Two ministerial regulations took effect in Thailand across April 2026, and together they represent the most consequential structural change to the country's cannabis licensing framework since cannabis was removed from the narcotics list in 2022. If you are a cultivator supplying an export-focused buyer, a foreign investor in the Thai cannabis space, or an international company with a Thai supply chain partner, these regulations change the operating environment in ways that require immediate review.
Neither regulation received significant international coverage when it took effect. The first was overshadowed by domestic news about dispensary closures. The second was framed primarily as a retail regulation. Both affect export operations directly.
Regulation 1: The Extract Regulation (Effective April 26, 2026)
The Ministerial Regulation on permission to produce, import, export, sell or possess Category 5 narcotics, specifically cannabis or hemp plant extracts, B.E. 2569 (2026), was published in the Royal Gazette on March 26, 2026 and came into force 30 days later on April 26. It replaces the 2021 extract regulation that had governed high-THC extract production and trade since cannabis was partially liberalized.
The 2021 regulation limited extract use to medical cannabis only. The 2026 regulation expands the permissible purposes to four: medical use, research, industrial use, and official narcotics suppression activities. On the surface this looks like a liberalization. In practice, the conditions attached to each permitted purpose are substantially more restrictive than what the 2021 framework required, and one provision fundamentally reshapes who can operate in this space.
Foreign-owned entities are excluded from extract production
Applicants seeking permission to produce cannabis or hemp extracts for medical purposes must be juristic persons that are not foreign businesses under Thai law. This is a hard exclusion, not a preference or a threshold. Foreign Business Act classification determines who qualifies. A company with majority Thai ownership that operates under a Foreign Business License for other activities may still be ineligible depending on how that license is structured.
This matters for international cannabis companies that have established or are considering Thai subsidiaries as part of an extract supply chain. The structure you use to enter the Thai market now determines whether you can legally be a producer of high-THC extracts, regardless of the quality of your facility or the strength of your export relationships.
Foreign entities can still participate as buyers, importers, logistics providers, and compliance partners. They cannot hold the production license for high-THC extracts.
Existing licenses expire December 31, 2026
Licenses issued under the 2020 and 2021 regulations remain valid until December 31, 2026. After that date, all operators must hold a license under the 2026 framework. Renewal is not automatic; it is a full re-qualification under the new criteria, including the foreign ownership assessment.
For Thai operators currently supplying international buyers under extract-based contracts, this creates a license renewal cliff at the end of 2026. If your Thai supply partner has not begun the re-qualification process, their ability to legally produce and export after December 31 is at risk. This is not a theoretical concern. Regulatory re-qualification in Thailand routinely takes four to six months when documentation is in order. If it is not in order, longer.
Regulation 2: The Controlled Herbs Amendment (Effective April 30, 2026)
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 on April 30, 2026 and took immediate effect. It amends the 2559 (2016) controlled herbs regulation that has governed cannabis flower since cannabis bud was reclassified as a controlled herbal substance in June 2025.
The amendment does not create a new licensing regime. It overlays cannabis-flower-specific requirements on top of the existing controlled herbs framework. The practical effect is that a cannabis flower export license now carries additional conditions that do not apply to other controlled herbs.
What changed for flower exporters
The amendment establishes that export licenses for cannabis flower require the applicant to demonstrate supply chain traceability from cultivation through processing and packaging. GACP-aligned cultivation practices are referenced as the baseline standard. Cultivators supplying export-licensed processors inherit the compliance obligations of their buyers through the supply chain. If a licensed exporter holds a GACP-certified supply contract, their upstream cultivator partners must be capable of demonstrating GACP alignment on inspection.
Foreign-owned entities are also excluded from the extract production track under this regulation, consistent with the April 26 regulation. For the flower track specifically, foreign ownership restrictions apply to processing and packaging operations, not to cultivation itself, though this distinction requires careful legal analysis for any specific corporate structure.
Existing licenses under the pre-amendment framework continue until their original expiry dates. However, renewal applications filed after April 30 are evaluated under the amended standard. Any cultivator or processor whose license comes up for renewal in the second half of 2026 is now subject to the new requirements.
What the Cannabis and Hemp Act Would Change
Both April regulations operate under existing ministerial authority. A third, more fundamental change is in the pipeline. The Cannabis and Hemp Act, Thailand's first standalone legislation specifically governing the cannabis industry, is in its final pre-parliament consultation phase as of June 2026. If parliament passes the act before the end of 2026, it will supersede the ministerial regulations and create a statutory framework with legislated penalty levels, defined ownership rules, and clearer export pathways.
The timeline is uncertain. Thai legislative processes move slowly and the cannabis industry has significant political complexity attached to it since the 2022 decriminalization and subsequent reversal. The ministerial regulations in force as of April 2026 are the operative rules until the act passes, if it passes in its current form.
Operators building Thai supply chains should not plan around the act passing on any particular schedule. Plan around the April 2026 regulations as the stable operating environment, and treat the Cannabis and Hemp Act as a potential upside scenario that may simplify the framework in 2027 or later.
What This Means for International Buyers
International buyers sourcing from Thailand need to verify three things with their Thai supply partners before placing orders against post-December 2026 delivery commitments.
First, confirm the Thai partner's current license type and expiry date. Licenses under the 2020 and 2021 frameworks expire December 31, 2026. A supply contract that extends beyond that date requires the Thai partner to successfully complete re-qualification under the 2026 framework before the expiry.
Second, confirm ownership structure. Foreign-owned entities cannot hold extract production licenses under the April 26 regulation. If your Thai supply partner has any foreign ownership, confirm that their license qualification has been reviewed by Thai legal counsel under the new framework.
Third, confirm GACP supply chain traceability. Under the April 30 amendment, export licenses for flower now require traceability documentation from cultivation through packaging. If your buyer audit requirements include GACP documentation, verify that the Thai exporter can provide a full chain of custody, not just their own facility certification.
What This Means for Thai Cultivators and Processors
Thai operators in the export chain have a specific action window before December 31, 2026. Re-qualification under the 2026 framework requires the same documentation discipline that EU-GACP and EU-GMP compliance requires: SOPs, validated processes, traceability records, and staff training documentation. Operators who have already built compliance infrastructure for international buyers are better positioned for re-qualification than those who have been operating under looser domestic-market standards.
Operators who have not started GACP alignment should treat the December 2026 license expiry as a forcing function. The re-qualification process and GACP readiness work can be run in parallel. Waiting until Q3 or Q4 of 2026 to begin either creates material risk of a gap in legal production authorization at the end of the year.
DeeMED's medical cannabis export consulting team works with Thai cultivators and manufacturers on GACP readiness, EU-GMP compliance, and the licensing and documentation work required to maintain export-ready status under Thailand's evolving regulatory framework. If you have questions about how the April 2026 regulations affect your specific operation or supply chain, reach out directly.
Sources
- Royal Gazette of Thailand, Ministerial Regulation on permission to produce, import, export, sell or possess Category 5 narcotics, specifically cannabis or hemp plant extracts, B.E. 2569 (2026), published March 26, 2026, effective April 26, 2026
- Royal Gazette of Thailand, 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, published and effective April 30, 2026
- Asian News Network, Thailand's new cannabis-hemp extract rules take effect, limiting use to four purposes, April 29, 2026
- Cannabis Law Report, Thailand Cannabis Law Update: Two New Regulations Now in Force (May 2026)
- JusLaws, New Thailand Cannabis Law Published on April 30, 2026: Ministerial Regulation No. 2 B.E. 2569
- AIM Bangkok, Thailand Cannabis Business: Licenses, Compliance and Legal Guide 2026
