Thai Food Filings: What If the Overseas Factory’s GMP Evidence Has Expired?

If an overseas factory’s GMP evidence has expired, first establish whether the issue concerns a product filing or goods already shipped to Thailand. These situations have different implications. This article concerns food-production-system evidence; the Thai importer’s licence, formulation and labelling require separate checks.^{[FDA food-import procedures]}

Match the certificate to the factory and food

• Obtain the full certificate and annexes. Match the actual manufacturing site’s name and address, food category and production activities. A trading company’s certificate or another group factory’s certificate cannot simply be substituted.
• Check the standard and version, issuing body, certification status, issue or effective date and expiry date. Dates on a scanned copy may not tell the complete story.
• Put the food category, batch dates, expected arrival and filing stage in one record. Keep overseas-factory evidence separate from the importer’s own licence.

The document’s name is only one part of the assessment

The FDA’s current import-GMP page lists its notification dated 27 November 2024 and marks the 2021 notification repealed. Applicable foods need production-system evidence covering the imported food and meeting the relevant requirements. Distinguish GMP 420 from GMP 386 for certain fresh fruit and vegetables.^{[FDA import-GMP page][2024 notification, clauses 2–3]}

The document need not necessarily be titled “GMP certificate”. FDA examples for GMP 420 include HACCP and ISO 22000:2018. A standard’s name alone does not establish the appropriate version, food scope, special requirements or acceptable issuer, and does not establish approval for every food.^{[FDA examples dated 17 December 2025]}

Separate expiry, missing expiry dates and renewal

For expired evidence, obtain a replacement or investigate whether the certifying agency has issued evidence of continuing compliance. A renewal receipt, factory undertaking or one-off test result is not, merely by its description, proof of continued certification. Compare any changed site, entity or scope with the existing filing.^{[2024 notification, clauses 2 and 5]}

No expiry date does not mean indefinite validity: clause 5 limits such evidence to one year from issue or the effective certification date. It also addresses evidence from the certifying agency of continued compliance with clause 2. The actual document needs assessment; there is no general automatic extension.^{[2024 notification, clause 5]}

Document form matters too. Originals, certified copies, verifiable database records, electronic evidence and translations have conditions. For a foreign-language scan, check the verifiable information and Thai or English translation requirements.^{[Official translation of the same notification, clause 4]}

Expiry during shipment has specific conditions

The FDA’s publicly available checkpoint FAQ dated 10 April 2023 says officials check the manufacturing date where certification expires while goods are being shipped to Thailand. Evidence may accompany import checks for batches made before expiry. Batches made after expiry may be treated as lacking the certificate, with possible detention pending evidence, return or other action.^{[FDA checkpoint FAQ]}

This does not create general permission to use expired evidence in product applications or guarantee release. For goods in transit, provide batch-production records, certification and shipment dates promptly so that the responsible person can check the position with the relevant checkpoint. Do not ship on the assumption that the old certificate must be accepted.

Prepare a focused evidence package

• Collect old and replacement certificates, renewal documents, annexes and verifiable status results, identifying the actual site and covered foods.
• Include product details, batch numbers, production dates, expected arrival, importer licensing and existing filing records.
• Identify whether the gap concerns valid certification, scope or inconsistent filing data. Then confirm supplementary-document, production and shipment steps. Factory-certificate expiry alone does not establish that every product must be filed again.

Frequently asked questions

For classification and the general filing process, see the Thai food FDA classification and import guide. Importer-premises changes and overseas-factory certification require separate checks.

Identify the food and the current stage

For assistance, see our FDA registration and licensing service and describe the certificate status, food category and filing or shipment stage. This helps assess the required evidence. FDA acceptance, approval and customs clearance are not guaranteed.

Sources last checked: 20 October 2026. This article discusses existing notifications and public guidance, not a new rule introduced in 2026.