How the Controlled Herbs Framework Affects Dispensary Inventory and Sourcing

The June 2025 controlled-herbs notification did not simply add a prescription requirement to a business that otherwise carried on as before. It changed what a dispensary’s stock is. Flower held under that framework is a controlled herb dispensed against a practitioner’s prescription, and the shelf it sits on is now part of a documented chain that begins on a certified farm and ends on a numbered form.

For an owner or an inventory manager, that has three practical consequences: what you may hold has narrowed, what you must record about it has widened, and the weakest link in your file is usually something your supplier did or did not do before the product ever reached you.

For the dated timeline of how the framework arrived — the 2022 delisting, the June 2025 notification, and the two ministerial regulations of April 2026 — see Thailand cannabis regulation update. This article assumes that background and deals only with inventory and sourcing.

What the framework actually does to a stock list

Four categories of product, four different positions:

Category	Status	What it means for stock
Cannabis inflorescence (flower)	Controlled herb; dispensed only against a prescription on the official PT 33 form, under practitioner supervision	Every lot must be traceable to a GACP-certified cultivation site. Dispensing is recorded against a prescription.
Extracts above 0.2% THC by weight	Category 5 narcotic — never delisted	Not ordinary dispensary stock. Licensing under the April 2026 ministerial regulation is restricted, and foreign-owned businesses fall outside that pathway.
Extracts at or below 0.2% THC	Not a narcotic	Stockable, and the 0.2% figure is a compliance boundary that needs a certificate of analysis behind it, not a supplier’s word.
Seeds	Not the controlled item under the 2025 notification, and not narcotics	Stockable. Provenance still matters commercially and for anything you sell to licensed cultivators.

The single most consequential line in that table is the GACP one. Flower that is sold must come from a cultivation site certified under Good Agricultural and Collection Practices, certified by the Department of Thai Traditional and Alternative Medicine. That converts your purchasing decision into a compliance decision. A supplier without a current, in-scope certificate is not a cheaper supplier; they are stock you cannot lawfully dispense.

The lot file: what a dispensary should hold for every intake

A dispensary licensed to sell a controlled herb carries record-keeping and reporting duties, and the practical way to meet them is to treat every intake as a lot with a file, rather than as weight added to a total. Confirm the exact reporting format and frequency with DTAM or your licensing officer — that varies and it changes. What follows is the content those records need to be built from.

About the supplier, held once and refreshed on expiry:

• Legal entity name, address, tax ID and the name of the responsible person.
• Cultivation and/or sale licence number, with a copy, and its expiry date.
• GACP certificate: number, issuing body, issue and expiry dates, and — this is the part people skip — its scope. A certificate covers named sites and often named activities. A certificate that covers a farm’s outdoor field does not automatically cover the greenhouse next to it.
• Contact for the person who can produce records at short notice.

About each lot, held for the life of the stock and for as long afterwards as your licence requires:

• Lot or batch identifier as issued by the producer, carried through unchanged.
• Cultivar name and its documented genetic source — see below, this is the one that matters.
• Harvest date, and drying/packing dates.
• Quantity received, in the unit you will dispense in, with the weighing record.
• Certificate of analysis: cannabinoid content at minimum, and whatever contaminant panel your own standard requires.
• Moisture content or water activity at receipt.
• Transport and receipt documents, dated, with the receiving staff member named.
• Storage location.

Movement, recorded as it happens:

• Every dispensing event against the prescription reference.
• Transfers between storage and floor.
• Wastage, spoilage and destruction, with what, how much, why, when, by whom and witnessed by whom. Unexplained shrinkage is what turns a routine inspection into a difficult one.
• A periodic physical count reconciled against the book figure, with variances explained in writing at the time rather than later.

Why seed origin is your problem, not just the farm’s

Here is the part that surprises dispensary owners. Your traceability chain does not begin when the flower arrives. It begins with the plant material the farm started from, and if that end of the chain is undocumented, the hole is in the chain you are relying on.

GACP certification tests continuity from propagation material forward — the seed or clone, its supplier, the batch it came from, and the record linking that batch to the plants it produced and the harvest lot they went into. A farm that bought unlabelled seed from an informal source cannot evidence that link, and an auditor who finds the file starting at “planting” rather than at “seed received” has found a gap. That subject is treated at length in GACP documentation for licensed cannabis farms in Thailand.

