A batch of cannabis can leave Thailand for a regulated overseas market only when four things refer to the same lot number: four quality standards, one named person’s release decision and two government permits. A signed contract with a buyer does not, on its own, allow anything to cross a border.
This guide follows that chain in order. Part 1 covers the four standards, the release decision and the permits. Part 2 covers:
- what Germany, the Czech Republic and Australia require
- the document pack
- microbial and shelf-life testing
- contracts and common failures
- Thai export licensing
Some requirements were confirmed from the regulator’s own text or the guideline itself, and the article says so. Others could not be confirmed, and the article says that too. Get those answers in writing from the regulator before you plan around them.
1. Four standards along the route, and one law above them
A batch (or lot) is an amount of plant material that was grown and processed under the same conditions. It keeps one number from the field to the buyer.
Four standards each cover one stretch of the journey. Narcotics control law applies on top of all four. Primary processing is the first handling of the harvested crop. It sits on the boundary between farm and factory, so manufacturing rules may already apply to it.
| Step | Standard that governs it | The question an auditor asks |
|---|---|---|
| Seed, soil, crop protection, harvest | Good agricultural and collection practice (GACP): the quality standard for growing and harvesting medicinal plants | Is the plant identified, traceable and free of contamination? |
| Manufacture, packaging, labelling, testing | Good manufacturing practice (GMP): the quality system for making medicines | Can you prove this batch is the same as the last one? |
| Certification and release | The release step inside GMP | Does one named person state that this batch complies? |
| Storage, transport, wholesale movement | Good distribution practice (GDP): the quality rules for storing and moving medicines | Did the batch stay intact and traceable? |
| Crossing the border | Narcotics control law, which applies on top of all the above | Have both governments authorised this shipment? |
What to do: Copy this table for your farm. Next to each step, write who is responsible today and which records you already keep. Each empty box marks a step where you are not ready to export yet.
2. The farm standard: from field to dried flower
The European Medicines Agency (EMA) is the medicines regulator of the European Union. It publishes a guideline on GACP, which sets quality standards for obtaining plants used in medicines. These requirements are confirmed from that guideline:
- Seed identity. Each seed lot is identified by genus, species, variety and origin.
- Soil. Free of sludge, heavy metals and residues.
- Pesticides. Avoid them as far as possible. If one cannot be avoided, use only an approved product at the lowest effective level. Qualified staff apply it. A defined waiting period separates the last application from harvest.
- Harvest and drying. Harvest in dry conditions. Record the drying conditions.
- Records. Location, harvest date and quantity, every chemical used, and the previous crops on that land.
- Batch numbers. A separate batch number for each growing condition.
The batch-number rule has a practical purpose. Two greenhouses run under different conditions become two batches. If one fails a test, the other can still go ahead.
Translator’s note: Many growers in Thailand start from seeds or clones that have no paperwork. Clones bought from another farm can also bring in pests, hop latent viroid (HLVd) or the wrong variety. Keep the seed packet, the invoice and a mother-plant log for every lot. This lets you prove where each lot came from when an auditor asks.
Translator’s note: In Thailand, use only pesticides registered with the Department of Agriculture (กรมวิชาการเกษตร), and use them only as the label says. The forum topic on what you may legally spray under Thai GACP explains how this works. A product that is legal in Thailand can still leave a pesticide residue that the destination laboratory rejects. Part 2 covers this.
Translator’s note: “Harvest dry and record drying conditions” is hardest in the Thai rainy season. Days run at 30–35 °C and the air stays humid. Wet flower that dries slowly gives mould more time to grow. Harvest on days when the plants are dry, and dry in a closed room with air conditioning and a dehumidifier, as described in drying at 85–95% ambient humidity.
Translator’s note: Log temperature and humidity in the drying room with a data logger. If the power fails, write down when it went off, when it came back and the readings. An auditor expects this kind of record for every deviation (a departure from your planned process).
What to do: Open a one-page batch record for your next crop before you plant. Use these columns:
- seed lot and origin
- location
- every input, with date and rate
- harvest date and wet weight
- daily drying temperature and humidity
- dry weight
Fill it in on the day you do the work. Every document an export buyer asks for later starts from this sheet.
3. Manufacturing practice (GMP) and its certificate
Who issues the certificate
A GMP certificate comes from a government regulator. Consultants and laboratories cannot issue one. The reference material names three examples:
- the United States Food and Drug Administration (FDA)
- the national medicines agencies of European Union countries
- the Therapeutic Goods Administration (TGA) in Australia
The World Health Organization (WHO) also has a version of GMP, which is used in more than 100 countries.
