Export deals between Thai sellers and overseas buyers often fail because the two sides use the same words for different things. For example, a buyer asks for “EU-GMP flower” and receives a farming certificate. Or an invoice says “CBD flower” and arrives in a country where CBD is legal but flower is not.
Part 1 covered plant parts, the three THC figures on a lab report (Δ9-THC, THCA and total THC), and Thai legal terms. In short, THC is the compound that causes the psychoactive effect. Many foreign labs read total THC, which includes the acid form THCA. Thai law also treats cannabis and hemp flower as a “controlled herb” whatever its THC level.
This part covers three quality standards, the trade and customs documents, and two words whose meaning changes between countries.
This is Part 2. Part 1: Cannabis and Hemp Flower Export from Thailand, a Working Glossary: Plant Parts, THC Figures and Thai Legal Terms (Part 1 of 2)
4. Quality standards: three labels, three different jobs
GACP: Good Agricultural and Collection Practices. GACP is a farming standard. It covers:
- propagation material (seeds and clones);
- cultivation, harvest and primary processing (the first handling steps after harvest);
- storage and transport;
- the records behind all of these.
In Thailand, GACP certification is issued by DTAM, the Department of Thai Traditional and Alternative Medicine (Ministry of Public Health). GACP is about farming only. It says nothing about making medicines.
GMP: Good Manufacturing Practice. GMP is a standard for making medicines. EU-GMP is the European Union’s version. It is set out in EudraLex Volume 4, the EU’s official collection of GMP rules for medicines. An EU-GMP certificate is issued after an inspection by a competent authority of an EU member state, meaning that country’s medicines regulator.
The confusion this glossary is meant to prevent. GACP is not a lesser form of GMP. Holding GACP does not put a product one step away from GMP. They are different standards with different jobs.
Most medical markets require both. GACP applies up to harvest, and GMP applies from a defined step onward. Where that step sits differs by market. Getting it wrong is the most expensive mistake in this trade. A separate forum article sets out the GMP rule market by market: Five Medical Flower Markets Compared.
What to do: Before you quote a price, ask the buyer two questions in writing. At which step does GMP begin in their market? Which GMP certificate will they accept for that step? The answers tell you what extra processing you must pay for.
Translator’s note: If a Thai farm with only a GACP certificate receives a request for “EU-GMP flower”, it cannot meet that request alone. The steps from the GMP point onward must be done at a site holding a GMP certificate that the buyer’s market accepts. Make this clear before you sign, so the price includes those costs.
PIC/S: Pharmaceutical Inspection Co-operation Scheme. PIC/S is an international network of government inspectorates that check medicine factories. Thailand joined on 1 August 2016 (source: PIC/S).
PIC/S membership is a framework for co-operation between inspectors. It does not mean that member countries automatically accept each other’s certificates.
Thailand is also not on the European Commission’s Article 111b list. This list names non-EU countries whose GMP supervision the EU treats as equivalent for imports of active substances (the active ingredients of medicines). The source is the European Commission list, checked in September 2026.
What to do: Do not assume a Thai GMP certificate will be accepted in the EU. Ask the buyer which certificate their authority requires. This tells you early whether an inspection by an EU authority is needed.
Ph. Eur. Cannabis flos. The European Pharmacopoeia (Ph. Eur.) is the official book of quality standards for medicines in Europe. A monograph is its entry for one substance. “Cannabis flos” is the monograph for cannabis flower. It was published in Supplement 11.5 and has been official since 1 July 2024 (per ECA Academy, a European GMP training organisation).
The monograph sets requirements for:
- identification (tests that prove the material is cannabis);
- chromatographic assay (measuring cannabinoid content in the lab);
- chemotype classes (groups based on the main cannabinoids);
- foreign matter (stems, seeds, other plants, dirt);
- loss on drying (the weight lost when the sample is dried, mostly water): maximum 12.0%;
- elemental impurities (heavy metals and similar elements);
- pesticides;
- aflatoxin B1 (a toxin made by some moulds);
- microbiological limits (bacteria, yeasts and moulds).
