Good question. There are clearly some differences, and they may be crucial: in particular, I gather that they've largely decriminalized it (which changes a lot of economic incentives), and I believe they're actually prescribing controlled amounts of heroin in some cases. (I'm seeing one or two reports around the Net that seem to indicate that this works better than methadone for helping addicts get their lives together.) But I can't say I know what they've done in any depth.

It would be useful to understand the differences better, since it seems to be working better there, and I suspect that the details matter...