Interesting post by on linked in this past week raising the issue of how much cannabis Portugal actually grows and how much is imported then re-exported and then counted as Portuguese product
He writes
Just seen at PTMC – Portugal Medical Cannabis presented by INFARMED, I.P.
Portugal exported over 33 tonnes of medicinal cannabis YTD (as of August 2025), already above the full 2024 total, despite the well known recent delays. Almost all of it with Germany as the final destination.
I asked Vasco Bettencourt of Infarmed how much was domestically grown versus imported for processing and re-export. He couldn’t provide specifics.
Anecdotally, most industry contacts here say the majority of exports clearly are not grown in Portugal.
Pascual provided the folowing image to accompany his post
On 16 September 2025 Cannabis Regulation ai reported
Portugal 2025: INFARMED Tightens Import/Export of Medical Cannabis—New Docs, Timelines, and GMP Proof
Portugal medical cannabis import export 2025: For producers, exporters, importers, and compliance professionals, dramatic regulatory changes have defined 2025. INFARMED—the Portuguese National Authority of Medicines and Health Products—has undertaken a comprehensive tightening of the rules governing medicinal cannabis import and export. Below, we unpack what these new requirements mean, timelines, documentation standards, best practices for compliance, and what to expect as this leading EU jurisdiction keeps pace with both market expansion and heightened oversight.
Introduction: Why Portugal’s INFARMED Is Raising the Bar in 2025
Portugal’s medical cannabis sector is at an inflection point. Having granted multiple new cultivation, manufacturing, and import/export licenses in early 2025 (source), INFARMED is concurrently implementing stricter controls to safeguard product quality, public health, and supply chain integrity. As a result, Portugal’s role as a supply and transit hub for European medical cannabis is matched by an increasingly rigorous regulatory environment.
Key Highlights of 2025 INFARMED Regulatory Update
New Documentation Layers—GMP, COAs, and Stability Data
INFARMED now requires:
- EU-GMP or PIC/S GMP Certificates for all medical cannabis products. These must be current, scan-verifiable, and cover every site in the proposed supply chain (source).
- Batch-Level Certificates of Analysis (COAs): COAs must include results for all primary cannabinoids (THC, CBD, CBN), detailed contaminant testing, and must explicitly reference validated laboratory methods. All documentation should trace back to the specific batch intended for shipment, with supporting batch records available on request.
- Stability Data: INFARMED now reviews stability data specific to the final packed product format being shipped. This includes storage and transport condition simulations. Stability must be shown in alignment with expiry dates, labeling, and the product’s real shipment route, ensuring the medicinal cannabis remains compliant when it reaches the patient.
Added Portuguese Packaging, Labeling, and IFU Requirements
Companies must now ensure:
- Labeling fully in Portuguese, compliant with national conventions for medical products, including dosage, administration route, batch identifier, expiry, and manufacturer info.
- Updated Instructions for Use (IFU): These must align with current Portuguese medical and pharmaceutical terminology and cultural expectations.
- Advance Dossier Submission: Exporters/importers are expected to submit pre-assembled dossiers with templates for SOPs, validation summaries, chain-of-custody, and change-control matrices. INFARMED’s scrutiny includes cross-verification of SOPs and direct checks of QMS and production batch records.
Extended Administrative Timelines—Build Buffers into Supply
One of industry’s loudest concerns in 2025 is the noticeable lengthening of permit and import/export certificate issuance periods. Where approvals might have taken under six weeks in 2024, timelines in mid-2025 are reportedly 2–3 months or longer in some cases (source). Factors cited include:
- Increased Documentation Loads: INFARMED thoroughly reviews every doc, cross-referencing batch data, GMP sites, and destination market specs.
- Closer Scrutiny: Additional questions from INFARMED on psychoactive profiles, contaminant levels, and transport controls mean that incomplete or non-aligned dossiers see repeated requests for clarification—further delaying shipments.
- System Backlogs: Surging volumes due to more licensed companies are straining INFARMED staff, leading to administrative bottlenecks.
Takeaway: Producers and distributors must build generous time buffers into their supply chain plans and avoid just-in-time shipment models.
Compliance Best Practices for Producers and Exporters
Prepare Robust Dossiers
- Assemble master files with updated SOPs, batch documentation, and validation data before applying for export/import permits.
