By Luis David Suarez Rodriguez
UNAM graduate physician with clinical Specialization in Acupuncture and
Phytotherapy and Medicine of Physiological Regulation.
He is a member of several national and international scientific associations for functional medicine and ozone therapy. He has been practicing functional medicine for more than 12 years and has been working with medical cannabis in his private practice for 8 years. He has been a member of the International Association of Cannabinoid Medicines (IACM) since 2015. In 2018, together with other health professionals, he founded the Mexican Association of Cannabinoid Medicine (AMMCann AC), a non-profit institution whose objectives are the education of doctors and other health professionals on the correct use of cannabinoid medicine in Mexico. He is currently its President.
Specialist in Endocannabinology who graduated from the DIECC of the National University of Rosario, Argentina. He is the academic coordinator of the first International Diploma in Endocannabinology at PUIS-UNAM.
He is the author of several scientific articles on functional medicine and cannabinoid-based medicine and gives courses and lectures on these topics in national and international forums.
Experience of Medical Cannabis in Mexico.
"Don't try to understand Mexico using reason,
you'll have better luck with the absurd,
Mexico is the most surrealist country in the world"
- André Bretón, 1938
So, it has been surreal to try to have a Medical Cannabis practice in Mexico. Here is a bit of context to explain it:
The Regulation on the Medical Use of Cannabis in Mexico was approved on 12 January 2021; this regulates all activities related to the use of this plant in a therapeutic context. In theory, cannabinoids are regulated from the seed to the pharmacy shelf, including the extraction and production of herbal medicines (in our regulation, dietary supplements with cannabinoids are supposedly not allowed). The distribution, storage, marketing and even the destruction of stocks are included. Our regulation also allows the importation of registered products from other countries... on paper it is an advanced and novel regulation, but the truth is that its effective application is still far from being a reality. It is, so far, basically dead in the water.
Firstly, the published regulation is not fully implemented: although some licenses have been granted for the production of master formulae, and the regulation provides for the possibility of using THC (tetrahydrocannabinol) in them, none of the licensees have managed to legally import THC and market it. There are also no registered products containing THC, and more than two years after the regulation was issued, only two brands of isolated CBD have been registered.
As a statistical example, during the year 2022 I prescribed cannabinoids to more than 400 patients. Sixty percent of these prescriptions cannot be legally filled in Mexico as they contain THC. The patient then has to resort to the illicit market, where products registered as "food supplements" abound thanks to a legal loophole in the regulation (adding to the surrealism, they are legal products but do not comply with the regulation of cannabis for medical use), and as is common in places where medical use has not been regulated, many of these products do not contain the concentration or type of cannabinoids mentioned on the label, nor do they have guarantees regarding safety or freedom from pesticides and heavy metals, etc. Many of these products come from the North American market, with a surreal reversal of the flow: before, illegal Mexican marijuana found ways to reach American consumers; today, medical cannabis products and those destined for the adult-use market in the USA find their way to Mexican consumers.
It is worth mentioning that this delay in registration and marketing is because our government has not managed to harmonize the different regulations needed: there is, for example, no tariff category for importing cannabinoids. So, if one tries to go through the whole process according to the regulations and submits an import application, through a company with a license, everything legal, the import application will end up being declined because the authority does not know what tariff it should levy for this operation. This leaves both patients and doctors in an ambiguous situation that does nothing to reduce the stigma attached to cannabis use in these lands.
Let us remember that Mexico has, sadly, become infamous in the international context as a producer of narcotics and as the birthplace of infamous drug traffickers such as Rafael Caro Quintero and El Chapo Guzmán, which is why, in the national collective imagination, cannabis continues to be seen primarily as a drug of abuse, partly to blame for the violence associated with illicit trafficking, with all the social consequences that we experience: insecurity, corruption, and impunity.
In fact, and in keeping with our surrealism, the regulation of the adult use of cannabis is also ambiguous and this greatly complicates the situation. Although progress has been made in generating jurisprudence that recognizes the right of any person to use cannabis in the context of the "free development of personality" and although in fact permits have been granted for cultivation for personal use, since consensus has not been reached among the different political actors to generate a clear regulatory framework for adult use and industrial production of cannabis, as I mentioned earlier, today our porous northern border allows the passage of cannabinoid products for both adult use and extracts intended for medicinal use in the United States, where the regulation of both uses is shaped by the market.
