German Cannabis Business Assoc
Different interpretations: European authorities divided over pre-drying of Medical Cannabis
2026-09-21 | The regulatory assessment of pre-drying medical cannabis flowers differs considerably within Europe between the GACP (Good Agricultural and Collection Practice) and GMP (Good Manufacturing Practice) standards, reportsĀ KrautInvest. The Dutch Ministry of Health classifies any pre-drying as a manufacturing step that must fall under GMP. The Spanish medicines agency, by contrast, allows flexibility and permits pre-drying in the field under GACP, while requiring GMP for final drying. In Denmark, a regulation stipulates that the drying of cannabis bulk must be carried out according to active-substance GMP. By contrast, the Swiss authority Swissmedic explicitly permits simple pre-drying under GACP. The European Medicines Agency (EMA) points out that initial steps in the field may fall under GACP if this is justified in the marketing authorization, while subsequent processes are subject to GMP requirements.
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How National Regulators Compare
| Country | Drying Classification | Specific Regulatory Stance |
|---|---|---|
| Denmark | Strict GMP | Formally established via a legal decree. Bulk cannabis resulting strictly from drying must follow GMP rules applicable to active substances. |
| The Netherlands | Strict GMP | Classifies the entire flower drying phase as a manufacturing step requiring strict EU-GMP certification. |
| Spain | Strict GMP | Matches the Dutch and Danish approach, mandating full GMP compliance for post-harvest drying. |
| Switzerland | Hybrid / GACP | Reportedly permits a simple āpre-dryingā phase under the more lenient GACP standards before transitioning into a formal GMP step. |
The Root of the Conflict
