Introduction

1Over the past decade, medical cannabis reform has gained increasing traction across Latin America. Countries such as Uruguay, Colombia, Argentina, and Mexico have introduced new legal frameworks to regulate therapeutic use, often with the ambition of simultaneously improving patient access, generating economic opportunities, and correcting historically punitive drug policies (Corda et al., 2019). Yet these reforms have produced uneven results. While legal frameworks were adopted and bureaucratic architectures developed, access to medical cannabis remains limited in most jurisdictions, industry performance has often fallen short of expectations, and informal or grey-market practices continue to thrive alongside formal systems (Álvarez et al., 2023; Cruz & Pereira, 2021).

2This article investigates the implementation of Colombia’s medical cannabis policy – a case widely regarded as one of the most advanced regulatory efforts in the region (Martínez Rivera, 2019). Adopted in 2015 through executive decree and later codified by legislation, Colombia’s framework was among the first to establish a licensing system for cultivation, processing, and commercialization, with the explicit aim of building a pharmaceutical-grade cannabis industry for both domestic and export markets (Rivera-Vélez, 2019b). As detailed below, the design of Colombia’s reform reflected an unusual coalition of actors under the Santos administration (2010–2018), bringing together the Ministries of Justice and Health, the national pharmaceutical authority (INVIMA), parent advocacy groups promoting therapeutic access, and domestic and foreign investors seeking new markets. This convergence of moral, bureaucratic, and economic interests gave the reform legitimacy but anchored it in a pharmaceutical paradigm that prioritized regulatory control and international credibility over social inclusion.

3The Colombian case must be understood within a broader landscape of competing policy paradigms that shape the governance of medical cannabis. The prohibitionist paradigm denies the legitimacy of cannabis for any purpose and treats it exclusively as a narcotic substance. Historically, this paradigm has dominated national policies – such as in the United States (Becker, 1973) and Mexico (Campos, 2012) – and international frameworks promoted by the United Nations (Bewley-Taylor et al., 2014). The grassroots or therapeutic paradigm is rooted in community practices and patient associations that highlight the palliative role of cannabis for the sick and dying. Emerging during the AIDS crisis in the United States (Dioun, 2017) and later through the mobilization of mothers of children with epilepsy across Latin America (Labiano, 2018; Rivera-Vélez, 2019a), this paradigm values experiential knowledge and broad accessibility despite limited clinical evidence, and has, for example, been adopted in France, Switwerland and Brazil (Bernard & Jeanroy, 2025; Mavrot, 2023; Pereira, 2025). Positioned between these two, Colombia’s pharmaceutical paradigm recognizes medical use but confines it to standardized, clinically validated, and commercially produced forms. This model has also been implemented in Uruguay (Álvarez et al., 2023). While it provides legal legitimacy and international credibility, it also narrows the definition of therapeutic value and marginalizes alternative, community-based forms of care that persist outside the formal regulatory framework (Rivera-Vélez & Díaz, 2025).

4After a decade of implementation, Colombia’s medical cannabis policy remains deeply contested. Drawing on 25 semi-structured interviews with public officials, entrepreneurs, and civil society actors, this article shows that the policy is characterized by persistent internal tensions. On the one hand, Colombia successfully built a functioning regulatory system, attracted substantial investment, consolidated a small number of compliant firms, and positioned itself as a global exporter of cannabis-derived products. On the other hand, the pharmaceutical model – with its emphasis on medical prescription, laboratory certification, and export-oriented regulation – has constrained domestic access, underdeveloped local demand, and largely excluded small producers from the legal industry. These contradictions point to a central paradox of the Colombian case: a policy that performs well in institutional terms while falling short of responding to social, therapeutic, and economic realities.

5To account for this paradox, the article argues that Colombia’s experience illustrates a form of paradigmatic failure – a situation in which policy ideas no longer correspond to the realities they seek to govern. Policy paradigms define legitimate goals, frame problems, and determine which instruments are considered acceptable, even as they evolve through contestation, reinterpretation, and adjustment (Campbell, 2002; Carstensen, 2015; Skogstad, 2011b; Wilder, 2015). Building on classic distinctions between policy design and implementation (Linder & Peters, 1987), this article integrates paradigmatic analysis into existing frameworks of policy evaluation that examine process, programmatic outcomes, and political dynamics (Bovens et al., 2006; Compton & ’t Hart, 2019; Marsh & McConnell, 2010; McConnell, 2010b, 2015).

6More specifically, the article distinguishes paradigmatic failure from other analytically distinct levels at which policy failure may occur. Paradigmatic failure is understood as a situation in which the underlying way of conceptualizing a policy problem becomes misaligned with evolving social, economic, and political conditions. It is analytically distinct from implementation failure, which arises when policies are poorly executed or unevenly applied, and from policy design failure, which occurs when instruments or policy mixes are ill-suited to stated objectives.

7To assess paradigmatic failure in particular, the article proposes an evaluative framework that distinguishes between evaluation within a policy paradigm and evaluation of a policy paradigm. Evaluation within a paradigm focuses on the internal functioning of policymaking – whether stated goals are pursued and whether policy instruments operate coherently according to the paradigm’s own assumptions. Evaluation of a paradigm, by contrast, examines the ideational dimension of policy, assessing whether the paradigm’s underlying assumptions about the problem, its solutions, and legitimate instruments remain appropriate in light of observed outcomes and changing conditions. This distinction makes it possible to identify situations in which policies may perform consistently within a paradigm while the paradigm itself becomes increasingly misaligned with the realities it seeks to regulate.

8As one of the earliest and most structured efforts to regulate cannabis in the Global South, Colombia offers valuable insight into the challenges of post-prohibition governance (Corda et al., 2019). By examining both the technical and ideational dimensions of Colombia’s medical cannabis policy, this article contributes to ongoing debates on how to evaluate drug policy reform. It demonstrates that policies can be implemented effectively yet still fall short, not because of bureaucratic weakness, but because the ideas underpinning them no longer correspond to the realities they seek to govern. In doing so, it engages with the comparative literature on cannabis reform (Chatwin, 2018; Corva & Meisel, 2022; Decorte et al., 2020), and underscores the importance of interrogating not only what policies do, but the paradigms that shape them. Some paradigms, as we show, prove too rigid or ill-suited to change, ultimately calling for replacement rather than adaptation.

9The article proceeds as follows. Section 1 reviews existing literature on policy success and paradigms, emphasizing the value of integrating these approaches. Section 2 presents the theoretical framework, distinguishing between evaluation within and of a policy paradigm. Section 3 details the methodological approach, and Section 4 presents the empirical results, beginning with the relative success of Colombia’s policy in procedural and programmatic terms and then identifying key limitations of the governing paradigm. The conclusion reflects on the broader implications for policy evaluation and drug policy reform.

