one all plants died.
12 Page 12 of 29
account for half of the groups that started the process of becoming official UCCs. Most were assisted by AECU (Asociación de Estudios Canábicos del Uruguay) in the initial stages but they are organized in different ways. There is a second type of UCC where, in
ip t
addition to providing access to marijuana, activism plays an important role. These clubs are open and easy to reach, and eager to explain the advantages and problems they face.
cr
Some are organized as cooperatives with members who pay with work when they do
not have money, to clubs with paid staff and expensive membership fees. In spite of this
us
variation, most of have ties with the IRCCA, other clubs, and the Federation of
an
Growers.
In light of this, results are presented in six subsections: Origins, Membership,
M
Clubs Facilities and Organization, Cannabis cultivation, Cannabis Distribution, and
d
Activities. Detailed information is provided in Table 1.
Ac ce p
Origins
te
[TABLE 1 AROUND HERE]
The organizations that became the current cannabis clubs followed different
paths to becoming fully established. The first clubs, and most of those that show greater institutional strength, stemmed from parent organizations linked to some form to cannabis-related activism. Club A stemmed from Movida Cannábica Florida (Florida Cannabis Movement), the first pro-cannabis movement located outside Montevideo. Club B was formed by members of the pro-regulation organization Pro-Derechos, and Club C was formed by members of the Asociación de Estudios Canábicos de Uruguay (AECU, Uruguayan Cannabis Studies Association). Finally, Club E was formed by members of the Red de Usuarios de Drogas (Network of Drug Users). Not surprisingly,
13 Page 13 of 29
these clubs are also the ones engaged in additional activities, from activism to cannabis cultivation and distribution. Another type of club according to origin is that formed by groups of friends
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whose aim is to secure access to safe and affordable marijuana: Club F, Club G, and Club H fall into this category. Though similar, Club D is not entirely of this kind, as it
cr
was formed by the initiative of a single individual.
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Membership
an
The law cites that a cannabis club should have between 15 and 45 members. All the clubs that we surveyed complied with the regulation. However, not all had reached
M
their maximum membership. Some had 17-18 members, such as Club A and Club G, and still had room for new members. The rest has reached their maximum membership
d
and operated a waiting list for new members. Most members were young people,
te
between 18 and 40 years of age and male. Only Club B and Club G had an evenly split membership between males and females. There are clubs mainly formed by lower- and
Ac ce p
middle-class people, such as Club A and Club E, while in others the membership is from upper-middle class (Club B and Club C). This distinction is relevant because most of the upscale clubs are ones in which activism is less relevant and the main goal is access to marijuana. In other words, the access-activism distinction seems to be related to socioeconomic level.
Members are recruited following two main criteria: personal acquaintance and
recommendation. In order to be admitted to a club, new members must be introduced by an existing member. As a result, clubs membership is cultivated principally by friends and relatives. In addition, commitment to collective work (Club E) or activism (Club B) is essential for some clubs. For others, like Club D, there are no such requirements. In
14 Page 14 of 29
most clubs, members use marijuana for recreational purposes and on a daily basis. There are some clubs where a few members use marijuana for medical reasons.7
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Club Facilities and Organization In half of the surveyed clubs, the location was rented, and in the other half the
cr
property (either the house or the land itself) was owned by a member. Clubs that rented
their location are those with middle- and high-income members, while those that own
us
the site were clubs with lower- and middle- class members. Following the same
an
distinction, more up-scale clubs had paid personnel: in most cases a Gardener and one Administrator. In clubs with less affluent members, there were no employees and
M
membership fees could be paid with work.8 Also in Club C, if a member worked for the club, that person received a discount on their monthly membership fee.
d
Fees varied considerably. The total amount of marijuana that a member is legally
te
allowed to obtain is up to 40 grams per month. The fees for that quantity varied from 26 to 92 dollars per month.9 In most cases, the payment is fixed but there are exceptions.
Ac ce p
Club E has a voluntary contribution, but the ideal fee is fixed at 40 dollars per month. Some clubs like Club D have a differential fee depending on the amount of marijuana used: 64 dollars per 40 grams, 40 dollars per 25 grams, and 16 dollars per 10 grams. In some clubs, membership fees are mandatory, but in others, members pay for the amount they consume.
