Following the reclassification of medical marijuana to Schedule III of the Controlled Substances Act, state-licensed medical marijuana businesses must obtain DEA registration to manufacture, distribute, dispense, import, or export medical marijuana.
Through June 26, expedited DEA registration is available to state-licensed medical marijuana businesses engaged dispensing, manufacturing, and distributing medical marijuana. Applications submitted by this deadline are expected to receive a response within six months of submission, and businesses will be permitted to engage in the manufacture, distribution, and/or dispensing of medical marijuana products consistent with their state-issued licenses during the pendency of their application.
While businesses will still be able to apply for DEA registration after the June 26 deadline, they will not receive the benefits of expedited processing or continued operations during the pendency of their applications.
Under the expedited registration process, state medical marijuana licenses may be submitted as conclusive evidence of state-law authorization. Please note that the DEA will grant the registration unless doing so would be inconsistent with the public interest or international treaty obligations.
State-issued medical marijuana license holders may complete registration on or before June 26 via the DEA Application Portal.
Not a medical marijuana license holder and wish to become one? Massachusetts has eliminated the requirement that medical marijuana establishments vertically integrate their cultivation, processing, and dispensing functions (see Conference Bill 5350). New licenses will permit medical marijuana establishments to conduct any of those activities in isolation, but such licenses will only be available to social equity businesses for the first two years after the bill goes into effect.
If you have any questions, please do not hesitate to contact Michael Ross (mross@princelobel.com), Max Riffin (mriffin@princelobel.com) or anyone from our Cannabis Team.