Last week, the European Medicines Agency published the first revision of GACP for cannabis – although the official name is "starting material of herbal origins."
The first guidelines came out in 2006. With the advancement of the cannabis industry and the rise of new cultivation methods, such as indoor growing, a revision was inevitable. As the name itself suggests, though, GACP is not a strict requirement to market cannabis products in the EU – unlike GMP. These are guidelines that growers must follow if they want to obtain GACP certification.
What has changed?
"Not much," says Carl Haffner, a cannabis industry consultant since July 2022 after exiting Avida Global which he co-founded in 2018. "It's more of a confirmation that GACP is moving closer to GMP. From an industry point of view, a lot of people are out there obtaining GACP wherever they are in the world. It's an agricultural certification, which is fine for farming, but there are vast differences compared to GMP."
According to Carl, the revision does bring more clarity for growers. "With this update, it's very clear what you need to have in place from day one. Too many people have slipped through the cracks, managing to get products into markets just because they had GACP."
One of the most notable updates relates to indoor cultivation, which has seen significant growth across Europe. For instance, daily digital records of critical process parameters must now be kept and reviewed.
Another important update concerns documentation and audits. The guidelines state that "audit reports, including those by or on behalf of GMP-licensed manufacturers or other parties… should be stored (physically and/or digitally)." This is a welcome change, Carl says: "If we want to be taken seriously as an industry, we need true end-to-end traceability. Documentation can't just be window dressing."
The revision also places greater focus on contamination prevention, covering soil, water, and even cleaning processes.
What about cultivation?
On the cultivation side, the guidelines return to the basics: document your methods, respect local environmental rules, and follow good crop husbandry. Soil can't be contaminated, fertilizers must be minimal and justified, and manure needs to be properly composted and free from human waste. The goal is to avoid heavy metals, pesticides, or other unwanted residues creeping into the crop.
Irrigation has to meet the plant's needs, with water quality checked against local or international standards.
When it comes to crop protection, the message is clear: pesticides should be a last resort. If they are used, they must be approved, applied sparingly, and handled only by qualified staff, with residue limits and pre-harvest intervals respected. Growers also need to assess contamination risks from neighboring fields and keep crops under close watch throughout the season.
Even though the revision puts stricter rules in place, Carl Haffner welcomes the changes. "The tighter the guidelines, the better. When I explain this to new clients, I use one word: liability. At any point in the supply chain, if something goes wrong, the investigation will trace it back. If the grower cut corners on GACP, the responsibility lands on their doorstep. Even if insurance covers it, the reputation damage will stick to you like the smell of dung. That's why I think this update is a good thing. It's about protecting both patients and producers."