Rethinking Success and Failure: Policy Evaluation and the Role of Paradigms

10Understanding whether a policy succeeds or fails requires more than tracking outputs or implementation milestones (Linder & Peters, 1987). This section reviews two complementary strands of scholarship that, when combined, offer a richer evaluative lens. The first focuses on policy evaluation and highlights the need to assess policy along procedural, programmatic, and political dimensions. The second explores policy paradigms, drawing attention to how dominant ideas, problem framings, and instruments shape the goals and outcomes of public interventions. By integrating these perspectives, we build a framework capable of capturing both the performance of a policy within a paradigm and the relevance – or obsolescence – of the paradigm itself.

Success and failure as a contested ground of evaluation

11A foundational assumption in policy evaluation is that performance can be assessed objectively to improve public action. Evaluation, in this view, serves as a diagnostic and corrective tool to identify inefficiencies, adjust inconsistencies, and recommend better policy designs (Bovens et al., 2006). This rationalist and managerialist tradition assumes that governments seek success, aim to avoid failure, and are willing to learn from mistakes (McConnell, 2017). As Marsh and McConnell (2010, p. 566) note, “the evidence-based policy movement has been a powerful force within government, strengthening the assumption that evaluation is the study of policy improvement.”

12Yet policy scholars increasingly challenge this technocratic ideal. As policy processes become more complex and contested, evaluation emerges not only as a technical exercise but also as a political one (Mavrot & Pattyn, 2022). Boyne (2003) argues that public sector performance cannot be reduced to the functioning of isolated institutions; it involves a range of actors and organizations with often conflicting objectives. Consequently, scholars have expanded the criteria for assessing success to include not only effectiveness and efficiency, but also legitimacy, equity, and sustainability.

13From this perspective, policy success becomes a contested and situated judgment, since “one person’s success is often another person’s failure” (McConnell, 2017, p. 3). Evaluation must therefore account for how indicators reflect power relations and divergent stakeholder perceptions (Marsh & McConnell, 2010, p. 570). As Bovens et al. (2006, p. 319) observe, “policy evaluation is an inherently normative act, a matter of political judgment.” This calls for moving beyond binary labels and examining how policies perform across multiple dimensions.

14A widely adopted approach distinguishes three such dimensions: process – how a policy is designed and enacted; programmatic – whether it meets its stated objectives; and political – whether it maintains support and legitimacy (Bovens et al., 2006; Compton & ’t Hart, 2019; McConnell, 2010b). Performance in one domain does not ensure success in another: a well-designed policy may fail in practice, while a politically contentious reform may still achieve its technical aims. Recognizing this, McConnell (2010a) proposes a continuum between success and failure, highlighting “tolerable failures” and “conflicted successes.” Similarly, Bovens et al. (2001) introduce the notion of “non-failure” to capture ambiguous outcomes.

15While constructivist approaches rightly emphasize the political nature of evaluation, they often lack clear tools for normative judgment (Bovens et al., 2006) Acknowledging contestation should not preclude assessment. Building on classic approaches to program evaluation (Vedung, 1997), this framework extends analysis beyond policy performance to include the evaluation of the paradigm itself – the ideas and assumptions that guide policy design and implementation.

Policy paradigms as variables for success and failure

16To assess policy success or failure beyond outputs and implementation processes, this article integrates the concept of policy paradigms into the policy success/failure framework. Policy paradigms encompass the ideas, standards, and problem definitions that guide public action, determining which problems are legitimate, which goals are worth pursuing, and what instruments are appropriate. In his seminal work, Hall (1993) defines paradigms as overarching cognitive and normative frameworks that shape policy choices. Drawing on Kuhn’s (1970) theory of scientific revolutions, Hall identifies three orders of change: first-order changes adjust policy settings; second-order changes modify instruments; and third-order changes – when goals, instruments, and problem framings are all redefined – constitute a true paradigm shift.

17Hall’s model has proven valuable for explaining major transformations, such as the decline of Keynesianism and the rise of neoliberalism (Hay, 2001). Subsequent scholarship, however, has critiqued Hall’s approach for overstating the coherence and stability of paradigms. More recent work adopts a dynamic and constructivist view, seeing paradigms not as fixed blueprints but as evolving frameworks continuously reshaped during implementation (Campbell, 2002; Carstensen, 2015; Daigneault, 2014; Skogstad, 2011b). From this perspective, actors reinterpret goals and instruments in response to shifting institutions, political contestation, and unintended effects.

18This shift also redefines how policy anomalies are understood. For Hall (1993, p. 280), anomalies are developments that cannot be fully explained within a paradigm’s assumptions; when they accumulate, they erode coherence and can precipitate paradigm change. More recent authors, however, interpret anomalies as potential sources of incremental adjustment rather than collapse. Wilder and Howlett (2014, p. 186) describe them as “discrepancies between expected and actual outcomes” that invite ideational work, reinterpretation, or experimentation. Such adaptive responses have led scholars to characterize paradigms as “hybrid” (Skogstad, 2011a, p. 92), “flexible” (Carstensen & Matthijs, 2018, p. 433), “mixed” (Alons, 2020, p. 652), or “achievable” (Coleman et al., 2021, p. 456).

19Some paradigms can nevertheless become obsolete. As Bovens et al. (2006) note, evaluation is shaped by framing and incentives, yet it provides crucial opportunities to revisit underlying assumptions – not only to repair what fails in practice, but to rethink what no longer fits in theory. The study of policy failure often functions as a mechanism for delegitimizing dominant paradigms and opening space for alternatives (Bovens et al., 2001). Evaluation, therefore, is not merely a technical exercise but a potential catalyst for rethinking paradigms.

Differentiating success and failure within and of policy paradigms

20Building on this literature, the article proposes two complementary levels of evaluation. The first assesses whether a policy succeeds within its paradigm, focusing on the design coherence between objectives, instruments, and outcomes. At this level, success depends on the internal alignment of goals and means, and reforms typically aim to refine or adjust the existing paradigm. The second evaluates the paradigm itself – that is, whether its assumptions and objectives remain relevant amid evolving social, economic, and political realities. This level shifts attention from technical design to the validity of the governing ideas. When those ideas become obsolete, the challenge is not merely policy adjustment but paradigmatic change.

21To operationalize this distinction, we build on and expand the widely accepted framework in the literature on policy success and failure, which assesses public policies across three core dimensions: process, program, and politics (Bovens et al., 2006; Compton & ’t Hart, 2019; Marsh & McConnell, 2010). In our approach, the process and programmatic dimensions primarily capture the technical aspects of policy design and implementation and are thus best suited to evaluating performance within a paradigm. The political dimension, however, is essential for assessing the coherence and legitimacy of a paradigm as a whole. Following Hall (1993, p. 280), when control over a policy shifts to new actors, it often signals the erosion of consensus around its underlying principles. Conversely, sustained political support and the absence of major contestation indicate paradigmatic stability and, therefore, success. For this reason, we treat political consensus as a key indicator of a paradigm’s internal coherence and integrate a paradigmatic dimension into our evaluative framework (see Table 1).