When a buyer says “Ph. Eur. compliant”, this monograph is the document they mean.
What to do: Ask the buyer which Ph. Eur. edition they apply. Then test a trial batch against every item on the list before you quote. This shows which limit your farm fails while there is still time to fix it.
Translator’s note: In the Thai rainy season, outdoor humidity stays very high. This makes the loss-on-drying limit and the mould and microbial limits harder to meet. Dry and store export batches in a room where you control humidity. For drying options in these conditions, see Drying Cannabis at 85–95% Ambient Humidity.
5. Trade and customs documents
COA: certificate of analysis. A COA is a lab report for one specific batch. For export, it should state the test method, not only the result. As Part 1 showed, the method changes the THC figure. Testing before export is covered in Testing Before Export: The COA That Passes, and the One That Fails.
ISO/IEC 17025. This is the accreditation standard for the competence of a testing laboratory. It is not a standard for cannabis products. Accreditation is granted for a defined scope, meaning a list of the tests the lab is approved to run. A lab accredited for food chemistry is not accredited for cannabinoid testing because of that.
What to do: Ask the lab for its scope certificate, not just the accreditation logo. Check that the scope names the cannabinoid test you need. This proves that the result on your COA comes from an accredited test.
Phytosanitary certificate. This is a plant-health certificate issued by the national plant protection organisation, the government agency in charge of plant health. It covers one commodity and the requirements of one destination. For controlled goods it does not replace narcotics documents.
Translator’s note: In Thailand, the national plant protection organisation that issues phytosanitary certificates is the Department of Agriculture (กรมวิชาการเกษตร). Apply for it separately from your controlled-herb or narcotics paperwork.
Import certificate and export authorisation. These two documents work as a pair under Article 31 of the Single Convention on Narcotic Drugs, 1961, a United Nations treaty that controls narcotics trade. The steps are:
- The importer’s national authority issues an import certificate.
- The exporter presents that certificate to its own national authority and receives an export authorisation.
- A copy of the export authorisation travels with the consignment.
- The importing government records the quantity actually received on the authorisation, endorses it and sends it back.
The sources are the UNODC (United Nations Office on Drugs and Crime) text of the 1961 Convention, and the INCB (International Narcotics Control Board) guide Controls on International Trade in Narcotic Drugs. The Convention requires the export authorisation to travel with the consignment. National authorities detain shipments that arrive without one.
What to do: Get a copy of the buyer’s import certificate first. Do not book freight until you hold your export authorisation. Following this order prevents a shipment from being held at the border.
Translator’s note: In Thailand, flower exports need a Section 46 licence from DTAM, and extracts above 0.2% THC need a licence from the Thai FDA. Ask the agency for your product which office issues the export authorisation for each shipment.
HS code. The Harmonized System is the international numbering system that customs uses to classify goods. Common codes are listed below (source: Statistics Canada’s published cannabis classification, the clearest public mapping):
| Product | HS code commonly used |
|---|---|
| Dried cannabis flower | 1211.90 (plants and parts of plants used mainly in perfumery or pharmacy, other) |
| Extracts | 1302.19 |
| Cannabis medicines | 3004.90 |
| True hemp fibre | 5302.10 |
There are two warnings. First, the extra digits each country adds (national subheadings) differ. Second, a correct HS code does not make a product legal. Narcotics control applies at the border whatever the tariff code.
What to do: Confirm the full national code with the customs authority or your customs broker in both countries. Treat the HS code as a tax label only, not as proof of legality.
Novel Food. This is a status under EU food law, Regulation (EU) 2015/2283. A Novel Food needs authorisation before it can be sold. CBD in food requires this authorisation. As of 2026 none had been granted. In February 2026, EFSA (the European Food Safety Authority) issued only a provisional safe-intake figure (source: EFSA, February 2026).
Novel Food is food law only. It does not cover cosmetics. A smokable flower is not a food at all. That is why flower bans are written into narcotics or tobacco law instead.
What to do: For an EU buyer, first decide which law applies to your product form. It could be food law (Novel Food), cosmetics law, or narcotics or tobacco law for flower. This avoids the “CBD flower” invoice problem from the introduction.
