Five Medical Cannabis Flower Markets Compared for Thai Exporters: Israel, the UK, Switzerland and the Thai Side (Part 2 of 2)

No shipment of Thai medical cannabis flower has been documented into Israel, the United Kingdom or Switzerland. All three require the flower to pass through a GMP step before it reaches patients, and each puts that step in a different place. This part explains the permissions each market requires, where the GMP step must happen, and what to ask before you plan a shipment. It ends with the Thai paperwork every export needs and a table comparing all five markets.

Figures are as of October 2026. Israel’s recent reforms and the other figures here may change within the next year. Check the sources listed at the end before you rely on any number.

Part 1 covered Australia and Germany. Australia accepts Thai flower grown only to GACP as a starting material for GMP manufacture in Australia. About 20.7 tonnes of Thai flower was reported arriving there in 2025. Germany is the largest market, but Thailand is not on the published list of approved origins.

Two standards appear throughout. GACP (Good Agricultural and Collection Practice) is the farm standard for growing, harvesting and first handling. GMP (Good Manufacturing Practice) is the pharmaceutical standard for processing, testing and releasing a medicine, and EU-GMP is the European Union’s version. “The GMP step” means the first point where the flower must be handled under GMP. A consignment is one shipment.

This is Part 2. Part 1: Five Medical Flower Markets Compared: Germany, Australia, Switzerland, the UK and Israel

3. Israel: EU-GMP after harvest, under a rule last confirmed in 2020

Permissions

Importing into Israel requires:

  • an import permit from the Ministry of Health’s Medical Cannabis Unit
  • IMC-GMP, IMC-GDP and IMC-GSP licences, which are Israel’s own standards for manufacturing, distribution and security
  • a responsible pharmacist who oversees the import

The quality document is SOP 152, “IMC-GMP Quality Requirements for Manufacturing Medical Cannabis Products”. It sets the tests and specifications for products sold in Israel (reported by GSAP, an Israeli regulatory consultancy).

Where the GMP step must happen

Cultivation requires GACP. Post-harvest facilities must meet EU-GMP if they are abroad, or IMC-GMP if processing is done in Israel. This rule was last confirmed in 2020 (MJBizDaily, September 2020). It could not be confirmed from Ministry text that the current SOP 152 still contains it.

If the rule still stands, the GMP step cannot be left to the importing country unless processing moves to Israel. Secondary sources report a more recent reform. It was not checked against Ministry text.

Scale

Industry reports describe Canada as the main source of Israel’s imports. Documented origins include Canada, Portugal, South Africa, Lesotho and Colombia. No evidence of Thai-origin material was found.

What to do before considering Israel

Translator’s note:

  1. Ask an Israeli importer for the current SOP 152 requirements for post-harvest sites abroad. A news report from 2020 is too old to base an investment on.
  2. Ask whether any reform since 2020 changed the import rules. The answer tells you whether the EU-GMP condition still applies.
  3. If EU-GMP after harvest is still required and you do not have it, treat Israel as a later market. Put your effort into markets you can supply now.

4. United Kingdom: three permissions, small market

Permissions

The UK requires three separate permissions:

  • From the Home Office, the UK interior ministry that licenses controlled drugs: a Schedule 2 licence, plus an import licence for each consignment. Each import licence is valid for three months.
  • From the MHRA, the UK medicines regulator: a Manufacturer’s (Specials) Licence where the source is a third country, as Thailand is. A Specials licence covers unlicensed medicines supplied to meet individual patients’ needs.
  • Notice to the MHRA before import. The product must not be imported if the MHRA objects within 28 days of acknowledging the notice.

Where the GMP step must happen

A valid GMP certificate is needed for the overseas manufacturing site. Products must meet pharmacopoeial standards, which are the official quality standards for medicines. Each batch also needs a certificate of analysis, the laboratory report of test results for that batch. So the UK accepts a GMP step in the origin country, but that step must be certified (source: MHRA guidance on specials, as summarised by ECA Academy).

Scale

There is no official count of UK patients, and published estimates for 2026 vary widely. No official import figure in kilograms was found.

Why Thai paperwork gets close checks

From 1 October 2025 to 30 June 2026, Thai Customs recorded 3,309 cannabis smuggling cases. That is the year to date, not a full fiscal year. Of these cases, 2,133 were bound for the UK, involving nearly 14,000 kg (Royal Thai Government, 2026).

These were courier cases, not commercial shipments. Even so, a legitimate exporter should expect close checks on Thai-origin paperwork.

What to do before considering the UK

Translator’s note:

  1. Before you sign anything, confirm that the UK importer holds the Home Office and MHRA licences. Ask for copies. Without both licences there is no legal route.
  2. Plan to do the GMP step at your Thai site and have it certified. Ask the importer which GMP certificates the MHRA accepts for that site. The answer tells you what your site must achieve.
  3. Make every document match exactly: product name, batch number, weight and both company names. Thai-origin paperwork will be checked closely, and one mismatch can hold up a consignment.