Cannabis Cultivation
Cannabis clubs in Uruguay combine indoor and outdoor cultivation. There are exceptions where only indoor (Club C) or outdoor (Club D) cultivation is performed. 7
The regulation for medical marijuana production was passed after the recreational marijuana regulation. As a result, even less is known about it. 8 For example, members can work in harvesting, drying and curing. 9 Fees are charged in Uruguayan pesos. For comparative reasons, we converted Uruguayan pesos to the value of the dollar in August 2015.
15 Page 15 of 29
Outdoor production is used during the warm season and indoor production is employed during winter. Alternating cultivation systems is a technique growers use to avoid a drought period. The Uruguayan regulation allows the UCCs to have up to 99 flowering
ip t
plants at any one time. Clubs declared that they had from 20 to 99 plants at time of our interviews. The declared productivity of the plants also varies depending on the club:
cr
from 50 to 200 grams per plant in indoors facilities, and from 350 grams to 3 kilograms for outdoor cultivation. This variance in productivity seems to be an indicator of
an
productivity in other more experienced farm activities.
us
inexperience in marijuana cultivation. It is difficult to find such differences in per plant
There was also little knowledge about levels of cannabinoids THC and CBD in
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the marijuana. Most of the clubs reported a THC level of around 15% or higher, but say this is just an estimate. Few UCCs have gone through the process of testing the flowers
d
and the only information they have is that provided by the seed producer. Only one club
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declared that they had knowledge of CBD levels. The clubs with members who consume for medical purposes did not have information regarding CBD despite that
Ac ce p
chemical being the most useful component for medicinal users.
Cannabis Distribution
The ways in which clubs distribute marijuana to members also differed
significantly. Most of the clubs dispensed only at harvest time; others do it monthly; and a third group did it upon request or at any time they could. This complicates matters for inspection because the regulation states that each member may only get access to a maximum of 40 grams per month. In the clubs where distribution is on request, quite often members stopped by several times per month, and in order to comply with the law, the UCC should register amount taken by the member until 40 grams is reached.
16 Page 16 of 29
Currently, only two clubs were producing enough to provide each member with 40 grams.
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Activities
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As noted, there is an important distinction between cannabis clubs whose sole purpose is to provide marijuana to members, and those where activism is crucial. In this
us
second group, in addition to social meetings, UCCs organized activities related to risk reduction, prevention, and education. Club B, for example, required members to
an
participate in educational and promotional activities. Club E is defined, more than just as a club, but rather as a cooperative of producers in which each one brings what he or
M
she has: expertise, manpower, money, etc. Resources are then used to carry out music workshops, courses on cannabis home cultivation, or risk reduction events.
d
CSCs are promoted as a harm-reduction policy in countries where marijuana has
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not been fully regulated because they produce a less dangerous substance than that
Ac ce p
available on the black market. Cannabis clubs provide information on the potency and effects of their varieties as well, thereby allowing users to have more control over their levels of consumption (Belackova, Tomkova & Zabransky, 2015). In Uruguay, where the marijuana market is regulated, several UCCs also play that role.
Challenges and Problems faced by UCCs There were several challenges mentioned by the UCCs representatives in interviews. We group those into four categories: compliance with the regulation, financial sustainability, tolerance from the society, and collective action dilemmas. It is easy to see from the long description in the Background section that complying with the
17 Page 17 of 29
procedures to become a full-fledged UCC is a difficult task, or at least an endeavor that needs patience and some proficiency. In addition, several club representatives complained about the lack of guidance from government authorities. Part of this may be
ip t
explained by the scarcity of a Human Resources department at the IRCCA, which leads to long delays in answering requests and questions. Apart from demanding more and
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faster responses from officials in charge of controlling the regulation, interviewees were uncertain about what was to come, and expressed concern about the enforcement of the
us
regulations.
an
Financial sustainability was another concern. There were several cannabis clubs underestimated their operation costs and have since found themselves in dire financial
M
straits. Moreover, the UCC representatives questioned the limit of 45 members per club and argued that it is very difficult to cover fixed costs while keeping a reasonable
d
membership fee. Among these fixed costs, interviewees mentioned rent, gardening and
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administrative staff salaries. They also highlighted the burden of security systems (alarms, video cameras, electric and regular fences). Some of these problems could be
Ac ce p
solved by increasing club membership, as is done in Spain, where CSCs have hundreds, even thousands of members who share the collective cost burden. An alternative solution presented by a number of UCCs was to share the land for cultivation among three UCCs and thereby lighten the high costs of renting and security. However, the IRCCA denied their request and ruled that UCCs needed to be separated by a distance of 1000 meters. Thirdly, there were concerns related to the misunderstanding in society about UCCs which has led, in some cases, to neighbors filing police reports. Police responses to a neighbor’s claim were also full of ambiguities and lacked any standard procedure. However, in August 2015, a police protocol was finally approved. It states
18 Page 18 of 29
that no police action can take place without a judicial order. Activists played a crucial role in this measure.10 Finally, UCCs have faced certain “collective action dilemmas”.
