Suspension vs revocation: what triggers each and how to respond

On 22 June 2026 the Department of Thai Traditional and Alternative Medicine (DTAM) announced a guideline that grades breaches of the cannabis rules into three tiers. Read with the renewal rules in force since 30 April 2026, it turns a small paperwork failure into a threat to the licence itself.

This article sets out the tiers, the legal powers behind them and what to do if an order arrives. Consumer offences are a separate matter and are not covered.

The law behind the tariff

Cannabis flower is a controlled herb under the Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), called the Act below. Three sections give the licensor its powers over a licence issued under section 46.

• Section 52. If a licensee fails to comply with the Act or a ministerial regulation, rule or notification, the licensor may suspend the licence. During suspension the licensee must stop all acts under the licence. Verified
• Section 53. The licensor may lift a suspension early if satisfied the licensee now complies. Verified
• Section 54. For a serious failure the licensor may revoke the licence. A revoked licensee may not apply for any licence under the Act until two years from the revocation, and afterwards the licensor may decide either way. Verified

The three tiers

The tiers are as announced by the Ministry of Public Health on 22 June 2026. The guideline text itself has not been published. Estimated

30 day suspension:

• Reports on forms PT.27 or PT.28 not kept or filed.
• Flower sold or exported without the required DTAM certification.
• Licence not displayed or not produced to inspectors.
• Advertising controlled herbs for commerce.

90 day suspension:

• A sale without a PT.33 prescription.
• Export details not notified to the licensor.

Revocation:

• False PT.27 or PT.28 reports.
• Sale to barred buyers, such as people under 20 or pregnant or breastfeeding women, without a prescription.
• Permitting smoking on the premises.
• Online sale.

Press reports of the guideline add vending machine sales and sales in prohibited places such as temples, dormitories and public parks. Treat those as reported, not confirmed. Estimated

Repeat breaches and the cap

Suspensions are capped at 90 days in total, so breaches found together do not stack beyond that. A second breach after a suspension brings a harsher measure, and a repeated breach leads to revocation. Estimated

After a revocation the licensee has 60 days to pass remaining stock to another licensee or to persons the licensor approves, under section 56 of the Act. Verified

Why a suspension is now a renewal question

Under Ministerial Regulation No. 2 B.E. 2569, after a suspension for breaching a controlled herb notification the licensing authority "shall consider not renewing" (clause 11 as amended). Verified A 30 day suspension for a missed report can therefore become a refused renewal months later.

Three points are not published: whether suspensions before 30 April 2026 count, whether the record follows the licensee or the premises, and whether a successful appeal clears it. Indicative See what the 30 April 2026 rules changed and PT.27 and PT.28 explained.

Three worked examples

A missed monthly report. A shop forgets its PT.28 for one month. Under the guideline that is a 30 day suspension. Estimated The shop fixes the gap and reopens. At renewal the suspension is on its record, and the authority shall consider not renewing.

A sale without a prescription. A busy evening, a regular customer, no PT.33. The guideline makes this a 90 day suspension. If the buyer was under 20, it falls in the revocation tier instead. Estimated

Delivery through a messaging app. A shop takes orders on an app and delivers. Online sale is a ground for revocation under the guideline. Estimated A revoked licensee cannot apply for any licence for two years. Verified

How to stay out of each tier

• 30 day risks: file PT.27 and PT.28 on a fixed day every month, buy only stock that carries the required certification, display the licence and do not advertise.
• 90 day risks: no sale without a PT.33, and notify export details if you export.
• Revocation risks: check identification, refuse barred buyers, allow no smoking on site, make no online sales and never alter a report.

Most revocation risks arise at the counter, in seconds, under pressure. Keep staff training short, repeated and signed. See who a dispensary cannot sell to.

Records that defend you

When an inspector questions a sale, the records answer for you: the PT.33 behind each sale, the certification behind each batch, the monthly reports with proof of filing and the rota showing a trained worker on duty. A shop with complete records can show that a problem was isolated and fixed.

Since 26 June 2025 flower sold or exported must come from a compliant source: a farm certified by DTAM to its good cultivation and harvest standard, or, since 1 August 2025, a harvest that carries a laboratory certificate of analysis. Verified See how GACP certification works.

Common misreadings

• "A suspension ends when the shop reopens." It stays on the record and feeds the renewal decision.
• "Only the 30 day tier is about paperwork." The 90 day tier also turns on a record, the PT.33.
• "Revocation is just a longer suspension." Revocation ends the licence and starts the two year bar.
• "A second breach is treated like the first." A repeat leads to revocation.

If an order arrives

1. Read it closely: the breach found, the measure, the period and the start date.
2. Comply from the start date. Trading during a suspension compounds the problem.
3. Fix the cause and document the fix, with dates and photographs.
4. Take Thai legal advice quickly on any appeal. Administrative deadlines are short.
5. Plan the renewal on the assumption that the order will be weighed, and file the order and the evidence of the fix with the renewal papers.

Section 3 of the report, free to read, traces the path from a filing lapse to a refused renewal. If you want the penalty tariff applied to a shop you are looking at, start with a call.

Sources

• Section 3 of the 2026 report, The rules in force (free to read)
• Thai Traditional Medicine Wisdom Act B.E. 2542 (1999), English translation, sections 46 and 52 to 56
• Asia News Network, Thai ministry tightens penalties for cannabis shop rule breaches, 23 June 2026
• Thairath, DTAM issues administrative orders increasing penalties for cannabis shops, 22 June 2026
• Ministerial Regulation on Licensing of Controlled Herbs, second issue, B.E. 2569, Thai text, Royal Gazette, 30 April 2026

This article is market intelligence, not legal advice. Rules change by notification; check the current text with the licensing authority or Thai counsel before you act.