5. Switzerland: the least documented market

Permissions

Swissmedic is the Swiss medicines regulator. An importer needs a Swissmedic establishment licence covering cultivation, manufacture, storage, distribution, import and export. The licence is valid for five years. Narcotics import authorisations are also needed. Since 1 August 2022, Swissmedic has taken over medical cannabis licensing from the Federal Office of Public Health, and doctors no longer need an exceptional permit from that office to prescribe cannabis medicines (sources: Swissmedic cannabis pages; Chambers 2026, Switzerland).

Where the GMP step must happen

Sources state that imported medical cannabis must comply with GMP, enforced through Swissmedic inspections. No source consulted shows whether GACP-only material is acceptable. No source shows whether the narcotics authorisation is issued for each shipment.

Scale

Patient numbers are modest. Sources disagree on how use is split between extracts and flower. No reliable import volume was found, and no Thai-origin shipments were found.

What to do before considering Switzerland

Translator’s note: Ask a Swiss importer to get Swissmedic’s written answer to two questions. First, is GACP-only flower acceptable? Second, is the narcotics import authorisation issued per shipment? Those two answers show whether Switzerland works like Australia or more like Germany for a Thai farm. Until you have them, do not budget for this market.

6. The Thai side of every shipment

The destination country’s rules cover only half of the chain. The Thai side has its own licences:

  • Thai law. Cannabis flower is a controlled herb under the Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis) B.E. 2568. The notification was issued under the Thai Traditional Medicine Protection Act B.E. 2542. It has been in force since 26 June 2025.
  • Export licence. The exporter needs a Thai licence to export a controlled herb. These licences are issued under the Ministerial Regulation on licensing for research, export, sale and processing of controlled herbs, B.E. 2559 (2016). The criteria for cannabis flower were tightened by the Ministerial Regulation on Controlled Herbs (No. 2) B.E. 2569, in force since 30 April 2026.
  • Penalty. Exporting a controlled herb without a licence is punishable under Section 78 of the 1999 Act. The penalty is up to 1 year in prison, a fine of up to 20,000 baht, or both.
  • Paired authorisations. Cannabis remains a Schedule I drug under the 1961 Single Convention on Narcotic Drugs, the UN treaty that controls narcotics. Under Article 31, two documents travel together for each consignment. One is the destination country’s import authorisation. The other is a matching export authorisation on the Thai side.
  • Coming changes. The draft Cannabis Control Act is not law yet. The Cabinet approved the draft on 22 September 2026 and sent it to the House. It may change this framework.

The Thai licence chain is explained step by step in the forum topic From a Thai Farm to a Regulated Overseas Market.

Translator’s note: Before you sign a supply contract, check three things. Your GACP certificate must cover the site where the flower was grown. Your Thai export licence must meet the criteria in force since April 2026. And the buyer must be able to obtain the import authorisation that your Thai export authorisation has to match. If any one of these is missing, do not plan the shipment yet.

7. The five markets in one table

Importer’s permissions GACP-only flower straight to patients Where the GMP step must physically happen Thai flower reported arriving
Australia ODC licence + permit per consignment; separate biosecurity approval (BICON) No, but yes as starting material A site with TGA GMP clearance, or later at an Australian GMP manufacturer Yes: about 20.7 t in 2025 (reported)
Germany MedCanG section 4 licence + BfArM permit per consignment + AMG section 72/72a No EU-GMP from drying onward (BfArM guidance as reported); in practice often an EU processor with release by a Qualified Person Not on the practice guide’s origin list; one weak trade report
Israel Ministry of Health import permit + IMC-GMP/GDP/GSP licences No EU-GMP after harvest if abroad, or IMC-GMP in Israel (last confirmed 2020) No evidence
UK Home Office licence + import licence per consignment + MHRA Specials licence + 28-day notice No Certified GMP at the overseas site No evidence
Switzerland Swissmedic establishment licence + narcotics authorisation Unclear Not established No evidence

Notes on the table: ODC is Australia’s Office of Drug Control, and TGA is Australia’s medicines regulator. BICON is Australia’s online database of biosecurity import conditions. BfArM is Germany’s federal medicines regulator, and MedCanG and AMG are Germany’s Medical Cannabis Act and Medicines Act. A Qualified Person is the expert who legally releases each batch in the EU. Part 1 explains all of these in detail.

8. What the table shows

The options are limited:

  • GACP-only flower sent straight to patients is not lawful in four of the five markets. For Switzerland it is unclear.
  • Australia accepts GACP flower as a starting material, and an Australian manufacturer carries out the GMP step. Thai material is reported as Australia’s second-largest source.
  • Germany and the wider EU: the route described most often is processing at an EU-GMP facility inside the EU. That description comes from commercial commentary, not from regulators.

In the other markets, the rules allow import in theory, but no Thai consignment has been documented. That does not prove it cannot be done. It does mean any such plan is a first-of-its-kind project, with its own cost and timeline. It is not a repeat of the Australian trade.

Translator’s note: Choose one target market and list every permission from the table that the chain would need. Next to each one, write who issues it and whether it already exists on your side or the buyer’s side. The gaps on that list show your real cost and timeline. The same list is a ready set of first questions for a destination importer.

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

Further reading on Asiannabis