German State Says Medical Cannabis Must Be Dried Where It’s Grown, Tightening EU GMP Rules

Germany may be closing one of the most widely discussed loopholes in the international medical cannabis supply chain.

New guidance issued by the Hessian State Office for Health and Care on June 8 states that cannabis flower intended to be released as medicine must be dried and trimmed where it is harvested. Producers may only deviate from this requirement if they can demonstrate that delaying or splitting the drying process does not affect the quality of the finished product, according to a report by MMJ Daily.

The clarification could have significant implications for medical cannabis exporters and pharmaceutical manufacturers serving the European market, particularly those relying on a practice commonly referred to as EU GMP washing.

Germany Draws a Firmer Line Between Cultivation and Manufacturing

The guidance identifies drying as a critical manufacturing operation because it directly affects the quality of the finished medicinal product.

As such, regulators argue the process falls under European Union Good Manufacturing Practice (EU GMP) requirements rather than Good Agricultural and Collection Practice (GACP) standards that govern cultivation.

The distinction determines where farming ends and pharmaceutical manufacturing begins. Under the EU GMP Guidelines for herbal medicinal products, activities such as drying and trimming may fall under either framework depending on how significantly they influence the final product’s quality.

By classifying drying as a GMP activity, the Hessian authority is effectively saying that one of the most important pharmaceutical manufacturing steps cannot simply be postponed until cannabis reaches Europe.

What Is EU GMP Washing?

To understand why Germany’s guidance matters, it’s important to understand a practice known throughout the medical cannabis industry as EU GMP washing.

The term refers to a supply-chain model in which cannabis is cultivated, harvested, and partially processed in lower-cost producing countries before being shipped to Europe, where the final manufacturing steps—such as drying, trimming, packaging, testing, or product release—are completed under EU GMP certification.

Because the product receives its final pharmaceutical certification inside Europe, it can legally enter European medical markets even though much of the production took place elsewhere.

The model has allowed producers in countries such as Canada, Portugal, Colombia, Uruguay, South Africa, North Macedonia, and others to capitalize on lower cultivation costs while relying on European facilities for the pharmaceutical processing required by many importing countries.

Supporters argue the model creates efficient international supply chains, lowers production costs, and expands patient access to medical cannabis.

Critics, however, contend that it stretches the original intent of EU GMP by allowing critical manufacturing activities to occur separately from cultivation.

While Germany’s new guidance never uses the phrase “EU GMP washing,” its interpretation effectively narrows the practice by arguing that critical drying cannot be completed later at a European GMP-certified facility after partial processing abroad.

Supply Chains May Need to Change

If drying is officially considered a GMP manufacturing activity rather than an agricultural one, several existing import models may no longer comply with German regulators’ interpretation.

Companies would no longer be able to rely on completing critical manufacturing steps after importing partially processed flower into Europe unless they can scientifically demonstrate that delaying those steps would not affect product quality.

That could require exporters to invest in EU GMP-compliant drying and processing facilities in the country where cannabis is grown, rather than using European facilities for final pharmaceutical manufacturing.

For many producers, that would represent a significant capital investment and could alter the economics of exporting medical cannabis to Europe.

A Decision That Could Reach Beyond Germany

Although the guidance currently applies to the German state of Hesse, industry observers will be watching closely to see whether other German regulators—or regulators elsewhere in Europe—adopt a similar interpretation.

Germany remains Europe’s largest medical cannabis market and often serves as a regulatory reference point for other jurisdictions.

If its interpretation spreads, the decision could reshape international cannabis supply chains, influence future facility investments, and redefine where pharmaceutical manufacturing must occur for products entering Europe’s medical cannabis market.

For exporters, regulators, processors, users, doctors, pharmacies, dispensaries, and investors alike, the question is where cannabis can be manufactured in compliance with evolving pharmaceutical standards.