Table 1. Dimensions and Indicators of Policy and Paradigm Success.

Type of Evaluation	Dimension of Assessment	Primary Indicator
Within a policy paradigm	Process: Assessment of policymaking quality	Perceived legitimacy and fairness of procedures
	Programmatic: Assessment of goal attainment	Achievement of policy goals
Of a policy paradigm	Paradigmatic: Assessment of idea coherence	Absence of persistent anomalies or contradictions
	Political: Assessment of support and sustainability	Broad, sustained coalition with low contestation

Source: Adapted from Compton & ’t Hart (2019, p. 6).

Evaluation within a policy paradigm

22Evaluation within a policy paradigm assumes that the underlying problem definition, goals, and instruments are shared and legitimate. The analysis therefore focuses on whether policymakers succeed in executing their intentions through appropriate processes and programmatic design.

23The process dimension refers to how policy is formulated, adopted, and implemented. McConnell et al. (2020, p. 593) define process success as “the ability of an individual, group, institution, network or community to shape and steer the direction of the policy development process.” This includes control over agenda-setting, problem framing, and decision-making, as well as the construction of a legitimate, inclusive, and transparent policy pathway. According to Compton and ’t Hart (2019, p. 6), process success is also reflected in stakeholders’ perceptions of the process as fair and deliberative. Process failure, conversely, arises when governments are unable to produce the policy they intended, fail to build coalitions of support, or face criticism over the legitimacy or fairness of their decisions (McConnell, 2015, p. 236).

24The programmatic dimension assesses the congruence between policy goals and actual outputs and outcomes. This involves evaluating whether the policy achieves its stated objectives, operates efficiently, and delivers results that are seen as equitable and sustainable. As Bovens et al. (2006, p. 329) write, programmatic evaluation asks whether a policy “achieve[s] the stated goals of policymakers,” while considering effectiveness and efficiency. Programmatic success is thus reflected not only in technical performance, but in public value creation, logical instrument design, and fair distribution of benefits and costs (Compton & ’t Hart, 2019, p. 6). Programmatic failure, in turn, may involve weak implementation, unintended consequences, or failure to deliver meaningful outcomes (McConnell, 2015, p. 236).

25Failure within a paradigm occurs when a policy performs poorly across both dimensions – when it is poorly designed or perceived as illegitimate and fails to deliver expected results. Yet, as McConnell (2015) notes, success and failure are rarely absolute: a policy may succeed procedurally but fail substantively, or vice versa. Moreover, feedback and corrective reforms can partially mitigate these shortcomings over time.

26Still, even a policy that performs well on process and programmatic grounds may not address the societal problem it claims to solve. This possibility calls for a second level of evaluation – one that assesses not just the policy’s functioning, but the validity of the paradigm that informs it.

Evaluation of paradigms

27The second level of evaluation concern the paradigm itself: the broader set of ideas, goals, and instruments that define how a policy problem is understood and acted upon. This second level of evaluation becomes especially relevant in emerging or contested policy areas, where governing assumptions are still being formed or are increasingly challenged.

28A first criterion for evaluating a policy paradigm is its internal coherence, particularly its capacity to avoid accumulating anomalies. Following Hall (1993), anomalies emerge when real-world developments cannot be explained or addressed within the paradigm’s core assumptions. When such inconsistencies can no longer be resolved through incremental adjustments, they signal a misalignment between paradigm and reality. While some ambiguity is inherent to policymaking, persistent incoherence – especially when driven by efforts to reconcile conflicting objectives or interests through vague or contradictory goals (Palier, 2005) – can hinder effective implementation and reduce legitimacy. As Daigneault (2014) argues, paradigmatic failure arises when anomalies are no longer treated as technical problems but are recognized as symptoms of conceptual obsolescence. This threshold helps distinguish situations that require policy calibration from those that demand a redefinition of the policy problem itself.

29Beyond internal coherence, paradigms must also be evaluated in terms of their external alignment with broader political dynamics (Hall, 1993, p. 280). This includes their compatibility with other sectoral agendas, their ability to generate sustained political support, and their resilience in the face of institutional or societal contestation. McConnell et al. (2020, p. 593) describe this as the “sustainability of policy benefits” – the extent to which a paradigm continues to deliver political value over time. A paradigm that consistently provokes legal challenges, political backlash, or resistance from key actors may indicate deeper structural deficiencies, even if certain policies under its umbrella perform relatively well. Such misalignment often results in reputational costs for policymakers, reduced trust in institutions, or incoherence across policy domains (McConnell, 2015).

30Conversely, paradigmatic success is marked by a broad and stable coalition of support for the paradigm’s core values, instruments, and outcomes. Political association with the paradigm enhances the credibility of public institutions and the legitimacy of its goals (Compton & ’t Hart, 2019, p. 6). In this sense, paradigmatic legitimacy rests not only on technical performance but also on the ability to uphold public trust, navigate contestation, and maintain coherence across policy sectors. When a paradigm becomes a political liability – fueling controversy, litigation, or sustained public opposition – it suggests foundational tensions that incremental reforms alone cannot resolve. Political dynamics, of course, shape all levels of policymaking, including implementation, policy design, and paradigmatic framing. However, the erosion of political support for a policy paradigm nonetheless indicates that the underlying way of conceptualizing the policy problem has become increasingly inadequate.

31In sum, evaluating a policy paradigm requires attention to both its internal logic and its external viability. It means asking whether the paradigm can still meaningfully frame the policy problem, deliver socially acceptable solutions, and sustain political alignment. If failures manifest as unresolved anomalies, then success lies not only in performance but in the capacity of policymakers to provoke meaningful paradigmatic adaptation – or, when needed, a paradigm shift.

Methods

32This study offers a qualitative assessment of the implementation of Colombia’s medical cannabis policy, with the aim of identifying both its procedural successes and paradigmatic limitations. The analysis is primarily based on 25 semi-structured interviews conducted with key actors involved in the regulation, production, and contestation of medical cannabis in Colombia. These include public officials (n=5), entrepreneurs (n=12), and civil society actors (n=8) (see Table 2).

Table 2. Distribution of interviewees.

