DRUG POLICY
Samenvatting
Joren Brauwers
Academiejaar 2025-2026
, PARTIM COLMAN
H1: EXPLAINING THE BASIC
ILLICIT DRUGS MARKET
1. INTRODUCTION
WHAT IS DRUGS POLICY ?
By "drug policy" we mean all the rules, laws and plans a government makes to deal with drugs. It's about how drugs are
used, made and sold, and about the consequences of that — for both legal drugs (like alcohol) and illegal drugs. There are
different ways a drug policy handles this:
- Prevention: Informing people so they don't start using drugs, for example through education at schools.
- Support (treatment): Helping people with an addiction through medical and psychological support.
- Enforcement: Checking and punishing when people sell, make or possess drugs.
- Regulation: Setting the conditions under which certain drugs (like alcohol, tobacco or medical cannabis) are allowed to
be legally sold and used.
- Harm reduction: Measures to reduce the damage from drug use, such as handing out free clean needles or opening safe
drug-use rooms.
In short, it covers things like:
- What's allowed — which substances are legal, banned, or available only by prescription.
- Punishment vs. help — whether people who use or sell drugs get arrested and punished, or get treatment and support.
- Reducing harm — measures meant to keep people safer, like clean needle programs, overdose medication, or drug-
checking services.
- Prevention and education — efforts to stop problems before they start, like school programs or public health campaigns.
Different countries take very different approaches. Some focus on strict bans and criminal penalties (often called the "war
on drugs"), while others lean toward treating drug use as a health issue rather than a crime
DRUGS MARKET
The illicit drugs market (buying and selling of drugs) IS THE LARGEST CRIMINAL MARKET IN THE EUROPEAN UNION
- >1/3 EU organized crime groups are involved: production, traffic, and smuggling of illicit drugs, more than 1/3 of all EU
organized criminal groups are involved in the illicit drug market
- Large profits involved The EU drug market (at retail level) is worth at least €24 billion per year. Making money is the
main reason these groups do it.
LINK BETWEEN ILLICIT DRUG ECONOMY AND LEGAL ECONOMY
Undermining crime by drug crime means the way organized criminal groups gain influence over society, the economy, and the
government by mixing their criminal activities into legal structures. So Infiltration of organized crime into political, socio-economic
and financial power So the illegal world and the legal world become intertwined (connected and tangled together).
- Corruption or infiltration in local government Criminal networks try to influence local authorities by bribing officials or
placing their own people in government jobs. This lets them get inside information and, for example, obtain permits for
buildings that are secretly used to produce or sell drugs.
- Money laundering (washing illegal money) Criminals use legal businesses (like a hairdresser, restaurant, or real estate)
to make their illegal money look like it came from a legitimate source. 44% of profits re-invested in the legal economy of
Europe by money laundering (EMCDDA, 2016)
o Possible solution: if a local government suspects a building is used for illegal activities, they can take it away —
but of course, corruption can get in the way (point 1)
- Infiltration into legal sectors Criminal groups expand into legal industries like real estate, hospitality (bars/restaurants),
or transport. This lets them hide their crimes behind a normal-looking business. Criminals often intertwine with legal
businesses, so there is sometimes a connection between the UPPERWORLD (legal business) and the UNDERWORLD
(criminals)…. They use legal business to hide their activities, launder money,….
o Problem: unfair competition, because these criminal networks have a huge amount of money compared to
honest businesses.
1
,DIFFERENCES IN ORGANIZATIONAL STRUCTURES
There are two main ways criminal drug organizations are structured:
- Pyramid structure: This is a hierarchy, like a triangle. There's a boss at the top, and orders flow down through
different levels to the people at the bottom. Everyone knows their place, and power is clearly organized from
top to bottom. So there is clear leaderships and a clear distribution of tasks
- Flexible partnerships (cell-based structure): Instead of one big chain of command (top-down), the work is
split into separate "cells." Each cell has its own job/expertise and doesn't know what the other cells are
doing — or even who they are. So decentralized (not one boss at the centre making all the decision),
fragmented (divided in cells), and situational (can adapt if necessary)
o Example: large-scale cannabis production
▪ Cell 1: builds the plantation
▪ Cell 2: maintains the plantation
▪ …
▪ They don't know each other.
o Why use cells? Safety. If one cell gets caught by the police, its members can't reveal the others,
because they don't know them. This protects the whole organization.
DRUG MARKETS ARE ADAPTIVE AND RESILIENT
The drug markets are adaptive and resilient, meaning they keep going and keep the connection between producers and
buyers alive, even when there's pressure from outside (like police crackdowns) by altering the modus operandi (they way
they do certain things,…), or find different alternative to keep the profit-level the same (making money is their #1 goal and
priority and they will do everything the keep it that way
- They learn from legal businesses (organization, innovation): Illegal drug markets often copy legal companies and
use successful business models.
o (1) Seizing opportunities and innovations — for example, online drug markets (cryptomarket, when the
police shuts one down, they just move to another one)
o (2) The role of globalization — just like normal companies make their business more efficient by building
foreign contacts, drug markets do the same to keep transport efficient.
o (3) The difference from the legal market — illegal markets are NOT bound by rules and have plenty of
money.
- One of the main reasons drug markets are adaptive and resilient is that they change their "modus operandi"
(their way of operating): (!!!!)
o Example: clever use of national borders — cooperation between the Netherlands and Belgium. Activities
are split between countries, which makes them much harder to link together and harder for authorities
to stop, because different countries are involved.
▪ Production = Belgium
▪ Waste = Netherlands
o Example: fewer cocaine seizures at the Port of Antwerp because of innovative methods — this is actually
NOT a good sign, because we know Antwerp is still used as a channel for drug trade. So criminals are using
innovative methods: instead of hiding cocaine in containers with bananas, they now put it, for example,
in the fabric of clothes (clothes with cocaine in them), and the cocaine is later extracted from the clothes
in a "cocaine laundry."
