Greek hemp shops built entire business models around one number: 0.3% THC. Stay under that threshold, the thinking went, and your product is legal. Circular AP oik.4941, signed by Health Minister Adonis Georgiadis on September 15th, just told the entire industry that this assumption was wrong all along.

The circular doesn’t create a new ban. It interprets laws already on the books, namely Law 5302/2026 and Law 5322/2026, and tells the National Organization for Medicines (EOF), the food safety authority (EFET), and Greek police exactly how to enforce them. The result is a sweeping, closed-list approach where anything not explicitly permitted is treated as a narcotic, regardless of THC percentage.

For an industry that spent years pointing to lab certificates showing “compliant” THC levels, this is a significant shift. It also raises a bigger question worth asking out loud: does banning naturally low-THC hemp products actually protect public health, or does it just punish legitimate retailers while pushing consumers toward the unregulated products the circular claims to be fighting?

What Does Circular AP oik.4941 Actually Say?

The circular, reported by HealthStat, tells regulators and businesses that Greece follows a restrictive, closed-list legal principle for cannabis products. Under Article 1 of Law 4139/2013, THC itself is classified as a narcotic. Under Article 3B of the same law, any product meant for vaping, smoking, or inhalation that contains cannabinoids, natural or synthetic, counts as a narcotic too, no matter how small the concentration.

That means the law doesn’t ask “how much THC is in this product?” It asks “does a specific ministerial decision permit this exact product category?” If the answer is no, the product is illegal. Full stop.

This is the legal mechanism the circular activates. It doesn’t introduce new prohibitions so much as it removes the wiggle room that let retailers argue their low-THC products fell into a gray area. According to the circular, that gray area was never real. It was a misreading of how narrow the legal exceptions actually are.

The ministry frames this as a public health response to products marketed with labels like “legal,” “THC-free,” or “under 0.3%” that may still test positive for psychoactive delta-9-THC or banned analogs like HHC. Whether or not you agree with the framing, the enforcement instructions are concrete and immediate.

Which Cannabis Products Must Come Off Greek Shelves Now?

The circular lists six categories that businesses must withdraw from sale immediately, regardless of THC content:

• Vapes, smoking products, and inhalables containing any cannabinoids, natural or synthetic
• Raw cannabis flower and dried bud, including any product containing plant material with flower
• Foods containing any detectable THC, plus CBD foods lacking proper novel food authorization
• Dietary supplements with any THC, unless they carry an EOF notification number and lab-verified THC-free status
• Cosmetics containing THC, unless authorized under a specific ministerial decision
• Children’s food products containing any THC

Notice what’s missing from any exemption: a THC percentage. Products at 0.2% and products at 0.29% face identical treatment under this framework. The distinction Greek regulators care about isn’t concentration, it’s whether a specific legal provision authorizes that exact product type.

Pharmaceutical cannabis products approved through EOF’s official marketing authorization process are explicitly exempt. So are conventional hemp seeds, seed oils, and seed flour, which fall under existing food safety frameworks rather than narcotics law.

Why Doesn’t the 0.3% THC Threshold Protect Sellers Anymore?

Here’s where the circular reshapes the conversation. Greece’s 0.3% THC threshold has always governed agricultural cultivation, meaning it determines whether a hemp crop is legal to grow. It was never designed to determine whether a finished retail product is legal to sell.

Retailers and manufacturers, understandably, treated the cultivation threshold as a retail green light. If the raw material was legal to grow, the logic went, products made from it should be legal to sell. Circular AP oik.4941 draws a hard line between those two things.

Dried cannabis flower under 0.3% THC is explicitly named as prohibited for retail sale under Article 1, paragraph 3A of Law 4139/2013. This applies to the flower itself and to any product containing flower material, even mixed with other plant parts. Georgiadis’ ministry is saying, in effect, that agricultural compliance and consumer product legality are two entirely separate tests, and passing one doesn’t mean you’ve passed the other.