Type of interviewee	Quantity	Number identification
Public officials	5
Ministry of Justice	1	13
Ministry of Health	1	25
Presidency	1	20
INVIMA	1	15
Ministry of commerce	1	18
Entrepreneurs	12
Small company	6	3, 16, 22, 24, 19, 9
Multinational	6	1, 4, 5, 8*, 2*, 7*
Civil society	8
Drug Policy Reform advocacy	3	6, 14, 17
Cannabis legalization advocacy	3	10, 11,12
Patient associations	2	21, 23

Source: Author’s records. Interviews marked with an asterisk (*) refer to individuals currently working in private companies who previously worked at the Ministry of Justice.

33Interviewees were identified through a combination of pre-existing contacts established during earlier fieldwork (Rivera-Vélez, 2021) and snowball sampling. This approach allowed for the construction of a diverse and information-rich sample that reflects the variety of actors and perspectives surrounding the implementation of medical cannabis policy. Several high-profile individuals were also contacted through professional social media platforms.

34Interviews were conducted between January and February 2025 and focused on the evolution of regulatory frameworks, the challenges faced by both legal and informal actors, and the scope of possible reforms. Interviewees were asked about the formulation and application of different regulations, Colombia’s positioning in the global cannabis market, the accessibility and therapeutic uses of cannabis, and the persistence of illegal practices despite legalization. More broadly, the interviews aimed to document the claims and expectations of actors navigating – or resisting – the country’s pharmaceutical-oriented regulatory model.

35All interviews were transcribed and thematically coded based on two central research questions: (1) how actors assess the procedural and programmatic dimensions of the policy within its original paradigm, and (2) to what extent their experiences call into question the paradigm itself. The coding process combined deductive and inductive strategies. Initial codes were derived from the analytical framework – capturing dimensions such as procedural aspects”, “programmatic coherence”, “political support over time”, and “paradigmatic (ideational) contents” – while additional themes emerged inductively from participants’ narratives, including references to overregulation, bureaucratic learning, or patient/small producers’ exclusion. This iterative process allowed codes to evolve, ensuring that both expected and unexpected insights were incorporated into the analysis.

36To contextualize the interview data, complementary desk research was conducted on grey literature produced by public authorities, NGOs, and sectoral stakeholders, as well as on media coverage and digital content published by cannabis companies. These sources were used to triangulate interview evidence on regulatory evolution and ensure analytical validity, but are not systematically cited, in order to preserve the anonymity of interview participants.

37Finally, it is worth noting that several political actors – particularly legislators involved in cannabis reform – were contacted for interviews. Despite initial expressions of interest, they ultimately declined to participate, likely due to the political sensitivity of cannabis policy in 2025, a year marked by renewed legislative debates and heightened public scrutiny.

The paradigmatic failure of the pharmaceutical medical cannabis model

38This section presents the findings of the study, organized according to the two levels of evaluation outlined above. It first examines the relative effectiveness of Colombia’s medical cannabis policy in terms of design and implementation. It then turns to the limitations of the pharmacological paradigm in addressing emerging needs and expectations.

The Relative Effective Implementation of the Medical Cannabis Policy in Colombia

39An initial assessment of Colombia’s medical cannabis policy highlights relative effectiveness when evaluated in technical terms. This realization is evident in the policy’s multi-objective design, rapid institutional rollout, and the selective consolidation of a legally compliant industry. While later sections question the adequacy of the paradigm itself, this section focuses on the effectiveness of implementation according to the policy’s original goals and internal logic.

Designing a Multi-Objective Policy: Procedural Success within the Pharmaceutical Paradigm

40Colombia’s medical cannabis policy was conceived as a strategic effort to align three distinct policy goals: therapeutic innovation, economic development, and post-conflict rural integration. While these objectives eventually generated tensions, their integration into the initial design reflected a deliberate and negotiated process – a key indicator of success within the procedural dimension of policy evaluation. Rather than stemming from a single-sector logic, the policy emerged from the convergence of user and patient advocacy, investor interest, and broader debates on drug policy reform. Although the reform faced some contestation, it gained legitimacy through political alignment at the highest level of government.

41As Rivera-Vélez (2019b) demonstrates, the process began in 2014 with a legislative proposal from Senator Juan Manuel Galán, supported by advocacy from parents of children with treatment-resistant epilepsy who publicly demanded access to cannabis-based treatments unavailable through the health system. Their testimonies – often shared in the media and before Congress – framed medical cannabis not as a criminal issue but as a moral and humanitarian one, emphasizing the right of families to seek relief for their children. These voices helped shift public perceptions: by the end of 2014, 64% of Colombians supported the legalization of medical cannabis (FIP, 2014). Seizing this momentum, the executive branch under President Juan Manuel Santos capitalized on the growing legitimacy of the issue to advance a more structured reform aligned with its broader drug policy reform agenda. At the same time, a diverse coalition emerged that united patient advocates, reform-minded officials, and entrepreneurs who viewed medical cannabis as both a public health innovation and a new economic frontier. Domestic investors and foreign companies identified Colombia’s favorable climate and low production costs as strategic advantages, while the government saw in legalization an opportunity to attract investment and reposition the country internationally. When the bill faced resistance from conservative policymakers in Congress, the convergence of moral urgency to help the patients, bureaucratic initiative, and market enthusiasm enabled the executive to move forward unilaterally, advancing the reform through executive action – most notably with Decree 2467 of 2015.

42This top-down approach allowed the government to accelerate implementation and consolidate control through technocratic agencies. Three core institutions were tasked with managing the licensing regime: the Ministry of Justice, responsible for cultivation; the Ministry of Health, in charge of transformation; and INVIMA, the regulatory agency overseeing commercialization. The policy framed cannabis simultaneously as a high-risk substance requiring strict oversight and as a tool for economic modernization. As one cannabis expert explained, the model promoted and “known as medical cannabis, is in fact pharmaceutical cannabis,” meaning that it had to follow all clinical procedures and medical standards. Yet he emphasized: “Even though all pharmaceutical products must be medicinal, not everything that is medicinal is necessarily pharmaceutical. What is medicinal is what is good for your health” (Interview 12).

43Initially, the framework lacked mechanisms for rural and small producer’s inclusion. In response, both Congress and the executive branch codified a broader ambition in Law 1787 of 2016 and Decree 613 of 2017, which introduced obligations to support small and medium-sized producers. While these provisions later encountered implementation challenges (see section 2.1), their legal inclusion signaled an effort to reconcile pharmaceutical rigor with broader equity and development goals.

44At the time of adoption, these policy goals aligned with Colombia’s international positioning and investment incentives. The government sought to attract foreign capital by presenting itself as a compliant and cost-effective production hub. Public health safeguards and adherence to international drug treaties further legitimized the framework. Early approval from the International Narcotics Control Board in 2018 reinforced the country’s reputation – though, as later discussed, much of the licensed production never materialized (see section 2.1 and 2.3).