▪ The modus operandi has simply changed, but the same amount is still coming in — we just
haven't found it, because we focus too much on the traditional methods.
2. 4 LEVELS OF THE DRUG SUPPLY MARKET
The supply chain is the path every product follows, from production to consumption. It has 4 levels (echelons):
1. Production — e.g. cocaine made in Colombia
2. Wholesale — e.g. exporting large amounts to Europe (100 kg)
3. Middle trade (intermediate) — e.g. "cutting" the drugs and splitting them into 5 kg packages for different dealers.
o "Cutting" = mixing pure drugs with other substances to increase the quantity. This means more packages
can be sold (less pure), so profit goes up.
4. Retail — each dealer splits it into user-sized amounts (1–5 g) and sells to users.
2
,PRODUCTION
Regarding the production or manufacturing of drugs, we can make a distinction between different drugs and the country
who are the main producers:
- Synthetic drugs (made in a labo): Europe
o MDMA (XTC) & amphetamines: mainly produced in Belgium, Netherlands, Germany, and Bulgaria. Belgium
and the Netherlands are world-famous for this (their "top products").
o Methamphetamine: mainly the Czech Republic, increasingly the Netherlands (possible future for Belgium
through cooperation with the Netherlands).
- Cocaine: Latin America
o Main producers: Colombia = 70% of world production, Peru = 20%, Bolivia = 10%.
▪ New trends in Europe: the final production steps (turning cocaine paste into powder) now happen
in Europe too. Paste is delivered (harder to detect) and turned into powder in European labs. Also
"cocaine laundries" extract cocaine from the fabric of clothes
- Cannabis: a worldwide phenomenon — 159 countries report producing it.
o Hash (2010–2015): mainly Morocco, Afghanistan, Lebanon, India & Pakistan (but also local).
o Marijuana (2010–2015): produced locally.
- Opium: Afghanistan + Myanmar + Mexico = about 96% of world production
o Afghanistan – the "Golden Crescent" (with Pakistan & Iran): biggest opium producer (86%) and main heroin
supplier to Europe.
▪ Today: the Taliban opium ban has reduced production, so there's much less heroin on the EU market.
▪ Result: since people still use, they look for alternatives — synthetic opioids (like fentanyl).
• Danger: these synthetics are much stronger → risk of overdose.
• But NOT really the case in Belgium — no shift to synthetic opioids there.
o Myanmar – the "Golden Triangle" (with Laos & Thailand): about 5% of opium, mainly for Asia
o Mexico: another important supplier, mainly to the US.
WHOLESALE
This is about importing and exporting large amounts of drugs via various transport methods:
- Airports (small and large), often via private planes (less control)
o Through air cargo or postal packages (DHL, TNT, FedEx)
o Through an insider in the airport sector
o Through passengers — in luggage, or in/on the body ("body packers" who swallow capsules)
- Seaports (large and small)
o Hidden in a full container (or in its structure/walls)
o Hidden in legal cargo (empty containers)
o Hidden on the ship (e.g. in the command room)
o "Drop-off" = moving drug loads from big ships to smaller boats (speedboats, fishing boats)
o Hidden under the ship (collected by divers)
- Over land — via railways and roads
3
, Belgium is a strategic transit country (country where the drugs come in and are distributed across Europe) for
international drug trade because of:
1. Central location in Europe — an ideal hub to distribute drugs to neighbors (France, Germany, Netherlands, UK),
thanks to Schengen (open borders).
2. Access to several seaports — e.g. the Port of Antwerp, one of the world's largest, a major entry point for cocaine
hidden in containers.
3. International airports — e.g. Zaventem (Brussels) and Charleroi, attractive entry points for couriers and air
freight/postal packages.
4. Extensive road and rail network — allows fast distribution to other European countries.
PROBLEMS WITH TACKLING WHOLESALE
(1) Modus operandi changes — The criminals' "way of operating" keeps changing depending on the timing,
place, and the situation (for example, dodging stricter laws or more police checks in one area by switching
methods or routes)
(2) Jurisdiction: each country's police can only act within its own borders, but the criminals work across many
countries. The producers and distributors are in different countries, while arrests and seizures only happen
in the transit countries (the ones the drugs pass through) — so you never catch the whole network.
a. Need for coordinated, integrated and transnational responses! countries must work together across
borders — only coordinated, international cooperation can fight these networks.
MIDDLE LEVEL
This is a broad phenomenon with little research, so there's no clear, globally accepted definition.
- Possible definition 1: “Strategic link between wholesale and retail”
- Possible definition 2: Transaction volume (e.g. Cocaine → 1- 5 kg) , if you have less than 1 kg of cocaine, you are
at the retail level
So Roughly: middle level = the strategic link between wholesale and retail, where large amounts (e.g. 100 kg of cocaine
from wholesale) are cut and split into packages for different dealers (each 1–5 kg).
- This often happens in secret locations — empty houses, warehouses, garages, storage units.
o Inside these secret locations, there are different tasks (re-packers, distributors, cutters), often done by
family members because of the trust between relatives.
▪ Specific 1980s form: "deal houses" & "drug runners": ?
• Deal houses = houses with large amounts of drugs (possibly cut and split) that are also sold
directly via runners.
• Drug runners = people who wait, for example, at a highway gas station, for customers and
bring them to the deal house to get drugs. → The user goes to the dealer (demand goes to
supply).
o (Opposite = drug couriers in retail = dealers who bring the product to the
consumer → the dealer goes to the user.)
RETAIL LEVEL
The final step in the supply chain — drugs sold directly to end users by a dealer, usually in small amounts (1–5 g).
Three market types:
1. Open market — the dealer is accessible to anyone, but high risk.
2. Semi-open markets — the dealer is tied to a setting (selling in a bar or club).
o Variant: deal houses = semi-accessible (you can only get in through a drug runner). A place to buy
drugs that attracts many buyers (day and night), often associated with nuisance in the area. Deal
houses sit between middle trade and retail, but are becoming rarer today.
