A business licensed to sell cannabis flower in Thailand has duties that continue for as long as it holds the licence. It must keep records of where its flower came from (PT 27) and where it went (PT 28). It must match every sale to a PT 33 prescription, keep a trained person on duty during opening hours and keep its records ready for inspection at any time during opening hours. Under DTAM’s enforcement guideline, missing or incomplete PT 27/PT 28 records can lead to a 30-day suspension.
Who these duties apply to
Cannabis flower is a controlled herb under the Thai Traditional Medicine Protection Act B.E. 2542 (1999). Selling or processing it as a business requires a licence under that Act. Since 30 April 2026, the Ministerial Regulation on Controlled Herbs (No. 2) B.E. 2569 has made the criteria for a flower licence stricter. The forum topic on the two B.E. 2569 regulations explains what changed.
The duties below apply mainly to shops, clinics and pharmacies that sell flower.
The three core records
| Record | What it shows | What each entry needs |
|---|---|---|
| PT 27 (ภ.ท.27) | Where your flower came from | Enough detail to trace each incoming batch to its source |
| PT 28 (ภ.ท.28) | How your flower was used or sold | Date, batch and quantity of each sale or use |
| PT 33 (ภ.ท.33) | The prescription behind each sale | Patient details, prescribed quantity and duration (no more than 30 days) |
You also need two supporting records. The first is a stock log. The second is a set of batch records, which show the production batch that each sale came from.
Write each entry when the event happens. Never fill in entries afterwards and backdate them. Under DTAM’s enforcement guideline, not keeping PT 27/PT 28 records at the premises, or keeping incomplete ones, can lead to a 30-day suspension.
Reports and retention. Send a report to the licensing authority every month, within one month after the end of the month. The licensing authority is DTAM in Bangkok and the provincial public health office elsewhere. DTAM has said the PT 27/PT 28 reports can be sent through an online system or by e-mail. Keep PT 33 prescriptions at the place where you dispense for at least 1 year. Keep your accounts and supporting records for at least 3 years, ready for inspection during opening hours.
Thai conditions. Paper ledgers get damp in the rainy season, and floods can destroy a whole shelf of files. Every week, photograph or scan each finished page and keep the copy away from the shop. If the original is damaged, you can still show what was recorded.
Matching sales to prescriptions
Two checks keep your records consistent. Inspectors run the same two checks.
- Every sale has a prescription. On each sale line in the PT 28, write the PT 33 number. File the prescriptions in the same order as the PT 28. This lets you find any sale’s prescription in seconds.
- The stock balances. Take your opening stock, add what you received (PT 27) and subtract what you sold or used (PT 28). The result must equal the amount on the shelf. Count the stock every week. If the numbers differ, find the reason straight away. Inspectors may treat an unexplained difference as possible false reporting.
Each PT 33 covers at most 30 days of supply. Before you dispense, check the prescription date, the quantity and the signature. Never accept a prescription that has been signed but left blank. The topic on blank-signed PT 33 prescriptions explains why.
In September 2025, DTAM said it was developing a system to link PT 27, PT 28 and PT 33 data to a central database. It gave no start date. Until any electronic system is in force, the two manual checks above are your proof that you sold only against prescriptions.
Who must be on duty, and which qualifications count
DTAM is the Department of Thai Traditional and Alternative Medicine, part of the Ministry of Public Health. Under the April 2026 rules, each type of premises needs a supervising professional:
- a clinic: a physician, pharmacist, dentist, Thai traditional medicine practitioner, applied Thai traditional medicine practitioner or Chinese medicine practitioner
- a pharmacy: a pharmacist
- a herbal product shop: a Thai traditional medicine practitioner, applied Thai traditional medicine practitioner or Chinese medicine practitioner
- a folk healer’s practice site: a certified folk healer
In addition, at least one staff member must have completed a medical cannabis course certified by DTAM. A trained staff member must be present at the premises during all opening hours.
The certificate belongs to the person, not to the shop. If that person is absent, the shop must stay closed until another qualified person arrives. There is no grace period. Keep certified copies of all certificates at the counter, so inspectors do not have to rely on a photo on a phone.
How an inspection runs
Inspectors may visit at any time during opening hours, and your records must be ready for them. There are no official statistics on how often visits happen.
Operators report that inspectors check things in this order:
- the current licence, displayed where it can be seen from the entrance
- a qualified person on duty, with a certificate or licence to show
- a dedicated, labelled, locked storage cabinet, off the floor
- PT 27 and PT 28 records, compared against a count of the shelf
- PT 33 records, with a sample of entries compared against the PT 28
- the same address on every document
None of these six problems can be fixed while the inspector is in the shop.
If the inspector finds a violation, you receive a written notice (หนังสือแจ้ง). It names the rule you broke. It states the action, such as a suspension or revocation. DTAM’s enforcement guideline sets suspensions of 30 to 90 days, depending on the breach. Under Section 52 of the 1999 Act, each order can suspend a licence for up to 90 days. Under Section 70, you can appeal within 30 days of being notified, but the order still applies while the appeal is pending. The forum’s penalty map covers suspension, revocation and appeals in detail.
Renewal works like a full inspection, because the authority checks you against today’s criteria. Licences issued before the April 2026 rules stay valid until they expire, but renewal must meet the new rules in full. For renewal timelines, staff planning and a full routine calendar, see Running a Cannabis Dispensary in Thailand Without Losing Your Licence.
What to do this week
- Run the six-point check yourself, in the order above. It shows you what an inspector would find today, while you can still fix it.
- Write the PT 33 number on every PT 28 sale line from today. Matching any sale to its prescription then takes seconds.
- Count your stock and balance it against the PT 27 and PT 28. A difference found now can still be explained and corrected.
- Name two qualified people for every opening day on the roster. One absence will then not force you to close or break the rules.
- Scan this week’s record pages and store the copies away from the shop. A flood or leak will then not wipe out your history.
If you have a question about PT 27, PT 28 or PT 33 records, or you have been through an inspection, post it in the replies below this topic.
References
- Thai Traditional Medicine Protection Act B.E. 2542 (1999), Sections 52 and 70.
- Ministerial Regulation on licensing for research, export, sale and processing of controlled herbs, B.E. 2559 (2016). Royal Gazette, vol. 133, part 103 Kor, 9 December 2016.
- Ministerial Regulation on Controlled Herbs (No. 2) B.E. 2569. In force 30 April 2026.
- Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis), B.E. 2568. In force 26 June 2025.