February 20, 2026

Colombia 2025: Prescription‑Only Adult Use? Inside the Draft Decree and What It Means for Exports and Pharmacies

Colombia 2025: Prescription‑Only Adult Use? Inside the Draft Decree and What It Means for Exports and Pharmacies

In late July 2025, Colombian media reported that the Ministry of Justice circulated a draft decree that would allow adults to legally purchase psychoactive products through pharmacies and drugstores—but only with a medical prescription. The concept is often described as a “medical‑gate” adult‑use model: adult access expands, yet the distribution channel and controls look more like a tightly supervised medical program than a retail dispensary rollout.

Since then, Colombia has continued moving in this direction. In October 2025, the government issued Decree 1138 of 2025, which updated the health-sector framework (modifying parts of Decree 780 of 2016) and recognized flower as a finished product for medical use that can be dispensed with prescription through authorized pharmaceutical establishments—alongside other regulated dosage forms and magistral preparations.

For compliance leaders, export operators, pharmacy chains, and investors, the key question is no longer whether Colombia has a regulated ecosystem—it does. The question is how a prescription-only expansion (drafted in 2025 and partly reflected in subsequent reforms) could reshape licensing strategy, track‑and‑trace expectations, GMP/GACP alignment, labeling/packaging, and market access pathways.

This article is informational only, not legal advice.

Colombia’s baseline framework (before the July 2025 draft)

Colombia’s regulated model has been building since Law 1787 of 2016, which created a framework for safe and informed access for medical and scientific uses.

The operational backbone is built across multiple authorities and instruments:

  • Ministry of Justice (control and oversight of certain licenses and controlled-material flows) via the cannabis control group and the MICC platform for reporting and traceability.
  • Ministry of Health and entities in the health sector for product pathways and technical rules.
  • INVIMA (the national food and drug authority) for sanitary registrations, GMP/BPF certifications, and advertising control rules for medicines.
  • ICA for seed/plant material oversight and phytosanitary requirements.
  • Fondo Nacional de Estupefacientes (FNE) as a key actor in controlled substances administration and quota-related processes, with guidance and periodic reporting.

Two prior policy shifts matter for understanding the draft decree’s logic:

1) Export liberalization: Colombia’s reforms since 2021 (notably Decree 811 of 2021 and its implementing rules) enabled broader commercialization and helped unlock dried flower export pathways.

2) Industrial/non-psychoactive product rules: Resolution 227 of 2022 implemented Decree 811 and set out procedures for licensing/quotas/authorizations, including for industrial uses tied to non‑psychoactive components.

Official references:

What the late‑July 2025 draft decree reportedly proposed

Reporting from late July 2025 described a draft that would allow sales of psychoactive products to adults through pharmacies upon presentation of a medical prescription.

Key elements highlighted in press coverage included:

  • The point of sale would be authorized pharmaceutical establishments rather than general retail.
  • Product presentation would be dosified (e.g., tablets/capsules, or measured by gram/milliliter for solutions/creams), aligning the model with controlled dispensing rather than open-ended consumer retail.
  • Magistral preparations would be limited to authorized establishments and linked to INVIMA certification of good preparation practices for the relevant scope.
  • The Ministry of Justice would continue to play a licensing/control role for cultivation and controlled-material oversight.

Sources (media summaries of the draft):

Why compliance teams should treat it as “adult-use adjacent,” not adult-use retail

Even though some headlines framed the draft as legalization for adults, the structure described is closer to expanded medical access:

  • A prescription gate.
  • Pharmacy dispensing.
  • Medical/pharmaceutical controls on dose forms, labeling, and professional oversight.

For international operators, this distinction matters because it changes assumptions about:

  • Advertising and promotion (Rx-style rules, not consumer lifestyle marketing).
  • Product specifications (more like medicines or controlled preparations).
  • Track‑and‑trace (tighter inventory controls at dispensing points).

Decree 1138 of 2025: the “real-world” regulatory anchor after the draft

On October 27, 2025, Colombia issued Decree 1138 of 2025 updating the health-sector rules for safe and informed access. Among the most consequential shifts, the decree recognized flower as a finished product for medical and veterinary purposes and enabled dispensing via pharmacies/drugstores under prescription within the authorized framework.

Official references:

Transitional and equity-oriented features to watch

Public reporting around Decree 1138 emphasized a two-year priority/exclusivity window for micro, small, and medium domestic cultivators to supply the national medical market for this finished-product category.