45In sum, the formulation of Colombia’s medical cannabis policy demonstrated a procedurally successful design phase. Through inter-agency coordination, stakeholder engagement, and the articulation of multiple goals, the state established a regulatory framework that was both institutionally legitimate and internationally visible. Although later implementation would expose contradictions, the initial phase represented a relatively coherent and inclusive attempt to balance competing interests within a novel policy domain.

Early Implementation and Regulatory Responsiveness: Delivering on Policy Commitments

46The second key indicator of policy success within the Colombian medical cannabis framework lay in the speed and scale of its early implementation. Following the adoption of the first regulations in 2015, the Colombian government moved swiftly to operationalize the regulatory framework. Within months, administrative procedures were established for licensing, quota allocation, and inter-agency coordination. By 2017, a functioning regulatory system was in place, the first cultivation and manufacturing licenses had been granted, and their number continued to grow exponentially until 2021 (Table 3).

47The government’s early prioritization of implementation was shaped by both political and economic imperatives. Politically, the Santos administration presented the cannabis industry as a visible sign of Colombia’s break with prohibitionist drug policy and as a symbol of responsible regulatory innovation. Economically, the policy offered a compelling narrative for the post-conflict period, especially by attracting foreign investment and positioning Colombia as a cost-effective production hub for pharmaceutical cannabis. By 2024, the Ministry of Justice had received over 2,400 license applications for cannabis production, of which only 3.8% were rejected (Table 3). Similarly, the Ministry of Health had granted 781 transformation licenses between 2017 and August 2024 (Rojas, 2024). As one official summarized, “The truth is that in those early days, the intention was to grant licenses” (Interview 25).

Table 3. Cannabis production licenses granted by the Ministry of Justice, 2017-2024

Year	First-time license applications received	First-time licenses granted	Applications rejected
2017	68	27	2
2018	941	159	15
2019	1 331	427	16
2020	241	928	28
2021	177	664	38
2022	73	210	11
2023	48	57	0
2024	19	21	1
Total	2 898	2 493 (86%)	111 (3,8%)

Source: Ministerio de Justicia y del Derecho (2025).

48This wave of market entry was partly fueled by investor enthusiasm and favorable international media coverage, which portrayed Colombia as an emerging cannabis leader (e.g. Semana, 2021). The regulatory clarity and early administrative responsiveness were widely praised by both international firms and domestic entrepreneurs, contributing to what several stakeholders described as a “speculative bubble” of investment (Interview 17). According to industry data, the medical cannabis sector received more than $650 million in investment between 2016 and 2024 – despite generating only $32 million in revenue (Becerra, 2025).

49Even when the conservative administration of President Iván Duque (2018–2022) initially sought to restrict license issuance, the economic crisis triggered by the COVID-19 pandemic prompted a shift in policy orientation. As noted by government officials, the right-wing administration came to view cannabis as a strategic sector for economic recovery (Interviews 3 and 24). In September 2020, cannabis was designated a “Project of Strategic National Interest,” a move that helped to reinforce investor confidence, accelerate bureaucratic procedures, and improve inter-agency coordination. Decree 811, adopted in 2021, aimed “to ensure that a solid industry was developed,” by introducing digital platforms (such as the MICC system) and establishing clearer mechanisms for revoking inactive licenses and closing “paper companies” with no actual production (Interviews 20 and 25).

50Beyond administrative streamlining, Decree 811 enabled regulatory expansion. Responding to industry demands, it introduced provisions authorizing industrial, food, and veterinary uses of cannabis (Interviews 24 and 25). Crucially, it also lifted the ban on cannabis flower exports – a product previously restricted due to concerns about diversion to recreational use and perceptions of lower profitability compared to derivatives. One of the decree’s drafters, in a detailed legal analysis, explained how this shift reflected a broader change in bureaucratic thinking: officials came to believe that the industry’s survival depended on diversifying its market outlets (López Amaris, 2022).

51From a process evaluation perspective, these developments demonstrated the state’s adaptability and responsiveness to policy feedback – key indicators of procedural robustness. As later sections will show, the expansion also revealed structural limitations: many companies obtained licenses but failed to reach the production stage. Nevertheless, these challenges did not negate the overall success of early implementation. Within five years, the state had set up a complex, multi-agency regulatory system, issued thousands of permits, and demonstrated political commitment to translating policy goals into administrative practice. The institutional capacity mobilized – particularly within the Ministries of Justice and Health – represented a significant achievement in the procedural dimension of policy evaluation.

Selective Programmatic Success: Sectoral Consolidation Without Inclusion

52Despite slow access to markets and persistent structural barriers (see section 2), a core segment of Colombia’s medical cannabis sector consolidated in recent years, marking a degree of programmatic success within the boundaries of the original policy paradigm. Although many companies failed to transition from licensing to production or exited the market altogether, a group of well-capitalized and technically equipped actors succeeded in establishing vertically integrated operations. These firms – primarily export-oriented – began producing, processing, and marketing cannabis-based products with increasing stability.

53This selective consolidation reflected the ability of a small number of firms to adapt to Colombia’s demanding regulatory environment. Those that endured typically met strict compliance requirements, secured investment – particularly from foreign sources – and navigated the complex licensing and quota systems across multiple government agencies. Since 2021, when Decree 811 introduced new regulatory flexibilities, including the long-awaited authorization of flower exports, these actors started to generate commercial returns. According to data from the Ministry of Health (Rojas, 2024), since 2020, Colombian companies established sales agreements and entered profitable markets for cannabis flower (mainly in Germany, Portugal, Switzerland, and Australia); cannabis derivatives (in the United States, Brazil, Argentina, Uruguay, the UK, Germany, Spain, Switzerland, Czech Republic, Israel, and Australia); and finished products (in Brazil, Argentina, Peru, Uruguay, Chile, Germany, France, the UK, Australia, and New Zealand). Several interviewees emphasized that this shift – from speculative licensing to real production – represented a turning point in the maturation of the sector, even if limited to a small group of actors (Interviews 2, 7, 8, 16, 24).

54From a programmatic evaluation perspective, these developments suggest a partial fulfillment of the policy’s original economic goals. The emergence of a legal, export-oriented industry – albeit narrow in scope – confirmed that Colombia’s regulatory model was capable of enabling compliant and profitable production, at least for select actors. As one official recalled: “We imagined six or seven companies doing this, not 50 trying to do the same thing” (Interview 8). To do so, “The technical quota group defined the market rules very cautiously and collectively” (Interview 25). In the end, it was mid-level bureaucrats that pragmatically adapted unclear rules to operationalize the licensing system, showing bureaucratic learning despite regulatory overload (see section 2.1).