- Include chain-of-custody matrices, change-control logs, and contingency planning for nonconformities.
Align All Materials to Portuguese Law
- Ensure labeling meets Portuguese medical norms, not just general EU standards.
- Translate all IFUs and critical documents into technical Portuguese, using regulators’ terminology.
Address Receiving Market Requirements Proactively
- Check not only INFARMED requirements but also importing country specifications (e.g., Germany, UK, or other EU states). Regulatory mismatches at the border can result in the need for rework or even shipment rejection.
- Confirm that COAs and stability testing are recognized by both INFARMED and the destination market.
Enforcement, Gatekeeping, and Market Growth—What Lies Ahead?
INFARMED has paired market liberalization (via new licenses for both cultivation and distribution) with tighter administrative gatekeeping. This trend is intended to:
- Prevent diversion and ensure medicinal cannabis reaching patients is consistent, pure, and safe.
- Maintain Portugal’s reputation as a trusted supplier for the European market.
- Discourage non-compliance with robust enforcement mechanisms: repeat non-conformities or document gaps can lead to permit revocations, delays, or financial penalties.
Penalties: Administrative penalties have increased, with non-compliant batches subject to seizure, quarantining, and in some cases, total prohibition from further import/export. Companies with repeated shortcomings are increasingly likely to be blacklisted.
For Medical Cannabis Businesses—Action Steps in 2025
What To Do Now
- Audit all documentation: Ensure every element of your GMP, quality, and shipment materials is up-to-date and mapped to INFARMED’s new formats.
- Pre-validate translation and labeling: Engage qualified local language experts and regulatory translators.
- Build time buffers: Expect 8–12 weeks for complete certificate cycles and work this into your supply strategy.
- Watch for ongoing updates: INFARMED is actively revising its guidance into the second half of 2025. Monitor the official INFARMED website and CannabisRegulations.ai for real-time news.
For Investors and Stakeholders
Portugal remains a foundational pillar of European medical cannabis. However, ease of market entry is now coupled with a world-class regulatory compliance burden. Investors and corporate leaders are encouraged to:
- Prioritize due diligence on compliance resources in production partners
- Monitor regulatory changes and require transparent, up-to-date compliance practices from investee companies
Final Thoughts
2025 stands as a turning point for Portugal’s medical cannabis import/export sector. INFARMED’s new documentation, quality, and administrative demands are reshaping the compliance environment—demanding greater rigor both from established players and new entrants. Business success in this space will depend not only on meeting GMP and product quality standards, but on cultivating an operational culture of proactive, detailed regulatory engagement.
For detailed walkthroughs, template dossiers, and real-time regulatory tracking, make sure to visit CannabisRegulations.ai, your trusted resource for cannabis compliance across Europe and beyond.
Also Read
Cannabis Business Plans.com wrote on May 25th 2025
Data provided by INFARMED shows that Portugal exported 4,850 kg of medicinal cannabis in 2020, 5,694 kg in 2021, 9,271 kg in 2022 and 11,973 kg in 2023. In 2024, cannabis exports surged by 172% to 32,558 kilograms, solidifying the country’s status as Europe’s largest exporter of cannabis.
Portugal News wrote 24 April 2025 , ” Portugal cannabis exports almost triple”
The volume of Portuguese cannabis exports almost tripled in 2024 compared to the previous year.
According to data provided to ECO by the National Authority for Medicines and Health Products (Infarmed), sales abroad totalled 32,558 kilos, covering cultivation, manufacturing and wholesale trade activities.
Germany, Spain, Poland, the United Kingdom and Australia were the top five destinations for medical cannabis exports last year. With this year-on-year growth of 172%, which made the volume exceed 65 tons in 2019, the country consolidated its status as the largest European exporter and second in the world, a ranking in which it appears behind only Canada.
The public institute led by Rui Santos Ivo, who last month was elected chairman of the board of directors of the European Medicines Agency (EMA), told ECO that there are currently 41 companies authorized to carry out cultivation activities, 24 at the manufacturing level and 15 operating in wholesale trade.
https://www.theportugalnews.com/news/2025-04-24/portugal-cannabis-exports-almost-triple/97136
Sean Hocking
Source link