Those
ip t
dilemmas were more important for organizations in which activism was a goal. Several of the UCCs thought that members should contribute not only with fees but also with
cr
voluntary work. However while participation in activism and volunteering for work in cultivation and care was easy to obtain in the beginning, later people started to make
us
excuses. In order to avoid the free-rider problem, some UCCs started to charge a lower
an
fee to those who contributed manpower, generating a positive incentive to participate. One of the interviewees summarized this in a very clear way saying that “Reality tops
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fiction… and ideology as well”. .
d
Conclusions
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In Uruguay, cannabis clubs are one of the three legal ways in which users can
Ac ce p
obtain marijuana. They enjoy a supportive legal framework in which to operate that makes them less vulnerable than in others countries where they have become a popular alternative source. Despite different legal framework for CSCs in Spain, Belgium, and Uruguay; these organizations share some problems, although certain challenges are exclusive to the Uruguayan experience. The following contains a preliminary SWOT analysis of UCCs. 11
Starting with the strengths: the most important strong point is the CSCs’ legal status in Uruguay. Contrary to the grey legal realm occupied by associations in countries where marijuana has not been fully regulated, the UCCs and their members 10
“Protocolo de Actuación Policial sobre Ley de Marihuana y sus Derivados”. Retrieved 10 September 2015 from http://www.infodrogas.gub.uy/images/stories/pdf/Protocolo_policial_cannabis.pdf. 11
Following an appropriate comment made by one of the reviewers, we focused the analysis on strengths, weaknesses, opportunities and threats.
19 Page 19 of 29
are protected by comprehensive regulation, and until now, no significant problems with police or the judicial system have been reported. One of the main arguments for becoming a UCC member is the possibility of
ip t
access to a high-quality product. No doubt this is one of the main opportunities that CSCs have in Uruguay and elsewhere – namely that they can keep strict control of the
cr
substance they are producing and control distribution among members. In Uruguay, we consider this dynamic as an opportunity rather than strength because most of the
us
interviewed members still did not have enough information about the varieties and
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quality of the marijuana they were consuming. Employment and taxes are also opportunities, but currently UCCs have more financial problems than economic
M
advantages.
They also share the threat of becoming a for-profit enterprise- something that is
d
explicitly prohibited in Uruguay as well as in other countries where CSCs first emerged.
te
The suspicion that CSCs can hide a profitable marijuana business is always present. This partly explains the Uruguayan limitation on club membership (up to 45) and the
Ac ce p
amount of marijuana that each member can receive (40 grams a month). Organizational aspects are highlighted as weaknesses in Uruguay as well as in
Belgium and Spain (Arana &Sanchez 2011, Decorte 2014). Challenges range from defining an appropriate delivery system to providing a high-quality product. Moreover, as a result of the dual purpose of some clubs (access to marijuana and activism), CSCs have to establish appropriate membership duties. It is not uncommon to find problems concerning collective action in social organizations, and CSCs are no exception. Other weaknesses faced by clubs in Uruguay are specifically related to country regulations, context and institutions. The creation of a UCC is complicated, the founding members need to constitute an assembly of 15 people and start collecting all
20 Page 20 of 29
the paperwork needed to become an official cannabis club. Until now, delays from one step to the next have been significant. For example, representatives declared that after being registered with the Ministry of Education, it can take months to be registered with
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the IRCCA. This is a design flaw of the regulations and a bureaucratic nightmare. Interviewees also mentioned that regulations have considerable gaps and can require
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further guidance from the IRCCA in order to continue with the registration process. To add insult to injury, those answers can take considerable time to arrive. This is also a
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problem of institutional design, because the IRCCA does not have the resources to
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prevent delays and provide guidance in a timely manner. At time of writing, the registry had been opened for 10 months but only two of 20 UCCs that started the process had
M
obtained official authorization12.