55However, the policy’s social and developmental objectives remained largely unmet. The firms that consolidated were, for the most part, urban-based, capital-intensive, and foreign-backed, with limited integration of small or rural producers. Inclusion mechanisms – such as the 10% sourcing obligation requiring processors to purchase from small or rural producers – suffered from weak enforcement. Moreover, support structures for marginalized actors remained underdeveloped. Several entrepreneurs noted that the policy created a dual reality: a regulated, export-facing sector slowly maturing, and a domestic-facing sector still defined by informal access and limited medical uptake (Interviews 2, 7, 16). In the view of some officials, this exclusion was “closely related to the fact that they have not managed to meet the health requirements for obtaining those authorizations” (Interview 13). Further inclusion remains possible, at least in principle, through more socially oriented implementation within the existing paradigm.

56In sum, the consolidation of a small but resilient legal cannabis sector constituted a programmatic success from within the pharmaceutical paradigm. The survival and growth of a few firms reflected institutional capacity, regulatory adaptability, and policy learning – largely in line with the original expectations of policymakers. Yet the narrowness of this success highlighted the limitations of a model centered on pharmaceutical compliance and export competitiveness, rather than inclusive development or patient-centered access.

The Failure of the Pharmaceutical Cannabis Paradigm

57This second section shifts the focus from implementation to paradigm evaluation, revealing the structural limits of Colombia’s pharmaceutical approach to medical cannabis. While the regulatory framework was technically robust, it rested on assumptions that proved poorly aligned with the realities of cannabis production, medical use, and market behavior. Licensing did not translate into production, and regulation outpaced both demand and access – producing a policy that was coherent on paper but increasingly disconnected from the field it sought to govern.

Excessive Regulation and a Paradigm Ill-Suited to Cannabis

58The first major limitation of Colombia’s medical cannabis policy lay in the profound mismatch between its regulatory logic and the agricultural and entrepreneurial realities it was meant to govern. From its inception, the policy was shaped by a pharmaceutical-conservative paradigm that defined cannabis as a high-risk substance requiring strict state oversight, medical prescription, and laboratory-standard quality controls. These foundational assumptions – designed to ensure medical legitimacy and international compliance – produced an overregulated system ill-suited to the effective production, distribution, and use of cannabis as an agricultural and therapeutic product. This constitutes a failure of policy design rather than implementation.

59To understand this misfit, it is important to recall the administrative procedures required for commercializing cannabis products. A company first had to obtain a cultivation license from the Ministry of Justice. It then needed to apply for a production quota from an interministerial technical group, which evaluated the request based on projected demand. To justify this demand, firms were often required to present a letter of intent from a buyer – even before having the product in hand. In other words, to produce a quantity of derivative, companies had to be authorized to produce a specific quantity of cannabis; to produce that cannabis, they needed authorization to cultivate a corresponding number of plants. The entire system operated backwards, consistent with the narcotics production logic of global drug control regimes, in which, as one official explained, “you have to demonstrate the need, and then the regulatory agency authorizes the production” (Interview 8, also interview 25).

60Once the quota was approved, cultivation could begin. But further steps required additional authorizations: transformation into medicinal products needed a license from INVIMA; commercialization on the domestic market required sanitary registration from the same agency; and exports needed approval from the National Narcotics Fund (FNE) – and, in the case of cannabis flower, from the Colombian Agricultural Institute (ICA). The process could cost over USD 800 (Cruz & Pereira, 2021, p. 137) and took, at best, 90 days – a timeline incompatible with products like cannabis flower, which needed to be sold fresh at around 30 days.

61Quotas had to be renewed annually and were often conditional on pre-established sales contracts, which many firms were unable to secure in advance. This restricted the ability to harvest multiple crops per year – despite Colombia’s tropical climate and stable light cycles, which were ideal for cannabis cultivation (Interviews 2, 3, 22).

62For many industry actors, the system represented clear “overregulation” (Interview 12) or “regulatory barriers” (Interview 24), a diagnosis shared by several public officials. Due to the high volume of applications and limited administrative capacity, the licensing system quickly became a bottleneck. As one official noted, “The licensing process was a disaster” (Interview 25). Although companies and civil servants proposed simplifying the framework – for instance, with a single license that would allow for progressive monitoring – such proposals were not adopted. Decree 811 encouraged streamlining but failed to eliminate the core bureaucratic burdens (Interviews 24 and 25). At the time, regulatory design was shaped by what one official described as a climate of “paranoia” about recreational use (Rivera-Vélez, 2025b, p. 77), and simplification was dismissed on the grounds that it could facilitate diversion (Interview 24).

63In short, the pharmaceutical paradigm imposed control mechanisms that were structurally incompatible with the agricultural nature of cannabis production. As one entrepreneur observed, “When you want to control absolutely everything, you end up controlling nothing and screwing over those of us who do comply with the controls, while making things easier for those who operate in a slightly more gray area” (Interview 2). Alongside the commercial challenges discussed in sections 2.2 and 2.3, this bureaucratic burden led many stakeholders to lose confidence in the legal framework. Activists and small entrepreneurs increasingly avoided the formal market, which they viewed as costly, punitive, and offering few advantages (Interviews 10, 11, 12, 19, 21, 23).

64Several actors also reported that Indigenous communities and traditional smallholder producers – particularly in Cauca and Nariño, regions that long supplied domestic therapeutic demand (Góngora, 2019) – increasingly rejected the legal model altogether. Some even began to oppose other reforms in the medical cannabis market or for recreational legalization, fearing that formalization would displace their existing market share (Interviews 12 and 22).

65On political grounds, the evaluation of implementation was largely negative. Most cannabis producers condemned the licensing regime as an obstacle to industry development and as a betrayal of the policy’s broader developmental and inclusionary goals. What began as a policy promising opportunity and transformation ultimately constrained production through a misaligned paradigm of pharmaceutical control – one ill-equipped to accommodate the agricultural, social, and therapeutic dimensions of cannabis in Colombia.

A Narrow Therapeutic Paradigm Misaligned with Medical Realities

66A second paradigmatic limitation of Colombia’s medical cannabis policy lay in the discrepancy between its initial promises and the actual therapeutic uses of cannabis in the country. The policy was framed as a transformative public health intervention – particularly for children with treatment-resistant epilepsy – and promised safe, equitable access through state-regulated channels. To ensure legitimacy and international credibility, the regulatory model was built around stringent medical protocols. Cannabis-based products were required to conform to pharmaceutical standards, including high-precision dosage, standardized active compounds, and documented clinical evidence.

67The legal framework envisioned three categories of cannabis products: (1) standardized pharmaceutical medications developed using synthetic cannabinoids; (2) standardized phytotherapeutic products (or herbal preparations) derived from plant extracts; and (3) individualized magistral formulations prepared in pharmacies on prescription from synthetic or natural derivates. However, each of these pathways encountered significant obstacles. The first required years of research and development, entailing high costs and uncertain returns. The second was systematically rejected by INVIMA unless backed by robust scientific evidence. The third – though theoretically more flexible – was poorly reimbursed, costly to produce, and limited to specialized pharmacies. As one entrepreneur remarked, “it’s not really Colombia’s fault or anything, but rather the fault of the entire medical sector for arriving and being focused on the pharmaceutical world” (Interview 3).