For you, downstream, two things follow:

Your product identity is only as good as the genetics behind it. A jar labelled “Amnesia” from two different farms may be two genuinely different plants with different cannabinoid and terpene profiles. If your practitioner is prescribing on the basis of a chemotype, and your repeat patient gets something materially different next month, the label was marketing and not information. Documented cultivars, from a named breeder, with a supplier who can say what the seed was, are what make a strain name mean something across restocks.

A supplier whose own file is thin is a supplier whose certificate is at risk. If their GACP status lapses on an audit finding, your stock from them becomes a problem in your building, not theirs.

Qualifying a supplier: a questionnaire you can use

Send this before the first order, and re-send it annually. Keep the answers on file with the certificates.

1. Provide your cultivation licence and current GACP certificate. What sites and activities are within the certificate’s scope, and when does it expire?
2. What propagation material did this lot come from — seed or clone? Name the breeder or supplier, and provide the purchase documentation for it.
3. Give the lot identifier and show how it links back to that propagation batch.
4. What is the cultivar, and what is its documented lineage?
5. Provide the certificate of analysis. Which laboratory, accredited to what, sampled how?
6. What was applied to this crop — fertilisers, biological and plant-protection inputs — with dates and rates? What is your pre-harvest interval policy?
7. Harvest, drying and packing dates. What moisture content or water activity was it packed at?
8. How was it stored and transported to us, and at what temperature and humidity?
9. Who is your responsible person, and can they produce the batch record within 24 hours of a request?
10. Have you had a licence or certification finding in the past 24 months? What was it and what changed?

A good supplier answers these without friction, because they already hold the answers. Reluctance to answer question 2 or 3 in particular is the signal worth acting on.

Practical stock control in a Thai dispensary

Compliance and product quality point the same way here, which is convenient.

• Store cool, dark and dry. Cannabinoids degrade with heat, light and oxygen; THC converts to CBN over time and a hot glass jar on a sunlit shelf is a potency complaint waiting to happen. Display jars should be display, with the working stock in a controlled space.
• Hold moisture where it belongs. Around 60–62% relative humidity in the container corresponds roughly to the water activity level at which microbial growth is controlled. Too wet is a mould risk; too dry is a harshness and terpene complaint. Two-way humidity control in bulk containers is inexpensive.
• Rotate strictly first-in, first-out, by lot, and record it.
• Never split or merge lots. Combining two lots into one jar destroys traceability irreversibly, and it is the single most common way a well-run shop breaks its own chain.
• Reconcile weekly, not annually. Small discrepancies found weekly are explainable. The same total discrepancy found once a year is not.
• Keep prescription records and stock records reconcilable to each other. They are the two halves of the same account.

Staffing and the April 2026 conditions

Ministerial Regulation No. 2 B.E. 2569, in force from 30 April 2026, set cumulative conditions on licensed flower sellers, including that trained staff be present throughout opening hours. Practically, that turns training into an inventory-adjacent record: keep a training log naming who was trained, on what, by whom and when, and a rota that demonstrates coverage. It is the kind of thing that is trivial to maintain going forward and painful to reconstruct.

Where seeds fit in a dispensary’s range

Seeds are not the controlled item under the 2025 notification and are not narcotics, which makes them one of the few parts of a cannabis retail range unaffected by the prescription requirement. For dispensaries that also serve licensed cultivators, they are a category worth carrying properly rather than casually: documented cultivars from a named breeder, supplied sealed, with an invoice that names the varieties and quantities and identifies breeder and supplier.

That documentation is exactly what your cultivator customers need at the start of their GACP file, and being the supplier who provides it without being asked twice is a durable commercial position.

What we can provide

Dutch Passion Thailand supplies provenance documentation to licensed growers and to businesses supplying them. Because auditors and licence conditions differ, we prepare it against your stated requirement rather than issuing a standard pack — tell us what your licence or your auditor asks for when you place the order and we will assemble it alongside the shipment. It is far easier to produce at the point of sale than to reconstruct when an inspection is booked.

What we will not do is certify something we cannot stand behind: we cannot certify your site, and we will not issue a cannabinoid figure for a crop we did not grow. Wholesale and documentation enquiries go through our contact page; ordering questions are answered in the FAQ.

A note on what this article is

This is a practical account of inventory and sourcing practice, written by a seed supplier that deals with licensed businesses. It is not legal advice and it does not replace your licensing officer, your certifier or your own counsel. DTAM administers the controlled-herb framework and GACP certification; where a decision turns on the requirement, confirm it with them. Thai cannabis regulation has changed materially three times since 2022 and will change again — the law page on this site is the one we re-date when it does.