3. Closed markets — buyers and sellers only deal with each other if they know and trust each other, or via a
trusted third party.
o Why did this develop? (1) the risk of police action present in open markets, and (2) to guarantee
quality (open markets have no quality guarantee).
o Downside: sellers can't maximize profits because they have limited clients.
o A form of closed market: the "social network" market (friends selling to friends — only accessible if
you belong to the group/network).
4
,Dealers
- Make little profit, some dealers deal to finance their own drug use
- Most dealers work independently or in separate groups (of 2 or 3 people) without hierarchy
Cannabis retail market is estimated to be the largest, followed by the heroin retail market and the cocaine retail market
INNOVATION IN THE RETAIL MARKET
Retail has adapted strongly thanks to new technology and communication (internet, social media):
1. Delivery services — drug runners have evolved into drug couriers who deliver drugs to your home. These
exist alongside the traditional street dealer.
1. So now we have: (1) street dealers, (2) drug couriers.
2. Use of social media — apps like WhatsApp, Telegram, Snapchat are used to order or contact the dealer.
3. Online drug markets — (1) the dark net, (2) the clearnet (normal websites).
Product prices rise the closer it gets to the
consumer! So the closer you are to the
customer, the higher the price will be
Who makes the highest profits? People
investing in the production and
wholesale, because they move massive
quantities and control the whole
operation. (need to invested less money,
and get WAY more profit when it’s sold)
5
, NEW PSYCHOACTIVE SUBSTANCES (NPS)
1. WHAT IS NPS
NPS (New Psychoactive Substances) are slightly changed versions of illegal drugs. Drugs like MDMA, cocaine, or heroin have
a specific chemical structure. Producers change one or a few elements in that structure to create a new substance that:
- still gives the same effect as the original drug, but
- can no longer legally be called that drug (e.g. it mimics cocaine but isn't technically "cocaine", because they
changed the chemical formula). → So substances stay legal (also know as “legal high”)
o Examples of NPS: stimulant and hallucinogenic variants, but also dangerous synthetic opioids like
fentanyl and carfentanil.
Main goal = give the SAME EFFECT as “normal drugs”, but AVOID LEGISLATION!!!!
- Legislation in Europe, and in Belgium specifically, controls drugs by listing them by name (cocaine, cannabis,
MDMA, etc.). A substance is only illegal if it appears on that list.
o NPS exploit this system. They are designed to mimic the effects of a known drug (for example, cocaine),
but because their chemical formula has been slightly altered, the new substance can no longer be
classified as "cocaine." Since it isn't on the list of banned substances, it remains legal — which is why
these products became known as "legal highs."
- To counter this, the legislation has to be updated. In Belgium, this was done by criminalizing the chemical formula
itself (NO longer the NAME), so that all chemical variants of a drug are banned as well, not just the originally
named substance.
WHY NPS ARE A PROBLEM
- They're often made in commercial labs (e.g. in Asia) and are usually cheaper than normal illegal drugs.
- They're very profitable (e.g. synthetic cannabinoids have about the same THC level but a much higher profit margin).
- Sold through specialized shops, street dealers, and online markets (clearnet
and dark net "cryptomarkets").
- Public health danger: they can be very strong (high potency), easy to buy
online, and sometimes get mixed into the normal street drug supply — for
example, heroin secretly cut with fentanyl. Users don't know what they're
really taking
o Fentanyl: 50 times more potent than heroin
o Carfentanil: 100 times more potent than fentanyl
▪ In the picture you can see the amount that is needed for
a potential overdose
2. NPS IN BELGIUM
In Belgium we see a rather big increase in NPS (new drugs) found in
Belgium, between 2014-2017, there were about 90-120 NEW NPS detected
per year. However, this has dropped in 2018 to 50 NPS.
EARLY WARNING SYSTEM
In 2017, Belgium's Early Warning System reported a death caused by an
NPS (3-MeO-PCP). Key points:
• The victims were not regular drug users — they were experimenting
with substances bought online.
• There was mislabeling — people didn't get the substance they thought
they ordered, so they took a much bigger dose than intended, leading
to overdose and death.
6
,LEGISLATIVE
The basic Belgian drug law (basis wet = framework) dates from 1921, and it's been updated several times over the
years (adding psychotropic substances in 1975, precursors in 2003 substances which may be used for the illicit
manufacture of narcotic drugs and psychotropic substances.) and detailed (specific lists and rules are written) through
"Royal Decrees." (koninklijke besluiten) International UN conventions (1961 for narcotics, 1971 for psychotropic
substances) also feed into it.
Over the years, more and more NPS were added to the banned lists (with names) — and importantly, this was done
retroactively (they add substances ones they been detected, and this is NOT an efficient way of working):
- 1999–2010: a handful of substances
- 2011: 30 substances
- 2013: 15 substances
- 2015: more than 90 substances
The big breakthrough came in 2014 (Royal Decree): The basic law of 1921 was amended (changed) again, which made
a “generic legislation" possible. Instead of banning one specific substance at a time, the law can now ban a whole
group of substances based on their shared chemical structure.
- Generic classification is a legal strategy used to control New Psychoactive Substances (NPS). ?
o Methode? Instead of banning one specific drug, the law bans a whole group of drugs that have a
similar chemical structure.
o Why this is needed? NPS are often slightly changed versions of illegal drugs. Producers change one
small part of the molecule, and suddenly it becomes a new substance that is not yet illegal. If the
law bans drugs one by one, producers can easily stay ahead.
A new Royal Decree in 2017 put this into practice, regulating substances by their structure (e.g. all variants of
amphetamine, cathinone, fentanyl, synthetic cannabinoids, etc.).
- Generic classification based on common basic chemical structure — pros and cons
o Advantages: bans many substances at once and is proactive (it can catch variants before they
appear).
o Disadvantages: it's hard to interpret, and it still needs occasional updates (some new NPS opioids,
like isotonitazene, still slip through).