From a compliance and commercial planning perspective, any transitional window like this creates immediate diligence tasks:

  • Confirm eligibility definitions and how authorities verify status.
  • Determine whether supply contracts and corporate structures could be scrutinized as attempts to bypass priorities.
  • Align procurement SOPs for pharmacies and manufacturers to ensure suppliers meet the prioritized category when required.

Licensing and operational impacts under a prescription-only expansion

A prescription-only “adult-use” layer doesn’t eliminate Colombia’s existing licensing framework—it overlays it. For businesses, the strategic shift is that domestic demand may start to matter nearly as much as export demand, but under medical-style constraints.

Cultivators and manufacturers: pivoting from export-first to dual-market compliance

If your operation historically focused on exports (particularly flower), the domestic Rx channel introduces new expectations:

  • Product standardization and batch consistency: pharmacies and prescribers often demand tighter specs and clearer patient instructions.
  • Documented chain of custody that supports dispensing-level audits.
  • Packaging/labeling readiness for a domestic pharmacy shelf (including Spanish-language requirements, warnings, and controlled dispensing information).

Pharmacies and drugstores: new category, new controlled-substance posture

For retail pharmacy operators, the compliance story is less about “dispensary rollout” and more about controlled inventory:

  • Prescription verification controls
  • Staff training and pharmacist oversight
  • Secure storage and loss prevention
  • Lot/batch recording and recall readiness

If the final framework explicitly allows inhaled routes (smoked/vaporized) under prescription—as described in some draft reporting—pharmacies should anticipate heightened scrutiny around patient counseling, warnings, and safe use communications.

Track-and-trace: MICC and the “pharmacy endpoint” challenge

Colombia’s regulatory ecosystem includes the Mecanismo de Información para el Control de Cannabis (MICC), a digital platform used for regulated reporting and activity registration.

Official MICC references:

What changes when the endpoint is a pharmacy?

Export chains often terminate at a logistics handoff plus foreign import documentation. A pharmacy endpoint introduces:

  • Higher transaction volume (many small dispenses vs. fewer bulk shipments)
  • The need for near-real-time inventory accuracy
  • Stronger reconciliation between prescription records, stock records, and MICC reporting

Action items for compliance officers

  • Map every “state change” in inventory from harvest to patient dispense.
  • Ensure SOPs define who records what, when, and in which system.
  • Build exception handling: returns, destructions, expired inventory, recalls.

Product specifications: dosage forms, THC caps, and labeling—what to watch in final texts

The July 2025 reporting suggested a strong preference for dosified presentations and measured quantities (grams/milliliters) for certain formats.

For 2026 planning, businesses should monitor final/implementing rules for:

  • Permitted dosage forms (flower, oils, capsules, creams, magistral preparations)
  • THC limits or categorization thresholds (especially for product type distinctions)
  • Labeling requirements: potency expression, warnings, contraindications, storage, batch/lot, expiry, and dispensing instructions

Even when rules do not specify a universal THC cap, regulators often enforce product differentiation through:

  • controlled-substance scheduling concepts,
  • prescription category restrictions,
  • and more intensive reporting/inspection requirements.

GMP/BPF and GACP alignment: why exports and domestic Rx are converging

A pharmacy-dispensed model tends to pull the whole supply chain toward pharmaceutical-grade discipline.

Cultivation: documenting agronomic controls (GACP-like expectations)

While “GACP” may show up more in international buyer requirements than in a single Colombian statute, the operational expectation is consistent:

  • controlled inputs,
  • pesticide and contaminant management,
  • harvest handling,
  • sanitation,
  • and complete traceability documentation.

ICA resources relevant to seed/plant material oversight and agricultural controls:

Manufacturing and preparation: INVIMA good practices expectations

For magistral preparations and other finished products, INVIMA certification for the appropriate scope of good practices becomes central.

INVIMA’s cannabis/regulated products landing page and framework reminders:

Advertising and promotion: Rx rules likely dominate

A prescription-only model heavily restricts the “brand marketing” playbook.

In Colombia, the publicity and promotion of Rx medicines is tightly controlled and generally limited to restricted professional audiences under defined conditions.

A key compliance reference point is the updated regulatory approach reflected in Resolution 1896 of 2023 (widely discussed by practitioners and referenced by INVIMA’s advertising control guidance).

Practical compliance implications:

  • Public-facing lifestyle advertising is high risk.
  • Educational material must be carefully vetted to avoid implied therapeutic claims beyond authorized indications.
  • Digital promotion must respect restricted-access requirements where applicable.

