Another name heard often is happy water, commonly misunderstood as a single substance with a settled formula. The truth is the opposite.

The UNODC records that happy water remains prevalent across the region, with multiple countries continuing to report detections, often with different combinations of substances identified in each country.

For Thailand, 21 samples of happy water were analysed in 2025. MDMA, ketamine, nimetazepam and caffeine were the most commonly identified combinations, followed by methamphetamine and diazepam. Other substances found include nitrazepam, diazepam, and PMK, a direct precursor for MDMA.

The format has changed too. Happy water first emerged in the region as a powdered product in packets to be dissolved in liquids, but it has now been seized in liquid form as well, and has also been found in canned packaging.

What this tells a user is that a person buying happy water has no way of knowing what they are consuming, and no way of knowing whether the next packet will match the last one.

Source: https://www.unodc.org/roseap/uploads/documents/Publications/2026/Synthetic_Drugs_in_East_and_Southeast_Asia_2026.pdf

 

The Chase the Law Tends to Lose

The central difficulty with new psychoactive substances is that once one substance is controlled, manufacturers adjust the formula slightly to produce a new one the law does not yet cover.

The UNODC provides a very clear set of figures. Following regulatory control of etomidate in China in 2023, the number of etomidate analogue samples analysed in that country jumped from only two samples in 2023 to 50 samples in 2024 and 93 samples in 2025, accounting for 37.8 per cent of all analysed samples.

The shift is not only to analogues but to entirely different substances. The report records that tiletamine, another dissociative anaesthetic, has emerged in the Chinese e-liquid market as a substitute for etomidate following controls on that substance, with samples received by China's forensic laboratory rising from 35 in 2024 to 89 in 2025.

The report summarises the pattern: although legal controls on new psychoactive substances have been implemented, traffickers have adapted and sought new ways to circumvent these controls, including by turning to pharmaceutical products such as etomidate and its analogues.

Source: https://www.unodc.org/roseap/uploads/documents/Publications/2026/Synthetic_Drugs_in_East_and_Southeast_Asia_2026.pdf

 

Hong Kong Chose to Close the Whole Class

Hong Kong answered this problem differently. Rather than scheduling one substance at a time, the government issued an order amending the First Schedule to the Dangerous Drugs Ordinance, effective from 18 July 2025, under which all analogues of etomidate became dangerous drugs.

A government spokesperson gave the reasoning: recent scientific analysis had shown that certain analogues of etomidate may potentially be abused, and the government was therefore taking a pre-emptive step to strengthen the control of all etomidate analogues.

The penalties under that ordinance are a maximum of life imprisonment and a fine of 5 million Hong Kong dollars for trafficking and manufacturing, and a maximum of seven years' imprisonment and a fine of 1 million Hong Kong dollars for possession and consumption.

Source: https://www.info.gov.hk/gia/general/202507/16/P2025071600662.htm

 

Lessons for Thailand

This subject differs from many covered before, in that Thailand is not lagging behind. Etomidate has been controlled here since July 2568 of the Buddhist Era, ahead of several other countries in the region.

The question worth asking next is therefore not whether the response was late, but whether the instrument issued covers only the named substance or the whole class of analogues alongside it. The Chinese figures show plainly that analogues follow within a year of control, and rose from two samples to ninety-three within two years.

The second observation is that the origin of this problem was a side effect of a measure that worked. China successfully closed off one class of substances, and the market moved to a hospital drug instead. Effective control therefore does not mean the problem is over. It means preparing to watch for whatever arrives in its place.

The third observation concerns the public directly. A vape bought on the underground market carries no label that tells the truth, and happy water has no fixed recipe, so a user has no way of knowing what is entering their body. The risk here does not lie in the potency of a substance alone. It lies in not knowing what the substance is.

What this teaches is that controlling drugs is work that no single instrument can finish, because the other side can reformulate faster than a legislative process can follow. A system that genuinely copes needs both continuous laboratory surveillance and a legal mechanism able to close a whole class at once rather than one substance at a time.