Before a batch can leave Thailand for a regulated market, it must pass four standards:
- good agricultural and collection practice (GACP) on the farm
- good manufacturing practice (GMP) in processing
- release by one named, responsible person
- good distribution practice (GDP) in transport and storage
On top of these sits the Single Convention on Narcotic Drugs, 1961. This UN treaty requires two permits for every shipment: an import certificate from the buyer’s country and a matching export authorisation from Thailand.
This part covers what three destination countries require and the documents that go with a batch. It also covers microbial and shelf-life testing, contracts, common failures and the current Thai rules. 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.
This is Part 2. Part 1: From a Thai Farm to a Regulated Overseas Market: Standards, Release and Permits (Part 1 of 2)
7. What each destination requires
Germany
Confirmed: Germany’s medical cannabis law took effect on 10 March 2017. It covers seriously ill patients who have no other treatment option. The Federal Institute for Drugs and Medical Devices, the German medicines regulator, issued the licences for cultivation and import. Imported cannabis had to meet EU GMP standards.
Confirmed: The Cannabis Act took effect on 1 April 2024. It removed cannabis from the Narcotic Drugs Act.
Not confirmed: The permit type, forms and processing times at the Federal Opium Agency, the German office that handles narcotics permits. It is also not confirmed how the 2024 change affected import authorisation.
Czech Republic
Confirmed: Medical cannabis became legal on 1 April 2013. Patients may receive up to 180 grams of dried cannabis per month, on an electronic prescription from a specialist doctor. In the first year only imported cannabis was allowed, so that standards were met.
Confirmed: Since 1 January 2026, adults aged 21 and over may grow three plants and keep 100 grams at home. Commercial sales are still prohibited. The forum topic on the Czech change explains it.
Not confirmed: The responsible Czech authority, the import licence type, the product specification and the set of required tests. Do not assume the 2026 change left the medical import route unchanged.
Australia
Confirmed: The Therapeutic Goods Administration (TGA) is Australia’s GMP regulator.
Not confirmed: Anything about Australian medical cannabis routes, standards, testing or import permits. Treat any claim about Australian requirements as unconfirmed until you have checked it with the TGA itself.
Requirements change
| Destination | Confirmed | Not confirmed |
|---|---|---|
| Germany | Prescription framework and dates; the federal institute’s licensing role; EU GMP for imports; 2024 narcotics-law change | Permit types, forms, processing times, import route, required tests |
| Czech Republic | Legalisation date, monthly limit, import-only first year, 2026 home-growing change | Name of the regulator, licence type, specification, required tests |
| Australia | Which national body regulates GMP | Everything else: standards, routes, permits, testing |
Every framework above has changed within the last ten years. Check the requirements again before every new contract.
Translator’s note: Thai rules have also changed several times since 2022 (see section 13). A requirement you checked last year may already be out of date.
What to do: Keep a one-page sheet for each destination. List each requirement, its source and the date you checked it. Before each new contract, ask the buyer for the regulator’s current written requirements and update the sheet.
8. The document pack
| Document | What it proves | Status in this article |
|---|---|---|
| Batch manufacturing record | Every defined step was done and recorded | Confirmed from GMP rules |
| Certificate of analysis (COA), the laboratory report for one batch | Test results for this batch against an agreed specification | The idea is confirmed; destination limits are not confirmed |
| GMP compliance certificate | A named site complied for named activities at inspection | Issuing authorities confirmed; wording not confirmed |
| Export authorisation | This shipment may leave | Confirmed from the Single Convention |
| Import authorisation | This shipment may enter | Confirmed from the Single Convention |
| Transport and storage records | The batch stayed within the defined conditions in transit | Confirmed from the scope of GDP |
Quantities and product descriptions must match across all of these documents and the goods themselves.
What to do: Make one cross-check sheet for each shipment. List the lot number, net weight and product description as they appear in each document. One person checks every line against the packed goods before the shipment is booked.
9. Reducing microbes, and irradiation
Why microbes matter
Dried plant material always carries microbes such as yeasts, moulds and bacteria. Some patients are immunocompromised, which means their immune systems are weakened. For this reason, destination markets set limits on microbial load.
Microbial counts are reported in colony-forming units per gram (CFU/g). The figure counts the living microbes in one gram that can grow into a visible colony in the lab. Limits differ widely between markets. A common one is for total yeast and mould, which is the combined count of all yeasts and moulds in a sample.
Methods, and how much they reduce
A 2016 paper by Arno Hazekamp in Frontiers in Pharmacology lists heat, chemical treatment, high pressure, filtration and irradiation as ways to reduce microbes. It names the Netherlands and Canada as countries that gamma-irradiate medicinal cannabis. A 2020 study by Jerushalmi and colleagues in the Journal of Cannabis Research tested gamma irradiation, electron beam and cold plasma. In some of its tests, gamma and electron beam brought fungal counts down to undetectable levels.
Reductions are given in “log” units. One log means ten times fewer microbes, or 90% removed. Five log means 100,000 times fewer. The 2020 study reports yeast and mould reductions of roughly 4.5 to 6 log with gamma irradiation, and about 5 log with electron beam on commercial flower.