7
,H2: DRUG POLICY & DRUG-RELATED CHALLENGES IN THE EU
INTRODUCTION DRUG POLICY (COLMAN)
1. DRUG POLICY VERSUS DRUG LAW
In Belgium, and other countries, we make a clear distinction between drug policy and drug law
- (1) Drug policy = is the general strategy or approach a government uses to deal with drugs. It includes the goals,
priorities, and ideas behind how drugs should be handled in society.
o Examples of what drug policy can focus on:
▪ Prevention (educating people about drugs)
▪ Treatment for people with Substance Use Disorder
▪ Harm reduction (e.g., safe use programs, syringe exchange )
▪ Law enforcement against trafficking
o So drug policy = the overall plan or vision.
▪ Example: A country might decide its policy should focus more on public health rather than
punishment. In Belgium the main starting point is public health
- (2) Drug law = is the specific legal rules or criminal provision that enforce the drug policy.
o These are the actual laws written in legislation that say:
▪ Which drugs are illegal
▪ What penalties exist for possession, use, or trafficking
▪ How substances like New Psychoactive Substances (NPS) are controlled
o So drug law = the concrete legal rules to implement the drug policy (these are part of the drug policy)
▪ Example: A law might state that possessing a certain drug can lead to a fine or prison sentence.
2. BELGIUM AS A CASE STUDY
The Belgian Drug Policy is rather YOUNG, it was mostly developed in the 1990s. It includes alcohol, tobacco, psychoactive
medication, illicit drugs + gambling and gaming (since 2016). So our Belgian drug policy does NOT only include illicit/illegal
drugs, but also tabacco, alcohol, gambling and gaming.
- Belgian drug policy is often described as "integral and integrated." These two words mean different things:
o Integral (allesomvattend) = it covers both sides of the drug problem
▪ Drug demand — the user's side: why and how people use drugs.
▪ Drug supply — the criminal/market side: how drugs are produced, supplied, and sold.
o Integrated (één geheel) = it combines different policy domain and government levels
▪ The policy brings together all the different approaches to drugs into one connected strategy:
• Prevention — stopping use before it starts.
• Harm reduction — reducing the damage for people who do use.
• Treatment/recovery — helping people with addiction get better.
• Repression — enforcement and punishment (police, justice).
▪ It also means all levels of government work together — ministers at both the regional and
federal levels. Because Belgium has this layered government structure, the policy is called
"interfederal" (cooperation across the different government levels).
• Since 23 ministers across Belgium can be linked to a domain where drugs have an
impact, there is a need for coordination and alignment. (Justice, Home Affairs, Health,
welfare, education…)
INTERFEDERAL, INTEGRAL & INTEGRATED DRUG POLICY = NEED FOR COOPERATION
The Interfederal, integral and integrated drug policy requires cooperation. There are more than 20 ministers involved
in making drug policy, spread across the national level (federal and regional). These ministers are responsible for
different domains that drugs have an impact on — like health, justice, welfare, education… That's why coordination is
needed, but it's not simple.
8
, To make that coordination possible in belgium, there are three things:
- (1) The General Drug Policy Cell (since 2008/2010): this includes representatives from all administrations and
cabinets (the political side). It ensures cooperation and alignment across the different levels and domains. In total
it has 55 members (ministers + cabinets + experts) and they meet ones a month
- (2) The Interfederal Drug Coordinator: one person responsible for the day-to-day coordination of Belgium's drug
policy (independent + a link between everyone, but doesn't make decisions themselves). This person also chairs
the Cell. The three coordinators so far:
o 2010–2017: Brice De Ruyver
o 2018–2022: Etienne De Groot
o Since 2022: Charlotte Colman (Professor)
▪ Several other European member state have their own NATIONAL drug Coordinator, and twice a
year there's a meeting between the national drug coordinators (at EU level).
- (3) The Quid National Drug Commissioner — Ine Van Wymersch (since 2023): This commissioner is responsible
for everything that is related to illicit drugs supply, so focuses on ILLEGAL DRUG PRODUCTION on the federal
level.
o This is not the came as the interfederal drug coordinator, they are responsbile for all substances and
behaviours in the drug policy from prevention to repression.
▪ But they actually work well together
DIFFERENT APPROACHES TO SUPPLY AND DEMAND
Belgian drug policy treats drug demand (the users' side) and drug supply (the producers'/dealers' side) very differently. Each
gets its own approach.
- (1) Demand (user)
o The starting point: public health For drug demand — and for the general drug policy as a whole — the
foundation is public health, not punishment. Drug use is seen first as a health issue.
o Punishment = Ultimum remedium (last resort for people who use drugs) help first, punishment last The
approach follows a clear order of priority:
▪ (1) Prevention (first) — stopping use before it starts.
▪ (2) Treatment / care / recovery — helping people who use.
▪ (3) Repression / punishment (last) — this is the ultimum remedium, Latin for "last resort."
Punishing users is only a final option when nothing else works.
o Diversion to treatment There's also the option to divert people who use drugs problematically (meaning
their use causes problems in other areas of their life) away from the justice system and toward
treatment. At every stage of the criminal justice process, such a person can be referred to treatment
instead of being prosecuted in the normal way.
▪ (!!!!) Importantly, this is voluntary — the person has a choice.
- (2) Supply (the producers'/dealers' side):
o Repression and punishment: Here the approach is repressive — focused on enforcement and
punishment. But it's targeted: the focus is on the criminals who produce and supply drugs for profit,
especially on hitting their financial gain through a "follow the money" strategy.
▪ (!!!) The aim is the big players, NOT people who sell small amounts just to fund their own drug use.
IMPORTANT DOCUMENT
2001 Federal Drug Note (Federale drugsnota): this was the FIRST comprehensive drugs policy document in Belgium,
- with 3 pillars
o Pillar 1: Prevention — for non-users and recreational (non-problematic) users
o Pillar 2: Care, harm reduction & (re)integration — for problematic users
o Pillar 3: Repression (punishment) — for producers and dealers
- 2 crucial principles: (1) Integral & (2) Integrated
9
Samenvatting
Joren Brauwers
Academiejaar 2025-2026
, PARTIM COLMAN
H1: EXPLAINING THE BASIC
ILLICIT DRUGS MARKET
1. INTRODUCTION
WHAT IS DRUGS POLICY ?
