International GMP Certificates Thai FDA Will and Will Not Accept

A foreign supplement manufacturer does not need a Thai GMP certificate to sell into Thailand. What it needs is a certificate that demonstrates equivalence to Thailand's own food production standard, and the paperwork that demonstration requires changed materially in November 2024. Manufacturers submitting the wrong type of certificate, or the right certificate in the wrong format, can find an otherwise complete product approval file stalled at the very first review stage, often for reasons that have nothing to do with the underlying quality of the manufacturing site itself.

What "equivalence" actually means under No. 420

Thai FDA's requirement for imported food supplements is that the foreign manufacturing site runs a food production management system equivalent to, or not inferior to, the standard set by MOPH Notification No. 420 B.E. 2563 (2020), the general Codex-based GMP framework for Thai food premises. This is sometimes confused with MOPH Notification No. 386 B.E. 2560 (2017), but the two are separate, differently-scoped instruments, not predecessor and successor: No. 386 is a narrower GMP standard specific to fresh fruit and vegetable packing houses, not a general equivalence standard relevant to supplement manufacturers. It is worth being precise about the wording here: the requirement is not that the factory holds a Thai GMP certificate specifically. The requirement is demonstrated equivalence to the Thai standard, which is a different and, for most manufacturers, more achievable bar.

No. 420 is Thailand's broadly applicable GMP framework for food production, and its core requirements track familiar ground for any manufacturer already operating under an internationally recognized food-safety system: premises and equipment condition, cleaning and sanitation protocols, pest control, personnel hygiene, production process controls, and quality management documentation. A foreign site already certified to a recognized international standard is, in most cases, already covering the substance of what No. 420 asks for.

Thai FDA explicitly lists which certifications qualify as accepted equivalents: GMP under Thai law itself, Codex Alimentarius GMP, HACCP, the ISO 9000 series, ISO 22000, FSSC 22000, BRCGS, GlobalG.A.P., and SQF. A manufacturing site holding current certification to any of these from a recognized accreditation body starts from a strong position, provided the certificate is current and submitted in the format Thai FDA now requires.

The November 2024 change to how certificates get submitted

On 27 November 2024, Thai FDA issued an updated notification governing the documents and certificates required for food production system standards on imported food, replacing the version that had been in force since 19 April 2021. The revision changed how GMP certificates need to be submitted, and the change is a meaningful one for manufacturers who had gotten used to the older process.

Before the change, every GMP certificate required a certified or notarized copy accompanying the submission, regardless of the certificate type. This added real cost and delay, particularly where a manufacturer's certifying body was not physically accessible for notarization purposes, which was a routine problem for manufacturers outside the region.

Since the change, certificates that can be verified online no longer require certified or notarized copies at all. The condition is that the online record has to display the standard name, the certified facility's name and address, the scope of certification, the certification dates or current status, and the name of the issuing body. Certificates verifiable through the standard owner, an accreditation body, a certification body, or the International Accreditation Forum meet this bar; FSSC 22000, BRCGS, and GlobalG.A.P. are common examples that typically qualify. A certificate from a certifying body with no online verification mechanism does not benefit from the reduced documentation requirement, and manufacturers in that position still need to prepare certified or notarized copies the way they always did.

Why certificate validity through the review window matters more than the submission date

An expired GMP certificate can stop an otherwise complete product approval file cold. Thai FDA requires the certificate to be current at the moment of submission, and it needs to stay valid through the entire review period, not just the day the file goes in. Supplement product approval reviews typically run several weeks to several months, which is enough time for a certificate that was current at submission to lapse before the review concludes.

This is a coordination problem between the manufacturer and the importer as much as it is a documentation problem. A certificate renewal scheduled for November on a file submitted in October is a genuine timing risk if the review runs long. The safer practice is confirming GMP renewals at least 3 months ahead of any submission deadline that depends on them, and tracking expiry against the full expected review window rather than just the submission date itself.

Why the online-verifiability distinction catches manufacturers off guard

The most common mistake manufacturers make after the November 2024 change is assuming the certificate type alone determines whether notarization is required, without checking whether their specific certifying body is actually reachable through an online verification route. Two manufacturers can both hold current FSSC 22000 certification, for example, and still land in different documentation categories if one certifying body publishes verifiable online records through the International Accreditation Forum and the other does not maintain an equivalent public record. This is a detail that sits with the certification body rather than the underlying standard, which means the manufacturer's own quality or regulatory team often has to check directly with their certifying body about how, and whether, their specific certificate can be verified online before assuming the lighter documentation path applies.

Manufacturers working with a certification body that does not offer online verification are not disqualified from the Thai market; they simply fall back to the pre-November 2024 process of certified or notarized copies. The practical implication is scheduling: notarization takes time to arrange, particularly across time zones and jurisdictions, so a manufacturer in this position needs to build that lead time into the submission timeline from the outset rather than discovering the requirement once the file is already being assembled.

Getting the certificate right before the file goes in

The certificate review belongs at the start of the process, not somewhere a manufacturer discovers a problem after a Thai FDA reviewer flags it. That means checking the manufacturer's GMP certificate against the No. 420 equivalence standard, confirming the certifying body actually qualifies under the November 2024 notification, and verifying online verifiability before the submission is built around it. A certificate that requires notarization slows down a file that a verifiable certificate would not, and that difference is entirely avoidable with the right check done early. DeeMED Consulting reviews manufacturer GMP certificates against the No. 420 standard as part of our Thai FDA supplement GMP requirements consulting, so certificate format and validity are confirmed before a product file is submitted, not after it stalls.