Guidance for Dispensaries: Transitioning to become a fully compliant medical cannabis dispensary

With the recent regulation change announced by the Thai Ministry of Public Health, many dispensaries may be confused by the overload of news and rumors.  PACCAN (www.paccangroup.com) is providing this guidance to the dispensary industry at large with the intention of educating and helping everybody transition to the new regulatory environment.  We do believe that this will be good for the industry overall.

Basically, the government is implementing a full track and trace system to account for every gram of products being cultivated/ manufactured in the country.  This means that everybody in the ecosystem must report their numbers to the authority through an online portal.  This includes farms, extraction factories, manufacturing factories, dispensaries, exporters, and even Doctors.  The government’s IT system has a reconciliation system assisted by an AI engine to catch any anomalies for enforcements.

What does this mean for dispensaries?  Here is a checklist of key compliance areas to abide by:

1.     Make sure you shop has the Dispensary License (the current one)/ form 11

2.     Make sure you purchase your products from licensed producers, and keep your receipts/ and purchase orders:

a.     Flowers must be from GACP certified farms, and GMP PIC/S packaged flowers are preferred (with sealed caps, expiration dates, and COAs)

b.     Manufactured products must be from GMP or GMP PIC/S factories, even though some products have to be under prescription anyway.

c.      Over the counter (OTC) products must have FDA number (effectively it must be approved by the Thai FDA)

d.     If you are a factory manufacturing products, make sure you raw materials (especially CBD and THC) are from licensed producers.

3.     Make sure you open your online account with DTAM (Department of Traditional Thai and Alternative Medicine) [https://herbctrl.dtam.moph.go.th/] where they have a form for you to self report your monthly activities; what do you purchase, what do you sell, what do you have left in your inventories.  Make sure your staffs update this database at least on a weekly basis.

4.     When dispensing THC products or flowers, make sure there is a prescription for each patient – where this can be by your onsite Doctor or Telemedicine Doctor.  There is a formal prescription form issued by the authorities already.

a.      Every Doctor is very selective and careful with the products they prescribe to their patients because they are responsible for whatever happens to the patients.  As a result, most Doctors would require the products to be GMP manufactured, with expiration dates, COA, and other quality assurances.  This also includes cannabis flowers, where most Doctors would be against improper packaging of the flowers (e.g., in big glass jars) which would be at risk of mold and contaminants.  When recruiting your Doctor, these are the basic quality requirements to uphold.

b.     Show COAs of your flowers visibly, and the COAs should be from certified labs, preferable ISO17025 labs.

*The Government does not require that you convert your dispensary into a full medical clinic, but if you are already a clinic, that is even better.

5.     When dispensing THC product or flowers, make sure you keep a copy of your patient’s identification card.  For Thai customers, have a copy of their ID card.  For foreigners, have a copy of their Passport.

 As long as you abide by the above compliance checklist, you are operating within the law and there should be no risks of license revocation or cancellation. 

PACCAN will continue to issue updated news as additional regulations are announced to the community.  Stay tuned, and feel free to connect with PACCAN wholesale partners throughout the country to work with us. 

PACCAN Team