In Europe, the GMP rules are collected in EudraLex Volume 4. Its Part I runs from the quality system through to self-inspection. Its Annex 7 covers herbal medicinal products.
The most important rule is about records. Records must show that every defined step was carried out. They must be kept so that the full history of a batch can be traced.
What the certificate says
The exact legal wording of a GMP certificate is not confirmed here. What follows is the general industry understanding, so confirm it with your authority. A certificate records the result of an inspection at one point in time. It covers a named site and named activities. It describes a facility, not a product.
What an inspection involves
Inspections may be unannounced. What follows is general industry practice, not a confirmed procedure. The inspector walks through the premises and compares them with the documented layout. The inspector checks a sample of batch records to see whether they were filled in when the work was done, not afterwards. The inspector also interviews the operators.
Timelines: one confirmed, the rest not
This article could not confirm three GMP timelines: how often inspections happen, how long a certificate stays valid and how long processing takes. Do not plan around a number you have not received in writing.
One time period is confirmed, and it belongs to GACP. Tilleke & Gibbins is a law firm that publishes legal guides on Thailand. According to its 2025 Cannabis and Hemp Business Guide for Thailand, a GACP certificate for a cultivation site is valid for one to three years, with a surveillance inspection (a follow-up check) every year.
Translator’s note: This article could not confirm which Thai authority, if any, would inspect your drying, trimming and packing rooms against GMP. It also could not confirm whether an EU importer would accept that certificate. Ask the buyer and the Thai authorities early, and get the answer in writing. For GACP, inspectors from the Department of Thai Traditional and Alternative Medicine (กรมการแพทย์แผนไทยและการแพทย์ทางเลือก) certify cannabis cultivation sites. Ask the department directly how to apply, because the application channel could not be confirmed here.
What to do: Run a trace test on your last harvest. Give the records to someone who did not do the work. Ask them to follow one packed bag back to its seed lot using only the paperwork. The point where they get stuck is the gap an inspector will find.
4. The release decision
In Europe, the release step is set out in Annex 16 of EudraLex Volume 4, “Certification by a Qualified Person and Batch Release”. A Qualified Person (QP) is a named, legally responsible person who signs off each batch. A person does the certification, and that person’s name goes on the record.
A laboratory test measures a small sample. A release is a decision about the whole batch. When the Qualified Person releases a batch, they confirm five things:
- it was made by the approved process
- it was made at a compliant site
- the records are complete
- any deviations are acceptable
- it may lawfully enter the destination market
Other countries may or may not have an equivalent role. Confirm this with that country’s regulator.
Translator’s note: A Thai farm selling to Europe will usually not employ its own Qualified Person. This article could not confirm whose Qualified Person certifies imported cannabis flower in each EU country. Ask the buyer early who will release your batch and what that person needs from you. The document pack in Part 2, section 8, lists what they will look at.
What to do: Get the release person’s checklist in writing before your first export crop is planted. That way you build the records they need while the crop is growing, instead of rebuilding them after harvest.
5. Distribution practice (GDP)
GDP is a quality assurance system for buying, receiving, storing and exporting medicines. It covers the whole route from the manufacturer’s premises to the end user.
When conditions in transit go outside the agreed limits, this is called an excursion. An excursion is a quality event. It can cancel a release that was valid on the day the container was sealed.
Translator’s note: In Thailand, a pallet can wait for hours in a truck, a port yard or on an airport apron at 30–35 °C. A power cut at a cold store has the same effect. Agree the allowed temperature and humidity range with the buyer in writing before shipping. Put a temperature and humidity data logger inside every shipment, because without the log nobody can prove the batch stayed within limits.
What to do: Send a test box containing packaging only, with a data logger inside, along the domestic part of your route, from farm to port or airport. Read the log to find where and when the heat peaks happen.
6. Narcotics control on top of everything
The Single Convention on Narcotic Drugs, 1961 is the UN treaty that controls the cross-border trade in cannabis. It entered into force on 13 December 1964. As of 2022 it had 186 parties (member countries).
Cannabis and cannabis resin used to be in Schedule IV, the treaty’s most restrictive list. The Commission on Narcotic Drugs is the UN body that decides these lists. On 2 December 2020 it adopted Decision 63/17, which removed both from Schedule IV. The change took effect for each party on the day that party received the UN Secretary-General’s notification, sent in 2021.