68In practice, this narrow pharmaceutical framing proved ill-adapted to the empirical realities of cannabis use and the evolving needs of patients and prescribers. Inflated expectations at the outset – fueled by global narratives portraying cannabis as a “miracle drug,” especially in pediatric care (Cox, 2021) – helped generate political momentum. Yet the clinical evidence remained limited, and much of the circulating knowledge was anecdotal or based on experimental use (Rivera-Vélez, 2025b). Over time, it became increasingly clear that cannabis therapies were most effective as complementary treatments – useful for managing symptoms such as pain, anxiety, or insomnia, but rarely curative or sufficient as standalone interventions (Hoch et al., 2025).

69Clinical uptake was further complicated by the fact that most existing trials focused on isolated or synthetic cannabinoids rather than full-spectrum plant products (Senator et al., 2025). Moreover, cannabis use was not without risks (Dawson et al., 2024), reinforcing reluctance among physicians- many of whom reported lacking adequate training on therapeutic cannabis. As one entrepreneur explained, “Cannabis has come to solve the diseases of the new world – problems such as anxiety, lack of appetite, lack of sleep, stress-related issues. But it can’t compete with ‘pills,’ like Aspirin, which everyone knows and which, ultimately, have the backing of big pharmaceutical companies” (Interview 3).

70Two conclusions emerge from this reflection. First, patients rarely substituted conventional pharmaceuticals with cannabis spontaneously; the dissemination of alternative medical knowledge remained gradual. This dynamic was compounded by the dominance of CBD – promoted particularly for pediatric use (Rivera-Vélez, 2019a) – even though it was generally less effective than THC-based products for a broader range of conditions (Hoch et al., 2025). Second, the pharmaceutical market was governed by entrenched commercial logics: major laboratories invested heavily in prescriber education and market penetration, while cannabis startups lacked comparable resources.

71Some companies attempted to bypass these barriers by partnering with medical associations or universities to offer training on medical cannabis, but such initiatives remained marginal. While a fringe of the medical profession showed openness, most practitioners did not adopt cannabis therapies. This professional reluctance, combined with high out-of-pocket costs and the absence of insurance coverage, sharply limited legal demand. Although public discourse emphasized the “right to access,” formal channels remained largely inaccessible, prompting many patients to turn to informal or grey-market suppliers where products were cheaper and more familiar, though often unregulated.

72In Colombia, the use of medicinal cannabis became more visible but remained largely exploratory (Cubillos Sánchez, 2021). As a result, legal demand stayed low, and many potential users never entered the formal system. This disconnect reflected a second form of political failure: the intended beneficiaries of the policy – patients – rejected the very solutions it offered. In other countries, access to medical cannabis was facilitated through temporary regulatory exemptions, which allowed practitioners to generate evidence through supervised experimentation (Bernard & Jeanroy, 2025; Mavrot, 2023; Pereira, 2025). As one entrepreneur recalled, “We have forgotten the domestic market, the patient market” (Interview 5). Ultimately, unregulated patient associations became “the only way for patients to access products” (Interview 23), thereby compromising their health and exposing them to additional risks.

73Ultimately, the limited medical uptake of cannabis in Colombia did not indicate a failure of implementation, but rather a conceptual misfit between the policy’s pharmacological paradigm and the real-world functioning of therapeutic cannabis. By prioritizing regulatory control over accessibility, affordability, and learning-by-doing, the policy failed to foster the broad, patient-centered experimentation needed to realize its public health goals. This gap constituted a second paradigmatic anomaly – rooted not in execution, but in the governing assumptions themselves.

A Misaligned Market Strategy and the Internal Anomalies of the Therapeutic Paradigm

74A third paradigmatic limitation of Colombia’s medical cannabis policy lay in its growing disconnection from the structure and dynamics of global cannabis markets. While the policy was initially conceived to position Colombia as a leading exporter of pharmaceutical-grade cannabis products, the internal assumptions embedded in this ambition – particularly the exclusion of dried flower, the prioritization of processed derivatives, and strict adherence to pharmaceutical norms – ultimately undermined its competitiveness in the most dynamic segments of international trade.

75The year 2018 marked a turning point. On one front, the legalization of recreational cannabis in Canada – originally viewed as a promising export destination – was accompanied by a protectionist regime that restricted all imports, including those from Colombia. On another, the U.S. Farm Bill liberalized domestic hemp production, leading to global oversupply. This glut caused cannabis oil prices to collapse, from approximately $12,000–13,000 per liter to just $1,500 (Interview 16). These shocks revealed the fragility of a strategy overly reliant on extract-based pharmaceutical exports and on highly regulated North American markets.

76In response, Colombian regulators introduced Decree 811 of 2021, authorizing the export of dried cannabis flower – a format that dominates global consumption and is often preferred by patients for its affordability, rapid onset of effect, and adaptability to individual needs. As one entrepreneur explained: “The German market for flowers is around 20 to 25 tons, which has doubled in five years. But the number of countries and companies supplying Germany also increased fivefold. So Colombia lost any chance of being relevant in that market, and that also, of course, affected companies in Colombia” (Interview 8).

77These developments pointed not only to regulatory delays but to a more fundamental failure of paradigmatic coherence. The original policy architecture was rooted in a pharmaceutical-industrial logic that emphasized control, vertical integration, and medical standardization. This design imposed high compliance costs, restricted product formats, and discouraged innovation – undermining Colombia’s ability to compete in a global cannabis economy increasingly defined by flexible, consumer-driven models that blur the boundaries between medical, wellness, and recreational use. As one expert observed, “Where there are dried flowers, the line between medicinal and recreational use becomes blurred” (Interview 8).

78Germany exemplified this hybridity. Despite its recent legalization of recreational cannabis, retail access remained confined to the medical system where patients could obtain high-quality flower through a simple prescription. Colombian companies recognized this opportunity and increasingly oriented themselves toward this “grey” medical-recreational space in Europe (Rivera-Vélez, 2025a). The firms that succeeded were those capable of adapting to or circumventing the constraints of the domestic regulatory paradigm – not those that fully complied with it.

79This strategic flexibility abroad stood in sharp contrast to the contradictions of the domestic market. While exports of dried flower were authorized in 2021, domestic sales remained prohibited. As one entrepreneur remarked, “The irony lies in the fact that today I can export flowers to Germany – a patient with chronic pain in Germany can smoke Colombian marijuana grown in Colombia in Germany – but no Colombian patient can access flowers grown in Colombia, whether to smoke them, vaporize them, or make juice out of them” (Interview 12). This paradox revealed a troubling disconnect between the policy’s stated goals – public health access and economic development – and its real-world effects.