MRL: maximum residue limit. This is the highest amount of a pesticide allowed to remain on a product. Residue limits are covered in more detail in the forum topic on pesticide residues on cannabis.
For medical flower, the binding pesticide limits are those in Ph. Eur. chapter 2.8.13. They apply through the Cannabis flos monograph. Food MRLs under Regulation (EC) 396/2005 matter mainly for hemp food products.
Under that food regulation, a pesticide with no specific limit generally gets a default limit of 0.01 mg/kg. This is far lower than a farm used to food-crop limits will expect.
Translator’s note: In Thailand, use only pesticides registered with the Department of Agriculture (กรมวิชาการเกษตร), and only as the label directs. A product being registered in Thailand does not mean its residue will pass an export limit. Keep a spray log (product, dose, date, batch) for every export batch. Test residues before you offer the batch. See also What You May Legally Spray Under Thai GACP.
6. Two words that mean different things in different countries
“Hemp”. Each market draws the line in a different place:
| Market | What “hemp” means | Source |
|---|---|---|
| Thailand | A plant with ≤1.0% THC; its flower is still a controlled herb | Ministerial Regulation on Hemp B.E. 2563, per Tilleke & Gibbins (law-firm commentary) |
| European Union | An agricultural variety below 0.3% THC, since 1 January 2023 | European Commission |
| Switzerland | Cannabis below 1.0% average total THC falls completely outside the Narcotics Act | CMS expert guide (law-firm commentary) |
| Czech Republic | 1.0% THC in dry matter | Czech law |
A shipment that is lawful hemp in Bangkok is not automatically lawful hemp in Berlin. For example, the Part 1 batch had about 1.78% total THC. That is above both the EU 0.3% line and the Swiss 1.0% line.
“Pharmaceutical grade”. This is not a legal term anywhere. It usually means one of two things. Either the batch met a pharmacopoeial monograph, or the site holds a GMP certificate.
What to do: When a buyer or seller says “pharmaceutical grade”, ask which meaning they intend, and ask to see the document. In every contract, write the destination country’s legal definition of hemp and its THC limit. Both sides then measure against the same line.
Share your experience
If you have completed a licensed export or import, which term caused the most confusion: GACP versus GMP, total THC versus Δ9-THC, or the permitted product form? Please share below, and describe only lawful, licensed transactions.
Related reading
- The two export tracks (flower, and everything that is not flower): What Can Actually Leave Thailand as Hemp.
- Where the GMP step must happen, market by market: Five Medical Flower Markets Compared.
- What GMP actually means for medical cannabis: see the EU-GMP topic linked in Section 4.
Sources cited in Part 2
- EudraLex Volume 4 (EU GMP rules).
- PIC/S, Thailand’s accession date (1 August 2016).
- European Commission, Article 111b list of third countries (checked September 2026).
- ECA Academy, on Ph. Eur. Cannabis flos (Supplement 11.5, official 1 July 2024).
- European Pharmacopoeia, chapter 2.8.13 (pesticide residues).
- UNODC, text of the Single Convention on Narcotic Drugs, 1961.
- INCB, Controls on International Trade in Narcotic Drugs.
- Statistics Canada, published cannabis classification (HS codes).
- Regulation (EU) 2015/2283 (Novel Food).
- EFSA, February 2026 (provisional safe intake of CBD).
- Regulation (EC) 396/2005 (pesticide residues in food).
- European Commission, EU hemp THC limit of 0.3% from 1 January 2023.
- CMS expert guide (law-firm commentary), Switzerland.
- Tilleke & Gibbins, Cannabis and Hemp Business Guide – Thailand, 2025 edition, updated November 2025 (law-firm commentary).
This article is reference information for readers operating legally in their own jurisdictions. It is not legal, customs or tax advice. The law described here changes often and differs by country. Several figures come from professional commentary rather than from the law itself, and they are marked as such in the text. Check every point with the competent authority and a qualified lawyer in the relevant country before you enter into any transaction.