The EMA GACP guideline allows fumigation only when it is really needed. It bans ethylene oxide.
The trade-off: aroma
Irradiation costs aroma. The 2016 paper found that gamma irradiation kept the terpene profile, which is the mix of aroma compounds, qualitatively the same, but it reduced some terpenes. Most of those fell by 10 to 20%, and some by as much as 38%. Cannabinoid levels did not change.
The producer wants to keep the aroma, while the market wants microbial safety. The market wins, because it controls the import authorisation. Every log of microbes you prevent with hygiene and fast drying is one log that does not need to be irradiated away.
Translator’s note: In the Thai rainy season, slow drying is the main reason microbial counts go up. A closed drying room with air conditioning and a dehumidifier is the cheapest way to keep the count down. It costs no aroma.
Translator’s note: Ask the buyer in writing whether their market accepts irradiated flower. Ask separately whether an irradiation service in Thailand will accept cannabis lots. This article could not confirm that any such service does.
What to do: Send a sample from one small lot to an accredited testing laboratory for a total yeast and mould count. Do this before you sign a contract that includes a microbial limit. You learn your starting level, and whether you would need irradiation at all. For other members’ experience with laboratories, ask in the B2B Services section.
10. Stability testing and shelf life
An importer needs a shelf life because a pharmacy needs an expiry date, and that date must be backed by data. Dried flower changes over time. Moisture moves in or out, cannabinoids slowly convert into other compounds, and terpenes evaporate.
No regulator document setting stability requirements for cannabis could be confirmed. The following is general industry practice, so confirm it with the destination regulator:
- Packaged batches in the real commercial packaging are stored at a defined temperature and humidity.
- A parallel set is stored under harsher conditions.
- Samples are tested at fixed intervals.
- The attributes that must stay within limits are decided in advance.
Real-time data takes real time. To claim a shelf life of a given number of months, you need that many months of data.
Translator’s note: Thai warehouses often run at 30–35 °C, which is harsher than the storage conditions a temperate buyer may assume. Data from your own storage conditions is therefore worth more than a promise.
What to do: From your first export-quality lot, keep sealed samples in the real packaging. Store them in your normal storeroom and log the temperature and humidity. Then you have real data when a buyer asks for a shelf life.
11. How contracts are structured
This section describes commercial practice, not regulation. Title (legal ownership of the goods) can pass at one of four points:
- at the farm gate
- after release
- at the port of departure
- only after the importer’s incoming tests
Each choice puts the risk of rejection on a different party. If ownership passes only after the importer’s tests, a failed test stays your loss.
A rejected batch cannot be sold locally or simply flown back. Re-export needs authorisations in both directions. Destruction needs supervision and a destruction certificate. The contract should state:
- who pays for storage while a dispute is open
- who pays for retesting, and at which laboratory
- who supplies the evidence of destruction
A failed shipment rarely costs only the goods. Add the freight, the importer’s handling and storage, and destruction or re-export. You also lose the time spent on the permit process and the share of the quota the shipment used.
Translator’s note: Bringing a rejected batch back into Thailand would also need Thai permission. This article could not confirm which permit applies, so ask the Thai authorities before you sign.
What to do: Before you sign, check that the contract says where ownership passes and covers the three questions above. Have a lawyer who knows cannabis export read it.
12. Common failure points
| Failure | Where it starts | Where it is caught |
|---|---|---|
| Microbial limits exceeded | Harvesting in humid weather, slow drying, poor hygiene, damp storage | The importer’s incoming test, after the freight is paid |
| Pesticide residues that your domestic tests do not cover | A product legal at home that the destination tests for, or drift from neighbouring fields | The destination laboratory, which tests for more substances |
| Gaps in the documents | Records filled in afterwards, deviations left open, batch numbers that ignore growing conditions | An audit or the release decision |
| Label in the wrong language or format | Assuming the destination accepts the exporting country’s label | Customs or the importer, before the goods reach a pharmacy |
| Expired or mismatched permits | Delays that outlast a permit, quantities that drift from the authorised figure | The border |
Translator’s note: Rice fields, orchards and vegetable plots next to a farm in Thailand may be sprayed during your crop. Their drift can show up in the destination laboratory’s wider test as a pesticide residue you never used. Talk to your neighbours about their spray timing. If you can, keep a buffer strip between their fields and your crop.
What to do: Before the first spray of the season, ask the buyer for the full list of substances the destination laboratory tests for. Compare it with every product you plan to use, including what your neighbours use.
13. Where Thailand stands today
How flower left the narcotics list
The Narcotics Code took effect on 9 December 2021. A Ministry of Public Health notification of 8 February 2022 removed cannabis from Category 5, the narcotics class cannabis had been listed in under Thai law. The exception was extracts above 0.2% tetrahydrocannabinol (THC) by weight. The notification took effect on 9 June 2022, and cannabis flower came off the narcotics list that day.
The forum topic on how Thai cannabis rules changed from 2022 to 2026 gives the full timeline.
