LPI: Thailand’s License per Invoice Import Permit

Q: Does a product registration certificate alone let you import into Thailand?

1. Key takeaways

No. Product registration in Thailand, whether listing, notification or licence, only confirms that the device is authorised for the market; it does not automatically release the goods. Every shipment must clear customs with an LPI, the License per Invoice, an import permit applied for shipment by shipment. The LPI is bound to the invoice, requires one application per invoice, and is a precondition for customs release. Only the licensed importer may apply, and the application is filed online through the Thai FDA National Single Window (NSW) system. Because the regulator checks every product model on the invoice, including accessories and spare parts, against the valid registration scope, the LPI stage is where non-compliant structures are finally exposed, no matter how smoothly registration went.

• Registration does not release goods. Product registration confirms market authorisation only; clearance still requires an LPI for each shipment.
• One invoice, one application. The LPI is bound to the invoice and is a precondition for customs release, applied for by the licensed importer.
• Application runs through the NSW. The licensed importer submits online via the Thai FDA National Single Window system.
• Review takes about 1 to 2 working days. The Thai FDA checks every product model on the invoice, including accessories and spare parts, against the valid registration scope.
• No LPI, no release. Without an LPI customs will not release the goods, and cargo stranded at the port incurs additional storage fees.
• Five delay causes recur. Inconsistent HS code classification, fluctuating declared values, late LPI submission, shipments mixing expired and valid products, and shipments involving multiple legal manufacturers.

2. Legal basis

The LPI requirement operates through the Thai FDA National Single Window system, through which the licensed importer submits the application. The application package consists of the importer establishment licence, the valid product registration certificate, and the original shipping documents, namely the bill of lading, the commercial invoice and the packing list. The Thai FDA then verifies the shipment against the registration scope, examining each product model listed on the invoice, including accessories and spare parts, to confirm it falls within a valid registration. Review takes approximately 1 to 2 working days. If no LPI has been granted, customs will not release the shipment, and goods held at the port will accrue additional storage fees. The practical effect of this design is that the licence holder and the importer of record must be the same entity: since only the licensed importer can apply for the LPI, any structure in which the certificate holder and the actual importing party are different entities simply cannot obtain the LPI. Many non-compliant arrangements pass through the registration stage, but they are inevitably exposed at the LPI stage, which is the operational-level manifestation of the three-in-one structure described elsewhere in this guide. For this reason the LPI should be read not as a routine shipping formality but as a recurring compliance gate: it re-tests, shipment after shipment, the same structural question that registration settled once, namely whether the entity that holds the certificate is genuinely the entity that imports the goods.

3. Expert insights

Five causes of customs delay appear repeatedly in practice, and each of them is avoidable with preparation done before departure rather than remediation after arrival. First, inconsistent HS code classification, where the code used in the filing does not match earlier shipments or the code the goods actually warrant. Second, fluctuation in the declared value between shipments, which invites questions at the border. Third, submitting the LPI too late, so that review time runs out while the vessel is already arriving. Fourth, a single shipment mixing products with expired and valid certificates; in the usual case partial clearance is not allowed, so the entire shipment is blocked because of the expired items inside it. Fifth, a single shipment involving multiple legal manufacturers, which complicates the model-by-model verification the Thai FDA performs against the invoice. Notice that all five causes concern consistency: consistent codes, consistent values, timely filings, homogeneous certificates and homogeneous manufacturers within one invoice. A shipment that is internally consistent gives the reviewing officer nothing to flag, and that is precisely what a disciplined pre-shipment routine achieves. The five pre-shipment checks described below cost only a few minutes each, yet they eliminate the great majority of port-stranding risk, which makes them among the highest-return compliance activities in the entire Thai import workflow.

4. Practical recommendations

• Make the LPI a fixed pre-shipment checkpoint. Treat it as a fixed pre-shipment check item, not a remedial action after the goods reach port.
• Run the five pre-shipment checks. Before dispatch, confirm: every model is within the valid registration scope; there are no items under expired certificates; HS codes are consistent; the declared value is consistent with previous shipments; and the shipment does not involve multiple manufacturers.
• Never mix expired and valid products in one shipment. Partial clearance is usually not allowed, so one expired item can hold the entire shipment at the border.
• Keep invoices homogeneous. Avoid involving multiple legal manufacturers in a single invoice, because the Thai FDA verifies each model on the invoice against the registration scope.
• File early enough to absorb review time. Since review takes about 1 to 2 working days, submit the LPI application early enough that the window is not consumed while cargo is already in port.
• Remember the storage-fee exposure. Goods stranded at the port generate additional storage fees, so the cost of a missed checkpoint compounds daily rather than staying fixed.

5. Verification checklist

• □ Thai FDA NSW National Single Window LPI application process
• □ LPI attributes: bound to the invoice, one application per invoice
• □ Application materials (establishment licence, product registration certificate, bill of lading / commercial invoice / packing list)
• □ Review of about 1 to 2 working days; no LPI means customs will not release
• □ Model-by-model verification rule (including accessories and spare parts)
• □ Common delay causes (HS codes, value fluctuation, late submission, mixed expired products, multiple manufacturers)

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support across Southeast Asia, including Thailand. Our team prepares dossiers to ASEAN CSDT structure, manages submissions and deficiency responses with the Thai FDA, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com