Consequently, in Mexico, if you know where to look, you can get cartridges of vaporizer oil with more than 90% THC as sold in dispensaries in California and Colorado, while a simple magistral formula with 100 mg THC and 1000 mg CBD cannot be obtained legally. Meanwhile, on the black market you can buy full-spectrum products with up to 1% THC (declared on the label) as sold in the USA or Canada. Confusion on reading this is understandable: this is the situation in Mexico, where doctors, patients, and businesspeople have been seeking for years to have a regulated context for the correct use of this plant.
In my case, I entered the fascinating world of Medical Cannabis thanks to my patients: with a private practice of Functional Medicine in the Riviera Maya, it was not long before foreign patients, usually Canadians or Americans, arrived with a cannabis prescription from their home country. They usually asked if there would be any interactions between the cannabis they were already using and some of the Chinese herbal treatments, supplements, and nutribiotics that we usually prescribe. I remained silent and after a few seconds I answered with the only possible answer: the honesty of ignorance - the truth is that I don't know. Let me investigate. I promise you that I will have the answer on your next visit.-
At the time, I knew cannabis as any student at the Ciudad Universitaria campus of my alma mater, the National Autonomous University of Mexico (UNAM), knew it at the time: in the form of a joint or marijuana cigarette, usually shared in the large gardens and open spaces of this campus, after class and amidst much laughter. In the classes, formally, we only reviewed what we were taught in the toxicology class within the pharmacology course in second year, and some mentions of cannabis-associated disorders when we rotated through psychiatry in the context of the addictions clinic. And nothing more. The endocannabinoid system (ECS) is unfortunately never discussed. Much less so for the use of cannabis in a therapeutic context.
Being able to respond to patients' needs and questions was what led me to study the endocannabinoid system and its therapeutic possibilities. Fortunately for my patients, the community of international Medical Cannabis experts is quite generous with their knowledge and is (or at least was) accessible through the conferences of the IACM (International Association for Cannabinoid Medicines). Linking up with them allowed me to continue learning about this plant. In 2018, together with other scientific professionals, I founded the Asociación Mexicana de Medicina Cannabinoide AC (Mexican Association of Cannabinoid Medicine) and we set ourselves the task of sharing our knowledge about the ECS and cannabis with other Mexican doctors and patients; little by little we have entered many medical associations' forums, where our colleagues are now showing a more open attitude towards the medical use of cannabis.
This has indeed changed, and, at least in Mexico, the perception of the medical use of the plant is now much more favorable than it was two years ago, when the regulation was published. Today, more than 80% of Mexicans agree with the medical use of cannabis, and many of our specialist colleagues (mainly oncologists and neurologists) are already referring patients to us endocannabinology specialists to initiate and carry out the treatment. Today, at the National Autonomous University of Mexico (UNAM), there is an international diploma course with an academically demanding program of more than 220 hours to train scientific professionals. There are several medical and patient associations doing their bit and seeking to broaden the knowledge of this plant and its applications. There is a fully-fledged industry ready to start up. There is a regulatory framework. What we still lack is the political will of our popular representatives and government officials to make progress on this issue. Our idiosyncratic surrealism on the issue of cannabis regulation has the potential to become a perfect storm against public health. And for a change, we are already late, and we owe a debt to patients, doctors, and businesspeople who have opted for legality and good practice. If our government does not get its act together and move to harmonize regulations, and if regulation is not enforced, we will continue to build the strongest illicit market in the world by simple omission.
In conclusion, the regulation of medical and adult use of cannabis in Mexico remains a complex and ambiguous issue. Although progress has been made in regulating medicinal use, there are still many hurdles to overcome to ensure safe and effective medical practice. Regulatory authorities need to work together with medical professionals and the cannabis industry to establish a clear and effective regulatory framework and enable safe and legal access to medical and adult-use cannabis products.