Navigating Global Cannabis Compliance: Thai GACP, EU-GACP, CUMCS, Thai GMP, and EU-GMP

Part I: The Standards Explained — GACP, GMP, GDP, and What Thai Exporters Need to Know

The global cannabis trade is expanding rapidly, and Thailand is positioning itself as a key player. However, entering regulated markets like Europe and Australia requires strict compliance with international quality standards. Thai growers and manufacturers must navigate a web of certifications, from Good Agricultural and Collection Practices (GACP) to Good Manufacturing Practices (GMP), to meet the demands of overseas buyers.

This series provides an in-depth look at Thai GACP, EU-GACP, CUMCS, Thai GMP, EU-GMP (Parts I and II), and related certifications. It distinguishes fact from hearsay, examines the current Thai market landscape, outlines what Thai farms and manufacturers need to work with global partners, and discusses the future outlook for Thailand's cannabis industry. Part II covers how deals actually get done, export timelines, and the future of Thailand as an international supplier.

GACP for Cultivation: Thai GACP vs EU-GACP vs CUMCS

Good Agricultural and Collection Practices are guidelines ensuring that medicinal plants, including cannabis, are cultivated and harvested under high-quality, safe conditions. GACP compliance is the foundation for entering pharmaceutical supply chains: any raw material used in medicines in markets like the EU must follow GACP.

Thai GACP

Thai GACP is Thailand's national standard for medical cannabis cultivation, certified exclusively by the DTAM under the Ministry of Public Health. As of June 2025, Thai law mandates DTAM GACP certification for all commercial cannabis cultivation supplying flower for sale or export. Thai GACP covers soil and water quality, input and pesticide controls, worker hygiene and training, seed-to-sale documentation and traceability, harvest and storage conditions, and regular product testing. Certificates are valid for 1 to 3 years with annual surveillance inspections. The process typically takes 90 to 180 days depending on preparedness.

EU-GACP

EU-GACP refers to compliance with the EMA's guideline on good agricultural and collection practices for herbal starting materials (EMA/HMPC/246816/2005 Rev. 1). The EMA states that GACP is "the first step in quality assurance, on which safety and efficacy of herbal medicines directly depend," and that "the cultivation, production and primary processing of the medicinal plant has a direct influence on the quality of the active pharmaceutical ingredient (API) used in herbal preparations." Thai growers targeting Europe must implement cultivation practices covering detailed environmental monitoring, documented use of fertilizers and plant protection products, defined and controlled post-harvest handling, and clear segregation and traceability of batches. While Thai GACP and EU-GACP are conceptually aligned, Thai GACP certification alone may not satisfy European importers, particularly where documentation expectations and enforcement rigor differ. For those targeting Europe, pursuing an internationally recognized third-party audit is the key step to building real trust with EU buyers.

CUMCS (Control Union Medical Cannabis Standard)

CUMCS-GAP is, according to Control Union, "globally the leading certification standard for medical cannabis certification." Control Union states that "the scope of CUMCS-GAP covers medical Cannabis propagation, cultivation and post-harvest processes and is fully compliant with both the WHO and EMA GACP guidelines." Certified farms receive both a CUMCS-GAP certificate and a formal GACP compliance certificate covering both WHO and EMA standards. It provides a formal certificate confirming compliance with WHO and EMA GACP, and is widely regarded by European and Australian buyers as strong independent export-readiness proof that a facility meets their minimum expectations. For Thai growers, obtaining CUMCS serves as the independent verification that EU buyers need to trust a Thai supply relationship.

GMP for Processing: Thai GMP vs EU-GMP

After cultivation, cannabis destined for medical markets often undergoes processing: drying and trimming flower, extracting oils, or formulating finished medicinal products. GMP is a system of strict, documented protocols ensuring products are consistently produced and controlled according to quality standards.

Thai GMP

Thailand's GMP standards are governed by the Thai FDA and are aligned with international norms. As PIC/S confirmed in its official announcement, "On 1 August 2016, Thailand's Food and Drug Administration (Thai FDA) became the 49th PIC/S Participating Authority," aligning its pharmaceutical GMP inspections with regulators including the US FDA, EMA, MHRA, and TGA. Any Thai facility manufacturing cannabis oil, extracts, or other medical cannabis products must hold a Thai GMP license. Thai GMP covers quality management systems, cleanroom and controlled production environments, SOPs, personnel training and hygiene, equipment qualification and calibration, documentation, and in-process and finished-product testing. While Thai GMP is necessary for domestic legality, overseas importers in the EU and Australia typically require that manufacturing sites comply with their own GMP standards or hold a GMP certificate recognized by their authorities.

EU-GMP: Parts I and II

EU-GMP requirements, defined by EudraLex Volume 4, are widely considered the global gold standard for pharmaceutical manufacturing. EU-GMP has two main parts relevant to cannabis:

• Part I covers finished medicinal products.
• Part II covers active substances (APIs), harmonized with ICH Q7.

In practice, a Thai facility exporting dried flower or crude extract to be further processed in the EU may focus on EU-GMP Part II compliance. A Thai facility manufacturing finished bottled oils or other dosage forms requires EU-GMP Part I compliance. Some importing countries, including Germany, may require that even dried flower intended for pharmacy dispensing be produced under EU-GMP conditions, making a Part I or hybrid API approach necessary.

Australian GMP (TGA Standards)

The TGA expects imported cannabis medicines to be manufactured under GMP standards equivalent to its own PIC/S-aligned framework. Compliance generally requires manufacturing in a GMP-certified facility the TGA recognizes (directly or through EU-GMP equivalence), compliance with Therapeutic Goods Order 93 (TGO 93), compliant labeling and packaging, and supporting documentation with batch-level test results. Obtaining EU-GMP often goes a long way toward satisfying Australian requirements given the similarity in rigor between the two frameworks.

Other Key Certifications

ISO/IEC 17025 for Laboratories

Any laboratory conducting quality testing on cannabis should be accredited to ISO/IEC 17025. Importing countries generally trust certificates of analysis only from accredited laboratories. Having an ISO 17025-accredited laboratory test each batch is a practical prerequisite for import clearance abroad. It demonstrates that analytical methods are validated and results are reliable and traceable.

GDP for Distribution

Good Distribution Practices cover proper handling, storage, transportation, and documentation of pharmaceutical products throughout the supply chain. For cannabis exports, GDP-aligned distribution ensures proper storage conditions including temperature and humidity control where relevant, security and chain-of-custody, accurate movement records, and tamper-evident packaging. EU importers expect GDP conditions between the GMP facility and the EU port of entry.

Thailand's Cannabis Market Today

Today's Thai cannabis market is the result of rapid expansion followed by regulatory correction. In June 2022, decriminalization triggered a quasi-recreational boom with thousands of shops and small-scale cultivators. By 2025, the government had shifted firmly back toward a medical-only, controlled model. As of late 2025, only 149 out of over 11,800 legacy-licensed operators held DTAM GACP certification, illustrating the substantial gap between aspiration and compliance reality. Operators building toward EU-GACP, EU-GMP, and GDP compliance are building toward the only sustainable commercial outcome: long-term relationships with verified international buyers who require and audit those standards consistently.

DeeMED Consulting works with both international buyers and Thai producers to bridge the gap between regulatory theory and on-the-ground operations, supporting farms and manufacturing sites through Thai GACP, EU-aligned GACP, and GMP audit preparation via gap analyses, SOP development, and implementation support.

This article was originally published on LinkedIn on December 3, 2025. Read the original post ↗