Most failed export conversations fail on vocabulary rather than on price. A buyer asks for “EU-GMP flower” and receives a GACP certificate. A seller offers “0.2% THC hemp” and the lab at the other end reads 1.8%. An invoice says “CBD flower” and lands in a country where the word CBD is legal and the word flower is not. This article defines the terms that carry legal weight, says which agency issues each document, and flags where two markets use the same word to mean different things.
1. The plant and the parts
Cannabis (กัญชา) and hemp (กัญชง) in Thai law. Thai law has separated the two mainly by THC content. Hemp is the plant whose leaves and inflorescence carry no more than 1.0% THC by dry weight, a threshold set in the hemp framework under the Ministerial Regulation on Hemp B.E. 2563 (2020) (per Tilleke & Gibbins, Cannabis and Hemp Business Guide – Thailand, 2026, law-firm commentary). The 1.0% figure is unusually high by international standards. Older texts also split the two by subspecies (subsp. sativa for hemp, subsp. indica for cannabis). Treat that wording as historical, because the subspecies split is botanically disputed. Under Notification B.E. 2568, hemp inflorescence is a controlled herb whatever its THC level, so the 1.0% line does not take hemp flower outside the controlled-herb rules. Before relying on the 2563 definition, check its current text with the Thai FDA: it may have been affected by the 2568 notification and the 2569 regulations.
Inflorescence / flower / bud (ช่อดอก). The dried female flowering head. This is the single most important word in this glossary, because Thai law now regulates it by plant part, not by potency — see the entry for Controlled Herb below.
Mature stalk, fibre and seed. In most narcotics statutes worldwide — the UK Misuse of Drugs Act 1971 is the clearest example — these parts are carved out of the legal definition of cannabis, while flower and leaf are not (source: UK Home Office drug licensing factsheet). A market that permits “hemp” may permit only these parts.
2. THC: three numbers that are not the same number
Δ9-THC is the psychoactive molecule. THCA is its acidic precursor, which is what actually predominates in fresh dried flower. Total THC is the conventional combined figure, calculated as:
Total THC = Δ9-THC + (0.877 × THCA)
The 0.877 factor is the molecular-weight ratio after the loss of CO₂ during decarboxylation (standard analytical convention).
Why this matters commercially: a laboratory using HPLC runs near ambient temperature and reports THCA and Δ9-THC as separate peaks. A laboratory using GC injects at 250–300 °C, which decarboxylates THCA inside the instrument, so the “THC” it reports is partly an artefact of the method — and the conversion is incomplete and variable, so the number is neither native THC nor reliable total THC (source: NIST work on THCA decarboxylation in GC-MS quantitation).
The trap for an exporter: the EU’s official method for checking hemp varieties (Reg. 2017/1155) is GC-based and effectively reads total THC; national customs and narcotics labs in most member states also apply total THC. Expect a COA showing Δ9-THC 0.2% / THCA 1.8% to be treated as ~1.8%. The United States is scheduled to move to an explicit total-THC-including-THCA standard as well (effective date set for 12 November 2026 by the November 2025 amendment to the federal hemp definition; check current status) (per DLA Piper, law-firm commentary, November 2025). Assume total THC everywhere unless a regulator says otherwise in writing.
3. Thai regulatory terms
Controlled Herb (สมุนไพรควบคุม). A designation under the Protection and Promotion of Traditional Thai Medicine Knowledge Act B.E. 2542 (1999). The Notification of the Ministry of Public Health Re: Controlled Herbs (Cannabis) B.E. 2568, issued 26 June 2025, placed cannabis inflorescence in this category. Note the two things it is not: it is a notification, not an Act, and there is no “Controlled Herbs Act” — that name is a persistent error. Note also its scope: it is drawn by genus and plant part, and hemp flowers were caught by it from the same date (per Tilleke & Gibbins, law-firm commentary). Under the notification, flower may not be sold or advertised online or supplied for recreational use, and flower that is sold or exported must come from a GACP-certified cultivation site.
Section 46 licence. The licence under the 1999 Act permitting study, research, export, sale or processing of a controlled herb. This is the instrument a Thai flower exporter actually holds.
Ministerial Regulation (No. 2) B.E. 2569. The Ministerial Regulation on Permission to Study, Research or Export Controlled Herbs, or to Sell or Process Controlled Herbs for Commercial Purposes (No. 2) B.E. 2569, in force 30 April 2026 (source: Royal Gazette text as published by DTAM). It tightens licensing for flower export, sale and processing. Reported conditions include proof of the right to use the premises, dedicated storage that is segregated and kept off the floor, and a qualifying credential (hospital, herbal-product, drug-manufacturing or Category 5 narcotics licence, folk-healer certification, or a cultivation site supplying licensed buyers). They also include at least one DTAM-trained employee present during operating hours and an odour and smoke elimination system (per Juslaws & Consult, law-firm commentary). It does not change the PT 33 prescription rules.
Category 5 narcotic. Under the Narcotics Code, cannabis or hemp extracts exceeding 0.2% THC by weight sit here and require Thai FDA licensing. The Ministerial Regulation on Permission to Produce, Import, Export, Sell or Possess Category 5 Narcotics, Specifically Cannabis or Hemp Extracts, B.E. 2569 has been in force since 26 April 2026 (source: Thai FDA Narcotics Control Division). For commercial operators it limits these licences to Thai juristic persons that are not “foreign” under the Foreign Business Act. Government agencies and the Thai Red Cross Society are also eligible (per Mahanakorn Partners, law-firm commentary).
DTAM. The Department of Thai Traditional and Alternative Medicine, Ministry of Public Health. It certifies GACP and runs the staff training that, per the commentary cited above, Regulation No. 2 requires on site.