By "drug policy" we mean all the rules, laws and plans a government makes to deal with drugs. It's about how drugs are
used, made and sold, and about the consequences of that — for both legal drugs (like alcohol) and illegal drugs. There are
different ways a drug policy handles this:
- Prevention: Informing people so they don't start using drugs, for example through education at schools.
- Support (treatment): Helping people with an addiction through medical and psychological support.
- Enforcement: Checking and punishing when people sell, make or possess drugs.
- Regulation: Setting the conditions under which certain drugs (like alcohol, tobacco or medical cannabis) are allowed to
be legally sold and used.
- Harm reduction: Measures to reduce the damage from drug use, such as handing out free clean needles or opening safe
drug-use rooms.
In short, it covers things like:
- What's allowed — which substances are legal, banned, or available only by prescription.
- Punishment vs. help — whether people who use or sell drugs get arrested and punished, or get treatment and support.
- Reducing harm — measures meant to keep people safer, like clean needle programs, overdose medication, or drug-
checking services.
- Prevention and education — efforts to stop problems before they start, like school programs or public health campaigns.
Different countries take very different approaches. Some focus on strict bans and criminal penalties (often called the "war
on drugs"), while others lean toward treating drug use as a health issue rather than a crime
DRUGS MARKET
The illicit drugs market (buying and selling of drugs) IS THE LARGEST CRIMINAL MARKET IN THE EUROPEAN UNION
- >1/3 EU organized crime groups are involved: production, traffic, and smuggling of illicit drugs, more than 1/3 of all EU
organized criminal groups are involved in the illicit drug market
- Large profits involved The EU drug market (at retail level) is worth at least €24 billion per year. Making money is the
main reason these groups do it.
LINK BETWEEN ILLICIT DRUG ECONOMY AND LEGAL ECONOMY
Undermining crime by drug crime means the way organized criminal groups gain influence over society, the economy, and the
government by mixing their criminal activities into legal structures. So Infiltration of organized crime into political, socio-economic
and financial power So the illegal world and the legal world become intertwined (connected and tangled together).
- Corruption or infiltration in local government Criminal networks try to influence local authorities by bribing officials or
placing their own people in government jobs. This lets them get inside information and, for example, obtain permits for
buildings that are secretly used to produce or sell drugs.
- Money laundering (washing illegal money) Criminals use legal businesses (like a hairdresser, restaurant, or real estate)
to make their illegal money look like it came from a legitimate source. 44% of profits re-invested in the legal economy of
Europe by money laundering (EMCDDA, 2016)
o Possible solution: if a local government suspects a building is used for illegal activities, they can take it away —
but of course, corruption can get in the way (point 1)
- Infiltration into legal sectors Criminal groups expand into legal industries like real estate, hospitality (bars/restaurants),
or transport. This lets them hide their crimes behind a normal-looking business. Criminals often intertwine with legal
businesses, so there is sometimes a connection between the UPPERWORLD (legal business) and the UNDERWORLD
(criminals)…. They use legal business to hide their activities, launder money,….
o Problem: unfair competition, because these criminal networks have a huge amount of money compared to
honest businesses.
1
,DIFFERENCES IN ORGANIZATIONAL STRUCTURES
There are two main ways criminal drug organizations are structured:
- Pyramid structure: This is a hierarchy, like a triangle. There's a boss at the top, and orders flow down through
different levels to the people at the bottom. Everyone knows their place, and power is clearly organized from
top to bottom. So there is clear leaderships and a clear distribution of tasks
- Flexible partnerships (cell-based structure): Instead of one big chain of command (top-down), the work is
split into separate "cells." Each cell has its own job/expertise and doesn't know what the other cells are
doing — or even who they are. So decentralized (not one boss at the centre making all the decision),
fragmented (divided in cells), and situational (can adapt if necessary)
o Example: large-scale cannabis production
▪ Cell 1: builds the plantation
▪ Cell 2: maintains the plantation
▪ …
▪ They don't know each other.
o Why use cells? Safety. If one cell gets caught by the police, its members can't reveal the others,
because they don't know them. This protects the whole organization.
DRUG MARKETS ARE ADAPTIVE AND RESILIENT
The drug markets are adaptive and resilient, meaning they keep going and keep the connection between producers and
buyers alive, even when there's pressure from outside (like police crackdowns) by altering the modus operandi (they way
they do certain things,…), or find different alternative to keep the profit-level the same (making money is their #1 goal and
priority and they will do everything the keep it that way
- They learn from legal businesses (organization, innovation): Illegal drug markets often copy legal companies and
use successful business models.
o (1) Seizing opportunities and innovations — for example, online drug markets (cryptomarket, when the
police shuts one down, they just move to another one)
o (2) The role of globalization — just like normal companies make their business more efficient by building
foreign contacts, drug markets do the same to keep transport efficient.
o (3) The difference from the legal market — illegal markets are NOT bound by rules and have plenty of
money.
- One of the main reasons drug markets are adaptive and resilient is that they change their "modus operandi"
(their way of operating): (!!!!)
o Example: clever use of national borders — cooperation between the Netherlands and Belgium. Activities
are split between countries, which makes them much harder to link together and harder for authorities
to stop, because different countries are involved.
▪ Production = Belgium
▪ Waste = Netherlands
o Example: fewer cocaine seizures at the Port of Antwerp because of innovative methods — this is actually
NOT a good sign, because we know Antwerp is still used as a channel for drug trade. So criminals are using
innovative methods: instead of hiding cocaine in containers with bananas, they now put it, for example,
in the fabric of clothes (clothes with cocaine in them), and the cocaine is later extracted from the clothes
in a "cocaine laundry."