These two sets of problems - difficulties with regulation and challenges related
d
to the institutional design - can be easily tackled. Regulations can be modified in order
te
to make the paperwork process more efficient, and an adequate budget can be provided to the agency in charge of the regulation. With regard to the institutional design
Ac ce p
challenges, it is important to remember that the marijuana regulation law made its first steps in a changing political context. It was passed at the beginning of a presidential campaign and its implementation began almost at the same time as changing of the guard from one administration to the next13, which surely had an impact on the speed of implementation of the new laws. The problems mentioned are easy to solve. But our survey of UCCs, highlights
two weaknesses and a risk that calls into question whether UCCs could become a popular and sustainable model, as is the case in other parts of the world. Starting with the weaknesses, we note that in order to accomplish their goal of providing marijuana to 12
Cannabis clubs registry was opened on the 30th of October, 2014. Though government remained in the same political party, the left of center Frente Amplio, a new President with a different agenda was elected and a new Secretary of the National Bureau of Drugs has been appointed.
13
21 Page 21 of 29
members, clubs in Uruguay need to adjust their views of collective action, which stand in harsh contrast to reality. Some of the UCCs were created with the idea that every member would take an active role in club activities, but the experience reported by the
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interviewees is very different. If they fail to live up to expectations, it is highly probable that some UCCs will disappear. Second, certain restrictions in the current regulations
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make it even more difficult to survive, particularly that which limits membership to 45.
Fixed costs are quite high for some UCCs that cannot charge expensive membership
us
fees. An alternative proposal to share fixed costs among a small group of UCCs was
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overturned by the IRCCA.
Additionally, we uncovered an important risk to the expansion of CSCs in
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Uruguay. Due to the fact that UCCs are just one of the legal options available to acquire marijuana in Uruguay, they have to “compete” with home cultivation and sale
d
of the product at pharmacies. Home growing is not a simple process, so it is not
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necessarily an option for everyone. It takes time, dedication, and lots and lots of physical space that the average person does not have in their apartment or home.
Ac ce p
Purchasing at a pharmacy is the opposite: it is the easiest way to access marijuana and the impact that pharmacies could have on UCC membership is uncertain. Once marijuana becomes available at pharmacies, and if the product offered is of high quality, many UCC members may move to that method of procuring marijuana, thereby undermining the clubs’ sustainability.
[TABLE 2 AROUND HERE]
The future of CSCs is different in contexts where cannabis regulation does not exist than in countries where regulation is already in place. While in the first scenario
22 Page 22 of 29
we have prolific collective organizations with extensive memberships, in post-regulated regimes such as Uruguay, the whole enterprise may turn into nothing more than a secondary way to acquire marijuana, only used by a handful of activists. By describing
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the current situation of UCCs, this article should serve as a baseline study against which to monitor the evolution of CSCs and understand their role in cannabis use in different
Ac ce p
te
d
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an
us
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regulatory contexts.
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References
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Arana, X., & Sanchez, V. M. (2011). Cannabis cultivation in Spain – The case ofcannabis social clubs. In T. Decorte, G. Potter, & M. Bouchard (Eds.), World wideweed: Global trends in cannabis cultivation and its control (pp. 163–177). London:Ashgate.
us
Barriuso, M. (2011). Cannabis social clubs in Spain: A normalizing alternative underway.Series on legislative reform of drug policies, nr. 9.
M
an
Belackova, V., Tomkova,A., &Zabransky T. (2015) “Qualitative Research in Spanish Cannabis Social Clubs: The Moment You Enter the Door, You Are Reducing Harms” Paper presented at the 9th Conference of the International Society for the Study of Drug Policy (ISSDP). Ghent, Belgium. May 19-22, 2015
te
d
Bewley-Taylor, D., Blickman, T. &Jelsma, M. (2014).The rise and decline of cannabis prohibition. The history of cannabis in the UN drug control system and optionsfor reform. Amsterdam/Swansea: Global Drug Policy Observatory/TransnationalInstitute.
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Boidi, M.F, Queirolo. R.& Cruz, M. (2015) “Marijuana Consumption Patterns among Frequent Consumers in Montevideo.” Paper presented at the 9th Conference of the International Society for the Study of Drug Policy (ISSDP). Ghent, Belgium. May 1922, 2015 Capler, N.R. (2010) “Canada Compassion Clubs.” In Holland, J. (Ed.). The pot book: A complete guide to cannabis. Inner Traditions/Bear & Co. Caulkins, J. P., Hawken, A., Kilmer, B., &Kleiman, M. (forthcoming). Marijuana Legalization: What Everyone Needs to KnowRG. 2nd Edition.Oxford University Press.
