Thai exporters of medical cannabis flower usually compare overseas markets by size. A more useful first question is whether a market’s rules accept your flower in the form you can supply. On that question, the five markets Thai exporters ask about most rank very differently. Australia is reported to have imported more than 20 tonnes of Thai flower in 2025. No Thai shipment has been documented in Germany, Israel, the United Kingdom or Switzerland.
Figures are as of October 2026. Several of them may change within the next year: import volumes, Germany’s annual import ceiling, Australia’s checks on prescribing and Israel’s recent reforms. Check the sources listed at the end before you rely on any number.
This part covers the two markets with the most detail. The first is Australia, where Thai flower already arrives. The second is Germany, the largest market. Part 2 covers Israel, the United Kingdom, Switzerland, the Thai paperwork every shipment needs, and a table comparing all five markets.
Terms used throughout this article
- GACP (Good Agricultural and Collection Practice) is the standard for the farm. It covers growing, harvesting and the first handling of a medicinal plant, with records for every batch.
- GMP (Good Manufacturing Practice) is the pharmaceutical standard for processing, packing, testing and releasing a medicine. A medicines regulator inspects and certifies each GMP site. EU-GMP is the European Union’s version.
- The GMP step is the first point in the supply chain where the flower must be handled under GMP. Each market puts this step in a different place. Where it sits decides whether a farm with only GACP can sell into that market.
- A consignment is one shipment. Several markets require a separate permit for each one.
1. Australia: the market where Thai flower already arrives
Who holds which permission
The Australian importer holds the import permissions, not the Thai farm. The importer needs two things:
- an import licence from the Office of Drug Control (ODC), the Australian government office that licenses imports of controlled drugs
- a permit for each consignment
Patients receive the product through one of three routes. Each route also needs a sponsor, which is the Australian company legally responsible for supplying the product:
- Special Access Scheme Category B: a doctor applies for approval to prescribe an unapproved medicine to one named patient.
- Authorised Prescriber pathway: a doctor is approved to prescribe the product to a group of patients.
- Clinical trial.
These rules come from guidance by the Therapeutic Goods Administration (TGA), Australia’s medicines regulator, on importing, manufacturing and supplying medicinal cannabis.
Where the GMP step must happen
Since 1 July 2023, all imported medicinal cannabis released for supply in Australia must be made under GMP. Every manufacturing step done overseas must also comply with GMP. The rule came from an amendment to TGO 93, Australia’s quality standard for medicinal cannabis (sources: ECA Academy summary of the amendment; TGA reforms FAQ).
There is one exception. Cannabis that was not made under GMP may still be used as a starting material, which means the raw input, to make another product that is GMP compliant. For a Thai farm this leaves two options:
- Ship GACP-only flower as starting material. An Australian GMP manufacturer then carries out the GMP step in Australia.
- Do the GMP step overseas, for example in Thailand. The site then needs TGA GMP clearance. A GMP certificate from just any regulator is not enough.
The TGA accepts GMP evidence only from regulators it has assessed as equivalent. That assessment happens through PIC/S (the Pharmaceutical Inspection Co-operation Scheme, a network of national medicine inspectorates) or through mutual-recognition agreements. If no accepted evidence exists, the TGA inspects the site itself (source: TGA page on international agreements and GMP clearance).
In practice, your real buyer is the Australian manufacturer. Its specification for incoming material decides whether your flower is accepted.
Biosecurity is a separate approval
Passing the medicines rules does not clear the border. Biosecurity approval comes from a different body, the Department of Agriculture, Fisheries and Forestry. Its import conditions for Cannabis plant material are published in BICON, the department’s online database of biosecurity import conditions.
A consignment with every medicines approval can still be held at the border if it does not meet these conditions. Read the current BICON conditions yourself before every shipment.
How much Thai flower has arrived
| Year | Thai flower imported into Australia | Source |
|---|---|---|
| 2023 | 11 kg | ODC data reported by StratCann |
| 2024 | 1,093 kg | same |
| 2025 | about 20,658 kg | reported by International CBC and Cannamonitor, citing ODC data |
The 2025 figure is roughly a quarter of Australia’s total imports of about 81 tonnes. Only Canada supplied more, at about 49.1 tonnes. The 2025 figure comes from trade press citing ODC data. ODC’s own 2025 table was not checked directly.