Removing cannabis from Schedule IV did not end control. Cannabis and cannabis resin remain in Schedule I, so the treaty rules below still apply to the cross-border trade in medical cannabis.
A government agency, estimates and quotas
Articles 23 and 28 require each party that allows cultivation for medical and scientific purposes to set up a government agency to control it. Growers deliver their total crop to that agency. The agency must take physical possession of the crop within four months after harvest. It also holds the exclusive right to import, export and sell wholesale. Article 28 excludes cultivation done only for industrial purposes (fibre and seed) or for horticultural purposes.
Article 21 limits the quantities each country manufactures and imports each year. The total may cover only set purposes, mainly medical and scientific use within the estimates, exports and additions to stock. Under Articles 12 and 19, the International Narcotics Control Board (INCB), the body that monitors the treaty, runs this estimates system. This article does not give the form names or deadlines for estimates, because they could not be confirmed.
Translator’s note: The estimate works as a yearly national limit. A large new export contract may not fit within it. Ask the Thai authorities which agency handles the treaty estimates for cannabis, and how far in advance a new export volume must be reported. This article could not confirm which agency that is.
Two permits for every shipment
The treaty requires an import authorisation and an export authorisation for every individual international transaction. First, the destination country’s authority issues the import authorisation to its licensed importer. Then the exporting country’s authority issues a matching export authorisation. Both permits cover one transaction only, and both expire.
A signed contract, a paid deposit and a booked ship give you no legal right to move the goods. The shipment does not leave in three cases:
- the import authorisation has not been issued
- it has expired
- it names a different quantity from what you produced
The import certificate comes first
Article 31 of the Convention sets the order:
- The importing country’s authority issues an import certificate for a named drug and quantity.
- The exporting country’s authority then issues an export authorisation. It quotes the number and date of the import certificate and names the authority that issued it.
- A copy of the export authorisation travels with the consignment. The exporting government also sends a copy to the importing government. Each transit country must be shown a copy before it lets the goods pass.
- When the goods arrive, the importing government endorses the export authorisation with the quantity actually received.
This order has four practical consequences:
- The import certificate sets the maximum quantity. A shipment above the authorised amount puts the whole consignment at risk, not just the extra.
- Both documents expire. You can ship lawfully only while both permits are valid at the same time. This shared window is often much shorter than either permit’s own validity period.
- Shipments without an export authorisation are held. Under Article 31, a consignment that enters or leaves a party’s territory without one is to be detained.
- Transit routes need paperwork too. Under Article 31, a transit country, where the shipment passes through on its way, may not let it pass unless its authorities are shown a copy of the export authorisation.
No lawful route lets you ship first and get the permit later. The buyer’s import certificate has to exist before the Thai export authorisation can be issued.
What to do: Before you set a harvest date, get a copy of the buyer’s import certificate. Check the named product, the quantity and the validity dates. Then plan harvest, drying, testing and packing so they finish while both permits are valid. Weigh the final packed lot and compare it with the certificate before you apply for export authorisation.
Checklist from Part 1
- Make a table of the standards for your own farm, showing an owner and the records for each step.
- Keep a batch record from planting onwards, filled in on the day of the work.
- Use only pesticides registered with the Department of Agriculture, as the label says.
- Log drying and transport conditions, including every power cut.
- Ask the buyer who releases the batch and what that person needs.
- See the import certificate before you plan the harvest.
If you have a question about any step above, post it below this topic. Growers who have already gone through a GACP audit or an export shipment can share what was asked of them.
References
- European Medicines Agency: guideline on good agricultural and collection practice (GACP) for medicinal plants.
- EudraLex Volume 4 (EU GMP guidelines): Part I; Annex 7 (herbal medicinal products); Annex 16 (Certification by a Qualified Person and Batch Release).
- World Health Organization: GMP guidelines.
- Single Convention on Narcotic Drugs, 1961: Articles 9, 21, 23, 28 and 31.
- Commission on Narcotic Drugs: Decision 63/17, 2 December 2020.
- Tilleke & Gibbins: Cannabis and Hemp Business Guide: Thailand, 2025 edition.
This article is part of the Asiannabis Community educational series on cultivation standards, testing and export. It is general information, not legal or regulatory advice. It is meant for education in places where cannabis is legally permitted.
Continued in Part 2: From a Thai Farm to a Regulated Overseas Market: Destinations, Documents, Testing and Thai Licences (Part 2 of 2)