80In analytical terms, this reflects a paradigmatic inconsistency between the regulatory model’s internal logic and its capacity to adjust to external conditions. The reform aimed to make Colombia a global player, but its underlying design failed to anticipate – or respond to – the fluidity of international cannabis markets. The exclusion of dried flower, the delay in authorizing exports, and the continued prohibition of domestic access all point to a model that prioritized symbolic control over market responsiveness and feedback.

81In short, the policy’s inability to reconcile its internal assumptions with external demands constituted a third paradigmatic anomaly. It exposed the limits of a regulatory paradigm oriented toward medical control and international legitimacy, but blind to evolving patterns of cannabis use and commerce. The most successful firms were not those that conformed to the policy’s initial blueprint, but those that moved beyond it – suggesting the need to re-examine not only how the policy is implemented, but also the foundational ideas that continue to shape its trajectory.

Conclusion: Rethinking Implementation Success through Paradigmatic Evaluation

82This article evaluated Colombia’s medical cannabis policy by distinguishing paradigmatic failure from the more commonly identified forms of implementation failure and policy design failure. It sought to understand how a policy can appear institutionally robust – successfully implemented and administratively coherent – while remaining socially and economically misaligned with the realities it was intended to transform. The analysis shows that, although the policy performed relatively well at the level of implementation, it fell short at the levels of policy design and, more fundamentally, paradigm. As summarized in Table 4, the evaluation reveals mixed results across the different analytical dimensions of the assessment.

Table 4. Evaluation of Colombia’s Medical Cannabis Policy (2025).

Type of Evaluation	Dimension of Assessment	Evidence
Within a policy paradigm	Process – Quality and coordination of policy implementation	Mixed–positive: Initial implementation (2015-2018) was rapid and institutionally coordinated, showing bureaucratic learning capacity. However, subsequent regulatory fragmentation and high administrative costs limited responsiveness.
	Programmatic – Achievement of policy goals	Partially positive: A functioning licensing system and small export-oriented industry were consolidated, but domestic medical supply and patient access remain minimal, relying largely on informal channels.
Of a policy paradigm	Paradigmatic – Relevance of underlying policy ideas	Negative: The pharmaceutical paradigm’s focus on clinical validation and export markets is increasingly misaligned with social, therapeutic, and economic realities; it excludes small producers and community-based models.
	Political – Assessment of support and sustainability	Ambivalent: Political support endures because of the sector’s economic symbolism, yet legitimacy among patients and producers has eroded. The paradigm persists through elite and bureaucratic consensus rather than broad social backing.

Source: Author’s elaboration.

83At the process level, implementation was initially rapid and well coordinated, demonstrating bureaucratic learning and institutional capacity under the Santos administration. Yet over time, regulatory fragmentation and excessive administrative burdens limited responsiveness. In programmatic terms, the policy succeeded in establishing a functioning licensing regime and a small export-oriented industry but failed to ensure domestic access or inclusion of small producers, leaving patient associations to operate informally. At the paradigmatic level, the dominance of a pharmaceutical logic – centered on clinical validation, prescription control, and export competitiveness – proved increasingly misaligned with the social and therapeutic realities of cannabis use in Colombia. Finally, on the political dimension, support for the reform has persisted mainly because of its economic symbolism: successive governments continue to view cannabis as a strategic export sector, even as legitimacy among patients and smallholders erodes.

84Together, these findings depict a policy that is technically effective but paradigmatically constrained – a case of institutional consolidation without conceptual adaptation. Colombia’s reform exemplifies paradigmatic failure, showing how governments can implement policies efficiently while perpetuating models that no longer fit the evolving social and economic contexts they are meant to address.

85Theoretically, this article contributes to policy evaluation scholarship by integrating insights from policy paradigm theory. Building on existing frameworks for policy evaluation – particularly the process, programmatic, and political dimensions identified in the literature (Bovens et al., 2006; Compton & ’t Hart, 2019; Marsh & McConnell, 2010; McConnell, 2010b, 2015) – it argues that evaluation should consider not only how effectively a policy achieves its goals, but also whether the ideas and problem framings that define those goals remain valid over time. By distinguishing implementation failure, policy design failure, and paradigmatic failure, the article shows that effective execution does not guarantee policy adequacy. Colombia’s medical cannabis reform succeeds at the level of implementation, partially fails at the level of policy design, and ultimately fails at the paradigmatic level, where pharmaceutical control crowds out therapeutic diversity, inclusion, and learning. As a result, bureaucrats interpret the consolidation of the cannabis licensing system as institutional strength, whereas small producers, patients, and advocates experience it as exclusion and regulatory capture.

86While the literature has emphasized that adaptable and flexible paradigms can foster policy learning and innovation (Alons, 2020; Carstensen & Matthijs, 2018; Skogstad, 2011a), Colombia illustrates the reverse: an incoherent and rigid paradigm that limits problem-solving capacity and blocks meaningful social change. The recent authorization of medical cannabis flower sales in October 2025 exemplifies this pattern. Although presented as a reform to expand domestic access, the measure remains confined within the same restrictive framework: sales are limited to pharmacies, and stringent prescription and storage requirements render the product largely inaccessible. As McConnell (2020) notes, such initiatives often function as placebo policies – symbolic gestures that create the appearance of progress while avoiding deeper structural reform. The 2025 authorization therefore represents a placebo response to a policy trap, allowing the government to demonstrate responsiveness without challenging the pharmaceutical paradigm that has constrained the market since 2017. These developments confirm that even as policies evolve, the dominant paradigm continues to prioritize control and compliance over experimentation and patient autonomy.

87Colombia’s medical cannabis policy demonstrates that reform can consolidate institutionally while failing ideationally, reminding us that policy durability is not synonymous with policy adequacy. Meaningful reform requires not only technical efficiency but also paradigmatic renewal – a rethinking of the ideas that define what counts as medicine, expertise, and legitimacy. Comparatively, Colombia’s experience contrasts with that of Argentina, where reforms have gradually incorporated patient associations and small-scale producers into the legal framework (Rivera-Vélez & Díaz, 2025). These cases suggest that paradigmatic adaptation is possible when reforms embrace plural forms of expertise and social participation. For Colombia, the challenge lies not in administrative capacity or implementation effectiveness, but in paradigmatic openness: reimagining the policy model to integrate local therapeutic practices, diverse producer networks, and patients’ experiential knowledge. As the global landscape of medical cannabis continues to evolve, such renewal will determine whether post-prohibition governance can move beyond control toward accessibility, equity, and social inclusion.