PT 33 (ภ.ท. 33). The controlled-herb prescription form. Flower may be dispensed only against a PT 33 from an authorised practitioner, for no more than 30 days per prescription. Each prescription can be used once only, with no refills.
Still a draft. The Cannabis Control Act is still a draft (Cabinet approved 22 September 2026, now before the House). The definitions here may change when it passes.
4. Quality standards — three acronyms, three different jobs
GACP — Good Agricultural and Collection Practices. An agricultural standard covering propagation material, cultivation, harvest, primary processing, storage and transport, plus the record-keeping underneath. It is issued in Thailand by DTAM. GACP is a farming standard. It says nothing about pharmaceutical manufacture.
GMP — Good Manufacturing Practice. A pharmaceutical manufacturing standard. EU-GMP is the European version, set out in EudraLex Volume 4, and an EU-GMP certificate is issued by a competent authority of an EU member state after inspection.
The confusion this glossary exists to prevent: GACP is not a lesser form of GMP, and holding GACP does not put a product one step away from GMP. They are different standards doing different jobs, and most medical markets require both — GACP up to the point of harvest, GMP from some defined step onward. Where that step sits differs by market, and it is the most expensive detail in the whole trade. A separate forum article covers it.
PIC/S. The Pharmaceutical Inspection Co-operation Scheme. Thailand acceded on 1 August 2016 (source: PIC/S). PIC/S membership is a framework for co-operation between inspectorates; it is not automatic mutual recognition of certificates. Thailand is also absent from the European Commission’s Article 111b list of third countries whose GMP supervision is treated as equivalent for active-substance imports (source: European Commission list, checked September 2026).
Ph. Eur. Cannabis flos. The European Pharmacopoeia monograph for cannabis flower, published in Supplement 11.5 and official from 1 July 2024 (per ECA Academy). It specifies identification, chromatographic assay, chemotype classes, foreign matter, loss on drying (max 12.0%), elemental impurities, pesticides, aflatoxin B1 and microbiological limits. If a buyer says “Ph. Eur. compliant”, this is the document they mean.
5. Trade and customs documents
COA — Certificate of Analysis. A laboratory report tied to a specific batch. For export purposes it should state the method, not just the result. Testing is covered in more detail in a separate forum article.
ISO/IEC 17025. The accreditation standard for the competence of a testing laboratory. It is not a cannabis product standard, and accreditation is granted for a defined scope — a laboratory accredited for food chemistry is not thereby accredited for cannabinoid assay. Always ask for the scope certificate, not the accreditation logo.
Phytosanitary certificate. Issued by the national plant protection organisation, attesting plant-health status for a specific commodity and a specific destination’s requirements. It is commodity- and destination-specific, and for controlled goods it does not substitute for narcotics documentation.
Import certificate and export authorisation. The paired system under Article 31 of the Single Convention on Narcotic Drugs, 1961. The importer’s national authority issues an import certificate first. The exporter presents that certificate to their own authority to obtain an export authorisation. A copy of the authorisation must accompany the consignment, and the importing government endorses and returns it with the quantity actually received (source: UNODC text of the 1961 Convention; INCB, Controls on International Trade in Narcotic Drugs). The Convention requires the export authorisation to accompany the consignment; national authorities detain shipments that arrive without one.
HS code. The Harmonized System customs classification. Dried cannabis flower is commonly declared under 1211.90 (plants and parts of plants used primarily in perfumery or pharmacy, other); extracts under 1302.19; cannabis medicaments under 3004.90; true hemp fibre under 5302.10 (source: Statistics Canada published cannabis classification, which is the clearest public mapping). Two warnings: national subheadings differ, and a correct HS code does not confer legality — narcotics control applies at the border regardless of tariff classification.
Novel Food. An EU food-law status under Regulation (EU) 2015/2283. CBD in food requires authorisation; as of 2026 none has been granted, and EFSA issued only a provisional safe-intake figure in February 2026 (source: EFSA, February 2026). Novel Food is food law only — it does not reach cosmetics, and a smokable flower is not a food at all, which is why flower bans are written into narcotics or tobacco law instead.
MRL — maximum residue limit. The permitted pesticide residue. For medical flower, the binding pesticide limits are those of Ph. Eur. 2.8.13 applied through the Cannabis flos monograph; food MRLs under Reg. 396/2005 matter mainly for hemp food products. Under the food regulation, a pesticide with no specific limit generally falls to a default of 0.01 mg/kg. That is far below what a farm used to food-crop limits will expect.
6. Two words that mean different things in different rooms
“Hemp”. In Thailand, a plant with ≤1.0% THC — and its flower is still a controlled herb. In the EU, an agricultural variety below 0.3% THC since 1 January 2023 (source: European Commission). In Switzerland, cannabis below 1.0% average total THC falls outside the Narcotics Act entirely (per CMS expert guide, law-firm commentary). Czech law sets 1.0% in dry matter. A shipment that is lawful hemp in Bangkok is not automatically lawful hemp in Berlin.
“Pharmaceutical grade”. Not a legal term anywhere. It usually means either “the batch met a pharmacopoeial monograph” or “the site holds a GMP certificate”. Ask which, and ask to see the document.
For members who have completed licensed exports or imports: which term caused the most confusion — GACP vs GMP, total vs Δ9-THC, or the permitted product form? Please share only lawful, licensed transactions.
Related reading: the forum articles on the two export tracks and on where the GMP step must physically happen; and the forum topic on what GMP actually means for medical cannabis (topic #1359).
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 frequently and differs by country; several of the figures cited come from professional commentary rather than from primary legislation, and are flagged as such in the text. Verify every point with the competent authority and with a qualified lawyer in the relevant jurisdiction before entering into any transaction.