What to do before shipping to Australia
Translator’s note: The steps below are practical suggestions for Thai exporters. They are not requirements written in the Australian rules.
- Before harvest, ask the Australian buyer for its specification for incoming material in writing. It tells you which tests, limits and documents the buyer requires. Ask specifically about testing, retained samples, audit rights and batch documentation. These terms are not published, so you will only see them in the contract.
- Ask the buyer which BICON conditions apply now, and who is responsible for meeting them. The answer shows early whether your packaging, cleaning or paperwork must change.
- Start with a small first consignment. It tests the whole chain once: your Thai export licence, the ODC permit, biosecurity and the buyer’s receiving tests. If something goes wrong, you lose one small batch instead of a full harvest.
- Plan for the Thai rainy season. Dried flower can absorb moisture again during storage and transport. Seal it well and test it just before shipping, so it does not fail the buyer’s tests on arrival (see testing flower before export).
2. Germany: the largest market, with the strictest GMP rule
Four permissions
Germany’s federal medicines regulator is BfArM, the Federal Institute for Drugs and Medical Devices. An importer needs four separate permissions (sources: Chambers Medical Cannabis 2026, Germany; BfArM import guidance):
- a licence under section 4 of Germany’s Medical Cannabis Act (MedCanG), issued by BfArM
- a separate BfArM import permit for every consignment
- an import licence under section 72 of the German Medicines Act (AMG), issued by the authority of the German state where the importer is based
- a certificate under section 72a AMG for material from outside the EU. This is a GMP certificate from the authority of the origin country. It must confirm that the site follows GMP equivalent to EU standards and has regular inspections, including unannounced ones.
Under EU rules, narcotic drugs do not move freely between member states. So flower that lands legally in another EU country has no automatic access to Germany. Each consignment still needs its own German permit.
Where the GMP step must happen
BfArM guidance requires a valid GMP certificate to cover the drying step. At least one German state inspectorate, in Hesse, does not accept pre-drying at the grower’s site as a GACP activity. Put simply, the German market treats drying as manufacturing, not as farm work (both points reported by ECA Academy).
Some commentators conclude that the farm itself would therefore need EU-GMP. That is their interpretation, not text from a regulator. Two further points remain unclear:
- No regulator text was found that says which part of the EU-GMP guide applies to flower dispensed by pharmacies. The options are Part I (finished medicines), Part II (active substances) or Annex 7 (herbal medicinal products).
- German state authorities are reported to differ on whether flower counts as an active substance or as a finished product.
The EU processing route
Consultancy and grower commentary describe the following route. Regulator texts do not describe it.
- The dried plant material is shipped to an EU-GMP processor inside the EU. Portugal is the country named most often.
- A Qualified Person releases the batch. In the EU, the Qualified Person (QP) is the named expert legally responsible for certifying each batch. Release is checked against the European Pharmacopoeia Cannabis flower monograph 3028, the EU’s official quality standard for the flower. It has been in force since 1 July 2024.
- The flower then enters Germany as a product made in the EU.
So whether a farm needs EU-GMP depends on two things. The first is where its post-harvest steps happen. The second is what the importer or processor requires. Ask the processor first.
EU rules that affect Thai material
- Thailand is not on the EU’s Article 111b list. This is Implementing Decision 2012/715/EU, as amended. The list names non-EU countries whose rules for active substances the EU treats as equivalent. It currently covers Switzerland, Australia, Japan, the United States, Israel, Brazil and the Republic of Korea.
- What this means for an unlisted country like Thailand: where the material counts as an active substance, the exporter needs a written confirmation from its own regulator. It has not been settled whether this applies to flower used for pharmacy preparations.
- Thailand joined PIC/S on 1 August 2016. PIC/S is cooperation between inspectorates. It does not mean automatic mutual recognition, so PIC/S membership alone does not get a Thai GMP certificate accepted in the EU.
Volumes and the import ceiling
All figures below are reported by trade press citing BfArM. No direct BfArM source was found.
