What can Canada learn from U.S., Uruguay about selling marijuana?

As the federal Liberals map out their plan for legalizing marijuana, they can look at how and how successfully a handful of other jurisdictions have overturned the prohibition of pot.

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In 2012, Colorado and Washington became the first U.S. states to legalize marijuana. Within two years, each state set up a framework governing how retailers could start selling.

But although the two states have much in common, they have different takes on key questions that Canada will have to consider, like whether residents will be able to grow their own plantsas they canin Colorado, or whether laws should put limits on non-residents who buy marijuana here, like in Colorado or leave the market open as Washington does.

To get a better idea of Canada's options, here's a look at how legalization has happened elsewhere.

Pot cookies in Colorado

Colorado became the first place in North America to sell legalized marijuana in January 2014. The state already had 493 medical marijuana dispensaries by that point, and it gave them first opportunity to sell to the public.

By the end of the year, the competition increased more than fourfold: 833 commercial sellers had sprouted up and 1,416 medical retailers were in the market, according to the state's 2014 Marijuana Enforcement Division annual report.

Residents could also grow their own marijuana, but no more than five plants at a time. Those crops have to be kept in a locked room, according to Colorado state law.

But that didn't keep the fledgling industry from moving plenty of product with medical firms selling nearly 50,000 kilograms worth of dried flowers in 2014, roughly three times more than recreational sellers, state records show.

Cookies were another story.

Coloradans devoured more than 2.85 million pot cookies, brownies and other edibles in 2014 sold from commercial stores, outpacing medicinal treats by 890,000 sales, the annual report found.

This new hunger soon revealed a problem.

Although regulations set a maximum dose for edible products, they did not take into account how that could be distributed in a serving size, a 2015 report from the Canadian Centre for Substance Abuse says.

"For example, a single brownie could contain up to 10 doses."

After news media reportedseveral overdoses, Colorado amended its regulations so that there could only be one "dose" per serving, the CCSA report says.

Cash only in U.S.

Marijuana cannot, however, be sold everywhere in Colorado; municipalities can prohibit both medical and commercial cannabis licences.

Of the state's 331 jurisdictions, 228 ban both types of marijuana sale, according to Colorado's state Department of Revenue, which oversees enforcement.

Washington also experienced some growing pains when it allowed marijuana into the market in July 2014. Because the state didn't have the same network of medical dispensaries as Colorado, it found itself overwhelmed by demand, the CCSA report found.

The problem may have been compounded by the fact that Washington forbids residents from growing their own plants, products of which CCSA senior policy analyst Rebecca Jesseman said found themselves ending up on the "black or grey markets" in Colorado.

But both states have a lot of policies in common: they only allow adults to buy marijuana, they have restrictions on drugs and driving, and they limit personal possession to 28 grams.

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And both are facing the same obstacle with the federal government.

The U.S. Federal Reserve will not allow banking transactions connected to marijuana production.

"This situation also prevents normal banking operations, resulting in a primarily cash-based industry with corresponding safety and administrative issues," the CCSA February 2015 report says.

Turning a blind eye in the Netherlands

Contrary to the traveller's legend, cannabis is actually illegal in the Netherlands. The country adopted a so-called "toleration policy," which essentially means that prosecutors and police will turn a blind eye to coffee shops that sell small amounts up to five grams to peopleolder than 18.

You cannot grow or sell your own marijuana in the European country. Someone caught growing five or fewer plants would likely just have them seized by police, according to the tolerance rule, but larger crops are still supposed to result in criminal charges.

Coffee shops are also supposed to ask patrons for identification, under stricter rules passed in 2013, according to the Dutch laws. But municipalities are responsible to enforce those,and Jesseman said that they rarely do.

Uruguay legalizes pot, but slowly

In 2013, Uruguay became the first countryto approve the selling of legalized marijuana, with the decision becoming law the next year.

Residents can grow their own plants or join marijuana co-operatives, the Guardian reported. But despite the public interest in the issue, it's taken the country more than two years to set up a regulatory framework to begin selling through storefronts, thenewspaper reported.

Fox News Latino reported this month that the two government-approved producers should harvest their first crop in the spring and have it ready for sale by mid-year.