Decorte, T. (2010). Small scale domestic cannabis cultivation: An anonymous websurvey among 659 cultivators in Belgium. Contemporary Drug Problems, 37(2),341–370. Decorte, T., Potter, G., & Bouchard, M. (2011). World wide weed: Global trends incannabis cultivation and its control. London: Ashgate.
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Decorte, T. (2014). Cannabis social clubs in Belgium: Organizational strengths and weaknesses, and threats to the model. International Journal of Drug Policy, http://dx.doi.org/10.1016/j.drugpo.2014.07.016 Feldman, H. W. & Mandel J. (1998) Providing Medical Marijuana: The Importance of Cannabis Clubs, Journal of Psychoactive Drugs, 30:2, 179-186
cr
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Hathaway, A. D. & Rossiter, K. (2007) Medical Marijuana, Community Building, and Canada’s Compassionate Societies , Contemporary Justice Review, 10 (3), 283-296,
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IRCCA (2014). “Condiciones para la habilitación de los clubes de membresia. Funcionamiento, infraestructura y seguridad”. IRCCA: Montevideo.
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Kilmer, B., Kruithof, K., Pardal, M., Caulkins, J. P., & Rubin, J. (2013). Multinationaloverview of cannabis production regimes.Rand Europe – WODC – Dutch Ministryof Security and Justice. La diaria (2012, September 19). “En los papeles”. La diaria.
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Parés Franquero, O. & Bouso Saiz, J.C. (2015). Innovation Born of Necessity: Pioneering Drug Policy in Catalonia. New York: Global Drug Policy Program, Open Society Foundations.
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Potter, G. (2010). Weed, need and greed: A study of domestic cannabis production.London: Free Association Books.
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Room, R., Fischer, B., Hall, W., Lenton, S., &Reuter, P. (2010). Cannabis policy: Movingbeyond stalemate. Oxford: Oxford University Press.
25 Page 25 of 29
ip t Luz Verde
Location
Florida
Montevideo
Montevideo
Parent organization
Movida Cannabica Florida
PRODerechos
AECU
Current members
17
45
45
Recruitment
Trust/recom mendation
Trust/recom mendation
Waiting list?
No
Age
20-30
Gender
70% male
cr
El Piso
Manga Rosa
Pájaros Pintados
Gogollo Alegre UruRoots
Montevideo
Montevideo
Montevideo
Montevideo
Maldonado
NONE
Red de Usuarios de Drogas
NONE
NONE
NONE
45
15
45
18
35
Trust/recom mendation
No requirement
Trust/ Trust/recomme Trust/recomme Trust/recomme Commitment ndation ndation ndation to collective work
Yes
Yes
No
Yes
No
NO
18-38
20-30/40-60
20-30
19-44
25-35
30-40
Less than 35
40% male
80% male
70% male
87% male
89% male
60% male
86% male
ed
ce pt
Ac
Yes
us
CLUC
M an
Cofradia Hoja Roja
Page 26 of 29
ip t Marijuana consumption
Daily, recreational
Daily, recreational
Daily, recreational + 1 medical
No data
Paid personnel
No
1 Gardener
1 Gardener
1 Gardener/
Member monthly fee
UDS 40
yes
no
Middle class
Middle class
Middle and upper class
Daily, recreational and medical
No data
Varied
Varied
No
No
No
No
Low
Middle class
Middle class
M an
ed USD 92
ce pt
UDS 26
Ac
Can fee be reduced with
1 Administrato r
Low and
cr
Middle and upper middle class
Low and
us
Middle class
Middle and upper middle class
SES
Administrato r
USD 64 (40grs) USD 40 (25 grs)
Voluntary USD 2 per gram, USD 50 contribution. up to 40 grams per month Ideal would be USD 40
USD 80
yes
no
USD 16 (10grs)
yes
no
no
yes
Page 27 of 29
ip t cr At harvest
Monthly
Quantity
Equally distributed among members
Equally distributed among members
Equally distributed among members
Anytime
On demand
M an
At harvest
Per request (members pay per what they get)
Per request
Monthly
When available Monthly
Per request
40 grams
40 grams
Ac
ce pt
ed
Frequency
us
manpower?
Page 28 of 29
ip t cr us M an
Table 2.Preliminary SWOT Analysis for UCCs
Strengths
Legal framework
Organization Regulations and Institutional design Collective action problems High fixed costs
Opportunities
High quality product Control the product Revenues Taxes
ce pt
Become a for-profit enterprise Selling in pharmacies
Ac
Threats
ed
Weaknesses
Page 29 of 29