▪ The modus operandi has simply changed, but the same amount is still coming in — we just
haven't found it, because we focus too much on the traditional methods.
2. 4 LEVELS OF THE DRUG SUPPLY MARKET
The supply chain is the path every product follows, from production to consumption. It has 4 levels (echelons):
1. Production — e.g. cocaine made in Colombia
2. Wholesale — e.g. exporting large amounts to Europe (100 kg)
3. Middle trade (intermediate) — e.g. "cutting" the drugs and splitting them into 5 kg packages for different dealers.
o "Cutting" = mixing pure drugs with other substances to increase the quantity. This means more packages
can be sold (less pure), so profit goes up.
4. Retail — each dealer splits it into user-sized amounts (1–5 g) and sells to users.
2
,PRODUCTION
Regarding the production or manufacturing of drugs, we can make a distinction between different drugs and the country
who are the main producers:
- Synthetic drugs (made in a labo): Europe
o MDMA (XTC) & amphetamines: mainly produced in Belgium, Netherlands, Germany, and Bulgaria. Belgium
and the Netherlands are world-famous for this (their "top products").
o Methamphetamine: mainly the Czech Republic, increasingly the Netherlands (possible future for Belgium
through cooperation with the Netherlands).
- Cocaine: Latin America
o Main producers: Colombia = 70% of world production, Peru = 20%, Bolivia = 10%.
▪ New trends in Europe: the final production steps (turning cocaine paste into powder) now happen
in Europe too. Paste is delivered (harder to detect) and turned into powder in European labs. Also
"cocaine laundries" extract cocaine from the fabric of clothes
- Cannabis: a worldwide phenomenon — 159 countries report producing it.
o Hash (2010–2015): mainly Morocco, Afghanistan, Lebanon, India & Pakistan (but also local).
o Marijuana (2010–2015): produced locally.
- Opium: Afghanistan + Myanmar + Mexico = about 96% of world production
o Afghanistan – the "Golden Crescent" (with Pakistan & Iran): biggest opium producer (86%) and main heroin
supplier to Europe.
▪ Today: the Taliban opium ban has reduced production, so there's much less heroin on the EU market.
▪ Result: since people still use, they look for alternatives — synthetic opioids (like fentanyl).
• Danger: these synthetics are much stronger → risk of overdose.
• But NOT really the case in Belgium — no shift to synthetic opioids there.
o Myanmar – the "Golden Triangle" (with Laos & Thailand): about 5% of opium, mainly for Asia
o Mexico: another important supplier, mainly to the US.
WHOLESALE
This is about importing and exporting large amounts of drugs via various transport methods:
- Airports (small and large), often via private planes (less control)
o Through air cargo or postal packages (DHL, TNT, FedEx)
o Through an insider in the airport sector
o Through passengers — in luggage, or in/on the body ("body packers" who swallow capsules)
- Seaports (large and small)
o Hidden in a full container (or in its structure/walls)
o Hidden in legal cargo (empty containers)
o Hidden on the ship (e.g. in the command room)
o "Drop-off" = moving drug loads from big ships to smaller boats (speedboats, fishing boats)
o Hidden under the ship (collected by divers)
- Over land — via railways and roads
3
, Belgium is a strategic transit country (country where the drugs come in and are distributed across Europe) for
international drug trade because of:
1. Central location in Europe — an ideal hub to distribute drugs to neighbors (France, Germany, Netherlands, UK),
thanks to Schengen (open borders).
2. Access to several seaports — e.g. the Port of Antwerp, one of the world's largest, a major entry point for cocaine
hidden in containers.
3. International airports — e.g. Zaventem (Brussels) and Charleroi, attractive entry points for couriers and air
freight/postal packages.
4. Extensive road and rail network — allows fast distribution to other European countries.
PROBLEMS WITH TACKLING WHOLESALE
(1) Modus operandi changes — The criminals' "way of operating" keeps changing depending on the timing,
place, and the situation (for example, dodging stricter laws or more police checks in one area by switching
methods or routes)
(2) Jurisdiction: each country's police can only act within its own borders, but the criminals work across many
countries. The producers and distributors are in different countries, while arrests and seizures only happen
in the transit countries (the ones the drugs pass through) — so you never catch the whole network.
a. Need for coordinated, integrated and transnational responses! countries must work together across
borders — only coordinated, international cooperation can fight these networks.
MIDDLE LEVEL
This is a broad phenomenon with little research, so there's no clear, globally accepted definition.
- Possible definition 1: “Strategic link between wholesale and retail”
- Possible definition 2: Transaction volume (e.g. Cocaine → 1- 5 kg) , if you have less than 1 kg of cocaine, you are
at the retail level
So Roughly: middle level = the strategic link between wholesale and retail, where large amounts (e.g. 100 kg of cocaine
from wholesale) are cut and split into packages for different dealers (each 1–5 kg).
- This often happens in secret locations — empty houses, warehouses, garages, storage units.
o Inside these secret locations, there are different tasks (re-packers, distributors, cutters), often done by
family members because of the trust between relatives.
▪ Specific 1980s form: "deal houses" & "drug runners": ?
• Deal houses = houses with large amounts of drugs (possibly cut and split) that are also sold
directly via runners.
• Drug runners = people who wait, for example, at a highway gas station, for customers and
bring them to the deal house to get drugs. → The user goes to the dealer (demand goes to
supply).
o (Opposite = drug couriers in retail = dealers who bring the product to the
consumer → the dealer goes to the user.)
RETAIL LEVEL
The final step in the supply chain — drugs sold directly to end users by a dealer, usually in small amounts (1–5 g).
Three market types:
1. Open market — the dealer is accessible to anyone, but high risk.
2. Semi-open markets — the dealer is tied to a setting (selling in a bar or club).
o Variant: deal houses = semi-accessible (you can only get in through a drug runner). A place to buy
drugs that attracts many buyers (day and night), often associated with nuisance in the area. Deal
houses sit between middle trade and retail, but are becoming rarer today.
