Conversion of legislation and regulatory requirements into practice


In Denmark, according to the Act on the medicinal cannabis pilot programme and the development scheme, permission can be obtained for cultivation, manufacture of primary products, manufacture and import of primary products, manufacture of intermediate products, and sales and export of bulk and primary products. Medicinal cannabis is the designation of the processed flowers of the cannabis plant used for medical treatment. However, since it is neither categorized as a medicinal product or a dietary supplement, there are quite specific rules for cultivation and manufacture. Therefore the Danish Medicines Agency has established a specific legislation that aims to ensure control of cultivation and manufacture, in order to obtain a uniform product which is manufactured in a quality-correct manner, every time. Legislation and the rules within the field approach the requirements for the production of medicinal products, where the rules for good manufacturing practice, cultivation, transport and storage are applicable:

The production requirements for medicinal cannabis approach the rules of pharmaceutical production, where the rules of good manufacturing practice must be followed. GMP ensures that medicinal cannabis is manufactured according to current quality standards, in relation to the use of product.

When cultivating the plant, the rules for good agricultural practice are followed. GACP is a set of rules that regulates the cultivation, harvesting and subsequent handling and processing of the plant material, to ensure a sufficient quality of the plant material.

To ensure the level of quality of the medicinal product, the rules of good distribution practice must be maintained throughout the distribution chain. This means that transport and storage must be controlled, and a traceability system must be established in order to identify any counterfeit products.


The company sends an application for company authorisation and/or product approval to the Danish Medicines Agency. The Danish Medicines Agency assesses the application and the submitted documentation in relation to applicable legal requirements, after which they come to the company for inspection before the final approval and company authorisation is given. The following example shows the application process for a company authorisation.


Since October 2017 we have supported a number of companies with counselling and specialist knowledge within both the development scheme and the pilot programme. We have extensive experience with the challenges that may arise in connection with the cultivation, manufacture, import and export of medicinal cannabis, and offer consultancy on company and product approval, including application to the Danish Medicines Agency.
We carry out GAP analyses and consultancy when establishing a quality management systems and preparing procedures. We offer competent feedback and support when establishing the production facility, commissioning testing of equipment and premises, including process risk analysis. We offer to perform auditing of suppliers and handle the contact with authorities, as well as affiliation of a competent person upon release to the market.
We offer education and training of employees in cannabis legislation, GMP, GACP, GDP and processes.



AlfaNordic's consultants have broad knowledge and experience within the various aspects of GxP regulated production environments. Our consultants in the cannabis team have extensive experience in advising about or resolving the challenges that may arise in cultivating, manufacturing, importing and exporting medicinal cannabis. We can you help interpret the rules and convert them into practice. This ensures an appropriate standard of quality from the beginning, so that a company authorisation will be obtained after a satisfactory inspection, and it ensures a satisfactory product application leading to the approval of the products. The starting point will usually be a GAP analysis. This is a controlled and systematic survey, in which requirements and milestones are defined in relation to standards on the basis of the company's current situation. The purpose of the GAP analysis is to identify the gaps that must be closed in order to achieve a solution that works in practice and, of course, meets the current legislation and standards.



  • Compliance: Legislation on medicinal cannabis. Legislation on euphoriant substances. GMP – Eudralex vol. 4, GACP and GDP.
  • Validation & Qualification Including commissioning testing of equipment and premises. 
  • CMO identification and contact to other relevant potential business partners
  • Supplier audit: Represents the client during audit. Prepares, accomplishes and completes with an audit report. Follow-up according to the client’s wishes.
  • Business case and counselling GAP analysis, advice on the preparation of quality management systems and procedures.
  • Process Risk analysis Performed on the company's processes in order to identify all critical processes in cultivation and production. 
  • Proces flow analysis and optimization
  • Process validation
  • Transfer fra pilot til production, generel upscale
  • Authority contact and competent person Advice on company and product approval, including application to the Danish Medicines Agency and handling of authority contact.
    Associated competent person upon release to the market.
  • Education & Training: Courses for employees in GMP, GACP, GDP, client-specific courses and on-the-job training in processes. 


We have practical experience in helping companies in the medical cannabis industry. Examples of tasks we have solved are:

  • Competent feedback and business development incl. GAP analysis of where the current company situation in relation to the ambitions, as well as advice on how the company achieves good progress and reaches its goals. 
  • Clarification of questions about import and export of medicinal cannabis.
  • Design and set-up of production facilities that comply with the authority requirements.
  • Establishment and/or optimization of quality systems and production processes that ensure high and uniform production quality. 
  • Pre-inspection preparation: Our cannabis consultants review the company's processes to identify the challenges that are critical to obtaining the necessary approvals and permissions. Guidance and help to solve specific challenges subsequently, so that the company is ready for the Danish Medicines Agency's inspection. 
  • Assistance during the inspection: AlfaNordic's experienced cannabis consultants can support the company's management when receiving inspectors, answering questions and following up on the subsequent reporting, as a companion or representative of the company. 
  • Courses that strengthen the company's knowledge and understanding of how rules and documentation and quality requirements of the legislation on medicinal cannabis are converted into the individual company's processes. 


If you want further knowledge about cultivation and the legislation within medicinal cannabis, we have prepared a table from which you can easily get an overview of different topics. 

Here you can learn more about the Danish Medicines Agency's legislation on the pilot programme and development scheme for medicinal cannabis, the requirements for GMP – good manufacturing practice, cf. EU-GMP Eudralex vol. 4, documentation and rules for handling euphoriant substances. The cultivation requirements according to the GACP – Good Agricultural and Collection Practices and the distribution requirements – GDP, which describes the rules within good distribution practice. 

Business with euphoriant substances

Here you can read about the Danish Medicines Agency's executive orders in this field.
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Good Manufacturing Practice covers the rules that must be obeyed in the EU within the manufacture of human and veterinary medicinal products.
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Good Agricultural and Collection Practices describe the regulations applicable to the cultivation, collection and primary processing of plants used for medicinal cannabis.
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Requirements for products in the pilot programme

Annex 7 in EU rules for medicinal products, applies to all medicinal plants incl. control of plant material, storage and processing.
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In order to avoid counterfeit medicines in the legal supply chain, the quality system must ensure that staff, documentation, storage and transport are under control.
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Requirements and expectations for a competent person

The Danish Medicines Agency requires that the company has a competent person at its disposal to obtain permission for the manufacture of cannabis intermediates and cannabis bulk.
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Permission for the production of cannabis products

Read more about the Danish Medicines Agency's requirements for the pilot programme, and read more about authorisation in connection with manufacturing here.
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Cultivation and handling of medicinal cannabis

Here you can read more about the Danish Medicines Agency's requirements for the development scheme, in which you can read more about authorisation for cultivation and handling of medicinal cannabis.
Learn more


 Take AlfaNordic's advice

Ole Markersen

Vice President

Subject areas
Medical Device
Propositions and contracts
QA, RA og Safety

+45 31 44 75 11


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