INVIMA advertising control guidance (includes restricted-access discussion):

Packaging and labeling: pharmacy-grade expectations, not “consumer branding”

If products are dispensed through pharmacies under prescription, packaging tends to be evaluated as part of a health-protection framework:

  • Clear potency and dosing information
  • Child-resistant and tamper-evident considerations (where required)
  • Batch/lot traceability
  • Contraindications and warnings
  • Storage and expiration

Even for plant material sold by gram, regulators can demand consistent labeling that makes it feasible to:

  • trace adverse events,
  • run recalls,
  • and audit dispensing practices.

Imports and mutual recognition: will foreign GMP/COAs be accepted?

Your research note correctly flags one of the biggest open questions: whether Colombia will recognize foreign GMP certifications or certificates of analysis for imports, and under what conditions.

At minimum, INVIMA generally requires that regulated products comply with its registration and import rules, and that establishments and products meet applicable sanitary controls.

INVIMA reminds that regulated products generally require Registro Sanitario for production, import, export, processing, packaging, and commercialization:

For businesses planning cross-border trade (importing finished products into Colombia or exporting from Colombia into tightly regulated destinations), the safest compliance posture is:

  • Assume no automatic mutual recognition unless explicitly stated.
  • Prepare for local registration and dossier expectations.
  • Maintain robust QA systems that can translate COAs, methods, and stability data into the receiving regulator’s expectations.

Enforcement and penalties: what “tighter national control” can look like in practice

Prescription-only access increases the political and regulatory need to demonstrate control. Expect enforcement attention on:

  • Diversion prevention and unexplained losses
  • Mislabeling, potency variance, or contamination
  • Unauthorized advertising or promotional inducements
  • Unlicensed manufacturing or compounding activities
  • Failure to report transactions properly in the MICC ecosystem

Consumer protection enforcement can also arise via general advertising/consumer rules, including scrutiny for misleading claims.

SIC reference point for consumer/advertising principles (example of 2025 SIC guidance on misleading advertising concepts):

Timeline and key dates (2025–2026) businesses should keep on a compliance calendar

Because the shift is happening through both draft instruments and final decrees, timing matters.

Key moments to track:

  • Late July 2025: press-reported circulation of a Justice Ministry draft decree proposing prescription-gated adult access via pharmacies.
  • October 27, 2025: issuance of Decree 1138 of 2025 updating the health-sector regulatory framework and enabling pharmacy dispensing under prescription for new finished-product pathways.
  • Five-month implementation windows: Decree 1138 includes mandates for additional technical regulation within defined timeframes (for example, provisions that anticipate further implementing rules in the months following entry into force).

Official Decree 1138 reference for monitoring implementation deadlines:

Practical takeaways for exporters, manufacturers, and pharmacy operators

For export-focused producers

  • Treat domestic pharmacy supply as a pharma-grade channel, not a secondary retail outlet.
  • Tighten QA around batch specs, stability, and labeling.
  • Stress-test your traceability from cultivation through packaging to downstream distribution.

For pharmacies and distributors

  • Prepare SOPs for controlled dispensing, including prescription validation and patient identity checks if required by implementing rules.
  • Build recall readiness: lot tracking at the point of dispense.
  • Train staff on what can—and cannot—be communicated publicly.

For investors and policy teams

  • Model market size realistically: a prescription gate can expand access but still limit uptake.
  • Watch for transitional supply rules that prioritize smaller domestic operators.
  • Monitor Congress separately: constitutional or statutory “adult use” proposals remain a distinct track from pharmacy-based prescription access.

Legislative tracking (Cámara de Representantes adult-use page):

What to do next

Colombia’s direction of travel is clear: the country is building a more scalable, controlled, and internationally legible system—one that can support both exports and a more accessible domestic Rx market. The compliance burden doesn’t shrink; it becomes more pharmacy-centered and data-driven.

To stay ahead, businesses should monitor:

  • Implementing technical rules under Decree 1138
  • MICC reporting updates and platform guidance
  • INVIMA positions on labeling, product categories, and Rx promotion
  • Any final text that explicitly defines dosage forms, THC thresholds, ID checks, and import recognition criteria

For compliance checklists, licensing workflow support, and ongoing regulatory monitoring, use https://cannabisregulations.ai/ to keep your team aligned as Colombia’s prescription-focused rollout evolves.