3. Closed markets — buyers and sellers only deal with each other if they know and trust each other, or via a
trusted third party.
o Why did this develop? (1) the risk of police action present in open markets, and (2) to guarantee
quality (open markets have no quality guarantee).
o Downside: sellers can't maximize profits because they have limited clients.
o A form of closed market: the "social network" market (friends selling to friends — only accessible if
you belong to the group/network).
4
,Dealers
- Make little profit, some dealers deal to finance their own drug use
- Most dealers work independently or in separate groups (of 2 or 3 people) without hierarchy
Cannabis retail market is estimated to be the largest, followed by the heroin retail market and the cocaine retail market
INNOVATION IN THE RETAIL MARKET
Retail has adapted strongly thanks to new technology and communication (internet, social media):
1. Delivery services — drug runners have evolved into drug couriers who deliver drugs to your home. These
exist alongside the traditional street dealer.
1. So now we have: (1) street dealers, (2) drug couriers.
2. Use of social media — apps like WhatsApp, Telegram, Snapchat are used to order or contact the dealer.
3. Online drug markets — (1) the dark net, (2) the clearnet (normal websites).
Product prices rise the closer it gets to the
consumer! So the closer you are to the
customer, the higher the price will be
Who makes the highest profits? People
investing in the production and
wholesale, because they move massive
quantities and control the whole
operation. (need to invested less money,
and get WAY more profit when it’s sold)
5
, NEW PSYCHOACTIVE SUBSTANCES (NPS)
1. WHAT IS NPS
NPS (New Psychoactive Substances) are slightly changed versions of illegal drugs. Drugs like MDMA, cocaine, or heroin have
a specific chemical structure. Producers change one or a few elements in that structure to create a new substance that:
- still gives the same effect as the original drug, but
- can no longer legally be called that drug (e.g. it mimics cocaine but isn't technically "cocaine", because they
changed the chemical formula). → So substances stay legal (also know as “legal high”)
o Examples of NPS: stimulant and hallucinogenic variants, but also dangerous synthetic opioids like
fentanyl and carfentanil.
Main goal = give the SAME EFFECT as “normal drugs”, but AVOID LEGISLATION!!!!
- Legislation in Europe, and in Belgium specifically, controls drugs by listing them by name (cocaine, cannabis,
MDMA, etc.). A substance is only illegal if it appears on that list.
o NPS exploit this system. They are designed to mimic the effects of a known drug (for example, cocaine),
but because their chemical formula has been slightly altered, the new substance can no longer be
classified as "cocaine." Since it isn't on the list of banned substances, it remains legal — which is why
these products became known as "legal highs."
- To counter this, the legislation has to be updated. In Belgium, this was done by criminalizing the chemical formula
itself (NO longer the NAME), so that all chemical variants of a drug are banned as well, not just the originally
named substance.
WHY NPS ARE A PROBLEM
- They're often made in commercial labs (e.g. in Asia) and are usually cheaper than normal illegal drugs.
- They're very profitable (e.g. synthetic cannabinoids have about the same THC level but a much higher profit margin).
- Sold through specialized shops, street dealers, and online markets (clearnet
and dark net "cryptomarkets").
- Public health danger: they can be very strong (high potency), easy to buy
online, and sometimes get mixed into the normal street drug supply — for
example, heroin secretly cut with fentanyl. Users don't know what they're
really taking
o Fentanyl: 50 times more potent than heroin
o Carfentanil: 100 times more potent than fentanyl
▪ In the picture you can see the amount that is needed for
a potential overdose
2. NPS IN BELGIUM
In Belgium we see a rather big increase in NPS (new drugs) found in
Belgium, between 2014-2017, there were about 90-120 NEW NPS detected
per year. However, this has dropped in 2018 to 50 NPS.
EARLY WARNING SYSTEM
In 2017, Belgium's Early Warning System reported a death caused by an
NPS (3-MeO-PCP). Key points:
• The victims were not regular drug users — they were experimenting
with substances bought online.
• There was mislabeling — people didn't get the substance they thought
they ordered, so they took a much bigger dose than intended, leading
to overdose and death.
6
,LEGISLATIVE
The basic Belgian drug law (basis wet = framework) dates from 1921, and it's been updated several times over the
years (adding psychotropic substances in 1975, precursors in 2003 substances which may be used for the illicit
manufacture of narcotic drugs and psychotropic substances.) and detailed (specific lists and rules are written) through
"Royal Decrees." (koninklijke besluiten) International UN conventions (1961 for narcotics, 1971 for psychotropic
substances) also feed into it.
Over the years, more and more NPS were added to the banned lists (with names) — and importantly, this was done
retroactively (they add substances ones they been detected, and this is NOT an efficient way of working):
- 1999–2010: a handful of substances
- 2011: 30 substances
- 2013: 15 substances
- 2015: more than 90 substances
The big breakthrough came in 2014 (Royal Decree): The basic law of 1921 was amended (changed) again, which made
a “generic legislation" possible. Instead of banning one specific substance at a time, the law can now ban a whole
group of substances based on their shared chemical structure.
- Generic classification is a legal strategy used to control New Psychoactive Substances (NPS). ?
o Methode? Instead of banning one specific drug, the law bans a whole group of drugs that have a
similar chemical structure.
o Why this is needed? NPS are often slightly changed versions of illegal drugs. Producers change one
small part of the molecule, and suddenly it becomes a new substance that is not yet illegal. If the
law bans drugs one by one, producers can easily stay ahead.
A new Royal Decree in 2017 put this into practice, regulating substances by their structure (e.g. all variants of
amphetamine, cathinone, fentanyl, synthetic cannabinoids, etc.).
- Generic classification based on common basic chemical structure — pros and cons
o Advantages: bans many substances at once and is proactive (it can catch variants before they
appear).
o Disadvantages: it's hard to interpret, and it still needs occasional updates (some new NPS opioids,
like isotonitazene, still slip through).
