DTAM Ministerial Regulation No. 2 B.E. 2569: what changed for Thai medical cannabis export in 2026

Why this matters before any spec sheet

Anything written about Thai medical-cannabis export before May 2026 is now legacy reading. On 30 April 2026 the Royal Gazette (Volume 143, Part 28 ก) published 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. It took effect on 1 May 2026 — and it materially narrows the field of Thai operators legally permitted to export cannabis flower.

If you are an Australian importer evaluating a Thai supplier right now and the conversation has not covered their licence status under B.E. 2569 specifically, that conversation is missing. Existing licences from the prior B.E. 2559 framework remain valid only until their natural expiry, and renewals must clear a tighter bar. The supplier you sign today may have a different paperwork picture in 6 to 12 months — and your importer's compliance team will be the one who has to live with that.

What B.E. 2569 actually does

The regulation narrows scope to a single plant part: the cannabis inflorescence — the flower — and to the activities the regulator now controls around it. Three things change at once:

1. DTAM is the issuing authority. The Department of Thai Traditional and Alternative Medicine, sitting under the Ministry of Public Health, is now the body that issues and approves licences for export, commercial sale, and processing of cannabis flower. Article 13(1) names DTAM as the approver.
2. Sale is prescription-only. Cannabis-flower sale to end-users requires a prescription. Standalone dispensaries without health-sector credentials are no longer permissible.
3. Export is gated to six qualifying statuses. Only operators in one of six defined categories may apply for export licences. This is the section that materially affects every foreign importer's due-diligence checklist.

For readers unfamiliar with Buddhist Era dating: B.E. 2569 corresponds to CE 2026, and B.E. 2559 referenced in Article 8 corresponds to CE 2016, when the prior cannabis framework was promulgated.

The six qualifying statuses for export

An applicant for a cannabis-flower export licence under B.E. 2569 must hold at least one of the following statuses:

1. Hospital operating licence under the Sanatorium Act.
2. Herbal product manufacturing or sales licence.
3. Drug manufacturing or sales licence.
4. Category 5 narcotics manufacturing licence, covering cannabis and hemp extracts.
5. Folk healer certification.
6. Cultivation site supplying licensed buyers.

For an Australian distributor's RA team auditing a Thai supplier, the most common status the supplier itself will hold is category 6 — they grow, and they sell to a licensed downstream party that holds one of categories 1 to 4 for the destination market. The chain matters: a category 6 supplier without a documented downstream relationship has not satisfied the framework on their own.

What's new in the bar

Every applicant — and every renewal — must satisfy four further criteria the prior B.E. 2559 framework did not enforce:

• Premises control. Ownership or documented possessory rights in the cultivation or processing premises. Leased premises require the owner's written consent on file.
• Storage discipline. A storage location segregated from the rest of the operation, elevated off the floor, sized appropriately for the volume held, with equipment to maintain product quality.
• DTAM-trained staff present during operating hours. At least one staff member who has completed DTAM training must be on the premises whenever the establishment is open.
• Effective odour and smoke elimination. A documented system, not an aspiration.

Renewals must re-satisfy all four. Any prior suspension automatically blocks renewal.

The Article 8 grandfather rule

Article 8 of B.E. 2569 preserves continuity for operators with prior paperwork: a licence issued under the B.E. 2559 framework shall continue in force until its expiry. Pending applications filed under the prior framework are processed under the new rules, with applicants permitted to supplement their files.

The practical consequence for foreign importers: a Thai supplier offering material into Australia or Europe in 2026 may legitimately be operating under either a still-valid B.E. 2559 licence or a freshly-issued B.E. 2569 licence. Both are valid; the audit profile is slightly different. The single most useful question to ask is which one, and when it expires.

What an Australian importer should verify

For an Australian, German, Israeli, or Swiss importer evaluating a Thai-origin supplier under the new framework, ask for:

1. The supplier's current cannabis-flower export licence — issued under B.E. 2559 or B.E. 2569, with issue date, expiry date, and the qualifying-status category.
2. The DTAM-trained staff roster — names and training certificates for the staff member(s) present during operating hours.
3. Premises documentation — ownership or lease evidence, with consent on file if leased.
4. Storage compliance evidence — segregation, elevation, sizing, monitoring equipment.
5. Odour-control system documentation — manufacturer, capacity, maintenance logs.
6. The supplier's TH-GACP certificate. See our companion brief on TH-GACP; the two frameworks sit alongside, not in replacement of one another.

If the supplier has ever been suspended, the renewal pathway is closed — substantial enough that the question is worth asking directly.

Why this matters commercially

B.E. 2569 narrows the field of Thai exporters whose paperwork a foreign importer can audit confidently. That is a quality signal, not an obstacle. The Thai operators who will not clear the new bar are not the operators you want supplying material into your Australian TGA-licensed channel or your German BfArM and Bundesopiumstelle pipeline.

For procurement directors who run a real supply-chain audit, the framework simplifies the question: which of the six categories does the supplier hold, and is their licence current. Two facts, easy to verify, dispositive.

Talk to us

If you want to walk through our licence-stack position under B.E. 2569, the simplest path is a short WhatsApp conversation followed by the documents packet. We don't ask for an LOI before sharing licence references, DTAM training records, and TH-GACP certification, because the patient at the end of this supply line is the only stakeholder who can't ask the question themselves, and we would rather you have the evidence to ask it on their behalf.