- 2025: 201,094 kg, up from roughly 73 tonnes in 2024. Canada supplied 93,006 kg and Portugal 55,164 kg (StratCann).
- First quarter of 2026: 67,569 kg. The figure was revised in August 2026 from 50,539 kg. Canada was reported at 26,753 kg and Portugal at 10,342 kg, but these country figures match the earlier total. No updated breakdown by country was found (StratCann).
- The ceiling: Germany’s 2025 import quota of 122 tonnes is registered with the International Narcotics Control Board (INCB), the UN body that monitors narcotic drug quantities. The quota was used up in September 2025, and import approvals were paused. BfArM then obtained an increase to about 192.5 tonnes. Approvals resumed around 20 October 2025 (Business of Cannabis; StratCann).
Thailand is not on the list of approved origins
A 2026 practice guide by Chambers lists 17 jurisdictions that Germany has approved imports from. They are Australia, Denmark, Israel, Jamaica, Canada, Colombia, Lesotho, Malta, New Zealand, the Netherlands, North Macedonia, Austria, Poland, Portugal, Spain, Uganda and Uruguay. Thailand is not on the list. It is not clear whether the list is complete or only describes past trade.
One trade source reports roughly 0.1 tonnes of Thai material entering Germany in 2025, but it does not cite BfArM. No Thai facility was identified as holding EU-GMP certification. Consultancy estimates put the path to certification at around twelve months.
What to do before planning for Germany
Translator’s note: These are practical steps, not requirements written in German law.
- Contact an EU-GMP processor before you invest. Ask in writing whether it accepts flower dried on a Thai GACP farm, and which documents it needs. The answer tells you whether your farm needs EU-GMP at all.
- Work out the real cost of the drying step. If drying must be done under GMP, the drying room needs climate control, cleaning routines and batch records. In the Thai rainy season, that usually means dehumidifiers and air conditioning running all the time (see drying at high ambient humidity).
- Allow about twelve months if you pursue EU-GMP yourself, based on the consultancy estimate above. During that time, keep supplying markets that accept GACP flower, such as Australia as starting material.
- Ask the Thai licensing authority whether it can issue the written confirmation an EU buyer may need for an active substance. This shows early whether that document is available for Thai material.
Share your experience
If you ship flower to Australia, please post below what the Australian manufacturer required beyond GACP. The regulation clearly allows non-GMP flower as a starting material. What is not public is what a receiving manufacturer writes into its contract: testing, retained samples, audit rights and batch documentation. Real examples from members would be the most useful addition to this thread.
This article is reference information for readers operating legally in their own jurisdictions. It is not legal, regulatory or investment advice. Most figures come from trade press or consultancy reports citing regulator data, not from the regulators directly. Where no reliable figure exists, the article says so instead of estimating. No certification is claimed here for any named company. Check every requirement with the destination’s competent authority and with the Thai licensing authority before committing to a market.
Sources used in this part
- TGA, guidance on importing, manufacturing and supplying medicinal cannabis
- ECA Academy, summary of the TGO 93 amendment
- TGA, medicinal cannabis reforms: frequently asked questions
- TGA, international agreements and GMP clearance
- Department of Agriculture, Fisheries and Forestry, BICON import conditions for Cannabis spp.
- StratCann, Australian import market
- International CBC, Australia’s 2025 medical cannabis imports
- Cannamonitor, Australia
- Chambers Medical Cannabis 2026, Germany; BfArM import guidance
- ECA Academy, GMP vs GACP: BfArM makes some clarifications
- ECA Academy, Can cannabis flowers be pre-dried in accordance with GACP?
- StratCann, Germany 2025 imports
- StratCann, Canada supplied half of Germany’s cannabis imports in Q1 2026
- Business of Cannabis, import approvals paused as Germany hits 2025 limit
- StratCann, German import quota
Further reading on Asiannabis
- Two Ways Countries Regulate Medical Cannabis: A Dedicated Cannabis Agency or the Normal Medicines Route
- What Can Actually Leave Thailand as Hemp: Extracts, Seed, Fibre and Cosmetics
Continued in Part 2: Five Medical Cannabis Flower Markets Compared for Thai Exporters: Israel, the UK, Switzerland and the Thai Side (Part 2 of 2)