The controlled-herb rules since 2025
The Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis), B.E. 2568 took effect on 26 June 2025. The Ministry of Public Health administers it. The Department of Thai Traditional and Alternative Medicine is the main enforcement agency. Sale requires a prescription.
Translator’s note: The 2025 notification was issued under the Thai Traditional Medicine Protection Act B.E. 2542 (1999). The prescription is the PT 33 (ภ.ท.33), valid for a maximum of 30 days. Advertising cannabis flower and selling it online are prohibited.
The most important rule for exporters: cannabis flower that is sold or exported must come from a GACP-certified cultivation site. Seed-to-sale records must cover:
- seed origin
- fertiliser logs
- pest-management reports
- harvest dates
- quality-control tests
Foreign ownership also matters. For extracts, the rule is in the note below. This article could not confirm the ownership rules for flower licences, so check them with a Thai lawyer.
Translator’s note: A separate regulation covers extracts. The Ministerial Regulation on Cannabis or Hemp Extracts B.E. 2569 took effect on 26 April 2026. Licences for extracts above 0.2% THC go only to three groups:
- Thai juristic persons that are not “foreign” under the Foreign Business Act B.E. 2542
- state agencies
- the Thai Red Cross Society
Export licence criteria since April 2026
Exporting cannabis flower needs a licence under section 46 of the Thai Traditional Medicine Protection Act B.E. 2542 (1999). The Ministerial Regulation on the Permission for Study, Research, or Export of Controlled Herbs, or Sale, or Processing of Controlled Herbs for Commercial Purposes (No. 2) B.E. 2569 was published in the Royal Gazette and took effect on 30 April 2026. It adds four criteria for anyone applying to export, sell or process cannabis flower commercially. An applicant must meet all four, and an application that fails any one is refused:
- Premises: you own the premises or have a right to possess them, or you have the owner’s written consent.
- Storage: a dedicated area, big enough to keep the flower in good condition. It must be separate from other materials and off the floor.
- Qualifying status: at least one of these:
- a hospital (sanatorium) licence
- a herbal product manufacturing or sales licence
- a drug manufacturing or sales licence
- a Category 5 narcotics licence for cannabis or hemp extracts
- folk-healer certification
- a cultivation site that supplies licensed buyers
- Trained staff: at least one employee trained by the Department of Thai Traditional and Alternative Medicine, present during all opening hours.
The same regulation requires an effective system for removing cannabis odour and smoke. Legal analyses of the text say that a past suspension for breaching the Ministry’s notifications counts against renewal and may lead to refusal. Check the Royal Gazette text if this applies to you. Existing licences stay valid until they expire, and the new criteria apply at renewal.
What this means for exporters: a trading company without one of the qualifying statuses cannot hold a flower export licence.
The Cabinet approved a draft Cannabis Control Act on 22 September 2026, and it is now before the House of Representatives. It is not in force, and there is no date for its passage.
What is still uncertain
The application routes and processing times for the section 46 export licence could not be confirmed, so none are given here. Thailand has no comprehensive cannabis act in force. Most of the framework still rests on ministerial notifications and regulations.
Whether a destination regulator accepts Thai GACP certification is a separate question. Meet the strictest standard your target market uses. Keep records that an inspector could read two years from now and still follow. Treat every permit as valid for one shipment only and for a limited time.
What to do: Check your business against the four criteria in this section before your licence comes up for renewal. If you lack a qualifying status, find out which one you could realistically get, and when.
Share what stopped your shipment
If you have exported or imported cannabis, other members learn most from what went wrong. Please post the details below this topic:
- What stopped your shipment: a microbial result, a residue that was not on your test list, a label, an expired permit, or a document you could not produce when asked?
- What do suppliers most often get wrong in the first document pack they send?
References
- European Medicines Agency: guideline on good agricultural and collection practice (GACP) for medicinal plants.
- EudraLex Volume 4 (EU GMP guidelines), including Annex 7 and Annex 16.
- Single Convention on Narcotic Drugs, 1961.
- Hazekamp A. Evaluating the effects of gamma-irradiation for decontamination of medicinal cannabis. Frontiers in Pharmacology, 2016; 7:108.
- Jerushalmi S, Maymon M, Dombrovsky A, Freeman S. Effects of cold plasma, gamma and e-beam irradiations on reduction of fungal colony forming unit levels in medical cannabis inflorescences. Journal of Cannabis Research, 2020; 2:12.
- Germany: medical cannabis law (in force 10 March 2017); Cannabis Act (in force 1 April 2024).
- Czech Republic: medical cannabis law (in force 1 April 2013); home-growing rules in force 1 January 2026.
- Thailand: Narcotics Code (in force 9 December 2021); Ministry of Public Health notification of 8 February 2022; Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis), B.E. 2568; Thai Traditional Medicine Protection Act B.E. 2542, section 46; Ministerial Regulation (No. 2) B.E. 2569 on controlled herbs; Ministerial Regulation on Cannabis or Hemp Extracts B.E. 2569; draft Cannabis Control Act (Cabinet approval 22 September 2026).
- Legal analyses of the Ministerial Regulation (No. 2) B.E. 2569 (not named in the original).
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.