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,H2: DRUG POLICY & DRUG-RELATED CHALLENGES IN THE EU
INTRODUCTION DRUG POLICY (COLMAN)
1. DRUG POLICY VERSUS DRUG LAW
In Belgium, and other countries, we make a clear distinction between drug policy and drug law
- (1) Drug policy = is the general strategy or approach a government uses to deal with drugs. It includes the goals,
priorities, and ideas behind how drugs should be handled in society.
o Examples of what drug policy can focus on:
▪ Prevention (educating people about drugs)
▪ Treatment for people with Substance Use Disorder
▪ Harm reduction (e.g., safe use programs, syringe exchange )
▪ Law enforcement against trafficking
o So drug policy = the overall plan or vision.
▪ Example: A country might decide its policy should focus more on public health rather than
punishment. In Belgium the main starting point is public health
- (2) Drug law = is the specific legal rules or criminal provision that enforce the drug policy.
o These are the actual laws written in legislation that say:
▪ Which drugs are illegal
▪ What penalties exist for possession, use, or trafficking
▪ How substances like New Psychoactive Substances (NPS) are controlled
o So drug law = the concrete legal rules to implement the drug policy (these are part of the drug policy)
▪ Example: A law might state that possessing a certain drug can lead to a fine or prison sentence.
2. BELGIUM AS A CASE STUDY
The Belgian Drug Policy is rather YOUNG, it was mostly developed in the 1990s. It includes alcohol, tobacco, psychoactive
medication, illicit drugs + gambling and gaming (since 2016). So our Belgian drug policy does NOT only include illicit/illegal
drugs, but also tabacco, alcohol, gambling and gaming.
- Belgian drug policy is often described as "integral and integrated." These two words mean different things:
o Integral (allesomvattend) = it covers both sides of the drug problem
▪ Drug demand — the user's side: why and how people use drugs.
▪ Drug supply — the criminal/market side: how drugs are produced, supplied, and sold.
o Integrated (één geheel) = it combines different policy domain and government levels
▪ The policy brings together all the different approaches to drugs into one connected strategy:
• Prevention — stopping use before it starts.
• Harm reduction — reducing the damage for people who do use.
• Treatment/recovery — helping people with addiction get better.
• Repression — enforcement and punishment (police, justice).
▪ It also means all levels of government work together — ministers at both the regional and
federal levels. Because Belgium has this layered government structure, the policy is called
"interfederal" (cooperation across the different government levels).
• Since 23 ministers across Belgium can be linked to a domain where drugs have an
impact, there is a need for coordination and alignment. (Justice, Home Affairs, Health,
welfare, education…)
INTERFEDERAL, INTEGRAL & INTEGRATED DRUG POLICY = NEED FOR COOPERATION
The Interfederal, integral and integrated drug policy requires cooperation. There are more than 20 ministers involved
in making drug policy, spread across the national level (federal and regional). These ministers are responsible for
different domains that drugs have an impact on — like health, justice, welfare, education… That's why coordination is
needed, but it's not simple.
8
, To make that coordination possible in belgium, there are three things:
- (1) The General Drug Policy Cell (since 2008/2010): this includes representatives from all administrations and
cabinets (the political side). It ensures cooperation and alignment across the different levels and domains. In total
it has 55 members (ministers + cabinets + experts) and they meet ones a month
- (2) The Interfederal Drug Coordinator: one person responsible for the day-to-day coordination of Belgium's drug
policy (independent + a link between everyone, but doesn't make decisions themselves). This person also chairs
the Cell. The three coordinators so far:
o 2010–2017: Brice De Ruyver
o 2018–2022: Etienne De Groot
o Since 2022: Charlotte Colman (Professor)
▪ Several other European member state have their own NATIONAL drug Coordinator, and twice a
year there's a meeting between the national drug coordinators (at EU level).
- (3) The Quid National Drug Commissioner — Ine Van Wymersch (since 2023): This commissioner is responsible
for everything that is related to illicit drugs supply, so focuses on ILLEGAL DRUG PRODUCTION on the federal
level.
o This is not the came as the interfederal drug coordinator, they are responsbile for all substances and
behaviours in the drug policy from prevention to repression.
▪ But they actually work well together
DIFFERENT APPROACHES TO SUPPLY AND DEMAND
Belgian drug policy treats drug demand (the users' side) and drug supply (the producers'/dealers' side) very differently. Each
gets its own approach.
- (1) Demand (user)
o The starting point: public health For drug demand — and for the general drug policy as a whole — the
foundation is public health, not punishment. Drug use is seen first as a health issue.
o Punishment = Ultimum remedium (last resort for people who use drugs) help first, punishment last The
approach follows a clear order of priority:
▪ (1) Prevention (first) — stopping use before it starts.
▪ (2) Treatment / care / recovery — helping people who use.
▪ (3) Repression / punishment (last) — this is the ultimum remedium, Latin for "last resort."
Punishing users is only a final option when nothing else works.
o Diversion to treatment There's also the option to divert people who use drugs problematically (meaning
their use causes problems in other areas of their life) away from the justice system and toward
treatment. At every stage of the criminal justice process, such a person can be referred to treatment
instead of being prosecuted in the normal way.
▪ (!!!!) Importantly, this is voluntary — the person has a choice.
- (2) Supply (the producers'/dealers' side):
o Repression and punishment: Here the approach is repressive — focused on enforcement and
punishment. But it's targeted: the focus is on the criminals who produce and supply drugs for profit,
especially on hitting their financial gain through a "follow the money" strategy.
▪ (!!!) The aim is the big players, NOT people who sell small amounts just to fund their own drug use.
IMPORTANT DOCUMENT
2001 Federal Drug Note (Federale drugsnota): this was the FIRST comprehensive drugs policy document in Belgium,
- with 3 pillars
o Pillar 1: Prevention — for non-users and recreational (non-problematic) users
o Pillar 2: Care, harm reduction & (re)integration — for problematic users
o Pillar 3: Repression (punishment) — for producers and dealers
- 2 crucial principles: (1) Integral & (2) Integrated
9