This is a tough pill for an industry that invested heavily in lab testing and compliant sourcing based on the 0.3% number. Businesses that built their entire compliance strategy around THC percentage now find that percentage largely irrelevant to their legal standing.

How Are EOF and EFET Going to Enforce This?

The circular gives Greece’s medicine regulator and food safety authority a specific playbook. EOF and EFET are instructed to inspect both physical stores and online sellers, collect product samples, and send them for laboratory analysis targeting delta-9-THC, HHC, and related cannabinoid compounds.

Where testing confirms a violation, authorities are directed to order withdrawal or recall of the product and refer the matter to the appropriate agency. Food-related violations go to EFET. Cases involving prohibited cannabinoids go to the Hellenic Police narcotics division.

Two testing methods get named specifically for supplement verification: HPLC, with a quantification limit around 0.1 mg/l, and LC/MS-MS, which is far more sensitive at roughly 0.001 mg/l. Manufacturers seeking to keep supplements on shelves need certificates of analysis showing THC below these detection thresholds, not just below 0.3%.

This is a meaningfully higher bar than what many suppliers have been working with. A product that comfortably cleared the old 0.3% cultivation standard could still fail this new trace-detection requirement, since the goal here is proving THC is essentially undetectable, not just under a percentage cap.

What Still Legally Qualifies as a Cannabis Product in Greece?

The list of what remains legal is short. Conventional hemp seeds, seed oils, and seed flour that meet existing food standards are recognized without additional hurdles. Dietary supplements can stay on shelves only if they’re entirely THC-free, carry a valid EOF notification number, and come with lab documentation proving THC falls below the quantification limit of a highly sensitive testing method.

Approved pharmaceutical cannabis products with a special EOF marketing authorization are exempt from all of the above restrictions, since they operate under a completely separate regulatory track built for medicinal use.

Everything else, including flower, vapes, THC-containing foods and cosmetics, and supplements that haven’t cleared the EOF notification process, falls outside the permitted list and is therefore treated as illegal.

Is This a New Cannabis Law or Just an Interpretation?

This question matters, and it’s one the ministry is careful to make. Circular AP oik.4941 is an interpretive circular, not new legislation passed by Parliament. It draws its authority from Law 5302/2026, published in May 2026, and Law 5322/2026, published in July 2026, both of which already contained the restrictive provisions the circular now operationalizes.

According to regulatory analysis from Zepos & Yannopoulos, Law 5302/2026’s Article 43 already imposed a complete ban on dry cannabis flower retail sale, distribution, and consumer use months before this circular arrived. Law 5322/2026 added further restrictions on vaping and inhalable products through Article 84.

What changed on September 15 wasn’t the underlying law. What changed was the instruction to EOF, EFET, and police to actively enforce it, with specific testing protocols and a clear statement that marketing claims like “THC-free” carry no legal weight on their own.

That’s a meaningful distinction for businesses assessing their exposure. Greek authorities aren’t issuing a temporary emergency order that they might later walk back. They’ve built this enforcement directive on legislation that has been in force for months, signaling that they intend this crackdown to stick.

The Bigger Problem With Banning Low-THC Hemp

Here’s the tension this circular doesn’t resolve. Low-THC hemp products, the kind that fall well under the 0.3% cultivation threshold, aren’t psychoactive in any meaningful sense. Treating them identically to high-THC narcotics under enforcement policy conflates two very different substances under one legal umbrella.

The public health argument behind the circular focuses on mislabeled products with hidden psychoactive concentrations, and that’s a legitimate concern worth addressing. But a blanket ban on legitimately low-THC flower and CBD products doesn’t just catch bad actors. It also removes compliant, lab-tested products from licensed retailers, the exact businesses that were doing the testing and transparency that regulators claim to want.

When legal, tested products disappear from shelves, demand doesn’t disappear with them. It shifts toward the unregulated market the circular is ostensibly trying to shrink, the same market that has no testing standards, no age verification, and no accountability at all. A regulatory framework built around a rigid closed list, rather than genuine science-based risk assessment, risks solving the wrong problem while creating a bigger one.

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