UNMC DEA Registration Information Center

AG Order No. 6754-2026 was published in the Federal Register on April 28, 2026, and became effective that same day. The order places certain marijuana products in Schedule III of the Controlled Substances Act: FDA-approved drug products containing marijuana and marijuana products subject to a state-issued medical cannabis license.

This is not full federal legalization. It does not apply to all cannabis activity. It creates a specific federal pathway for state-licensed medical cannabis activity and leaves non-medical cannabis activity outside the scope of the new registration protection.

The order creates an expedited DEA registration process for entities holding state medical cannabis licenses. Covered business activities include manufacturing, distribution, and dispensing of marijuana or marijuana products for medical purposes.

The order amends several parts of Title 21 of the Code of Federal Regulations, including:

21 CFR Part 1300 — Definitions
21 CFR Part 1301 — Registration of Manufacturers, Distributors, and Dispensers of Controlled Substances
21 CFR Part 1308 — Schedules of Controlled Substances
21 CFR Part 1312 — Importation and Exportation of Controlled Substances

The order directs the DEA to make every effort to process applications submitted within 60 days of publication within six months.

Because the order was published on April 28, 2026, businesses should treat June 26, 2026, as an urgent deadline and aim to complete and pay for the application before the 60-day window closes.

Unknown: DEA has not yet clearly explained the practical consequences for businesses that apply after the 60-day window.

Businesses should not panic; submit incomplete or inaccurate applications. There are no published limits on the number of businesses that may be registered under this process. Businesses should gather information, review their state license, consult appropriate advisors, and submit accurate applications before the 60-day window closes.

The order states that applicants who submit within the 60-day window may engage in medical marijuana manufacturing, distribution, and/or dispensing in conformity with their state-issued license while the application is pending.

But this is not the same as permanent approval. DEA may still deny registration after review if it determines that registration would be inconsistent with the public interest or with the requirements of the Single Convention.

State licensees seeking DEA registration may submit proof of a state medical cannabis license as evidence that they are authorized under state law. The order says a state license constitutes conclusive evidence that the applicant is authorized under state law to engage in the activity for which registration is sought.

This makes the state licensing structure extremely important. Businesses in states with clear medical cannabis licenses may be in a stronger position than businesses in states that have merged medical and adult-use systems or only issue adult-use licenses.

A DEA registration issued under this process cannot exceed the scope of the business’s state medical cannabis license. If the state medical cannabis license is suspended, revoked, or expires, the DEA registration is automatically suspended.

Businesses should immediately review state license renewal dates, ownership disclosures, facility approvals, inspection history, inventory tracking, local approvals, and any pending enforcement issues.

The order says the Administrator must register an applicant unless doing so would be inconsistent with the public interest under the relevant 21 U.S.C. § 823 factors or with the Single Convention.

Public-interest factors may include prior conviction records under federal or state law for the manufacture, distribution, or dispensing of controlled substances. Businesses with prior cannabis-related convictions, enforcement actions, license problems, ownership issues, or regulatory violations should consult counsel before submitting.

State-licensed businesses in medical-only states may be in a stronger position because their operations are easier to identify as medical cannabis activity.

Businesses in adult-use states, dual-license states, or unified-market states may need state officials to establish clearer medical-only licensing pathways, transferable medical endorsements, or other mechanisms to demonstrate compliance with AG Order No. 6754-2026.

This is one of the most urgent advocacy needs.

The order recognizes that state medical cannabis certifications or similar documents may be sufficient to permit dispensing, provided they include required information such as the patient’s name and address, the date and signature, and the issuing practitioner’s information.

Dispensaries should review patient verification procedures and make sure their systems can document that sales are limited to patients or caregivers authorized under state law.

The order is limited to medical cannabis activity. It expressly states that registrations under this section do not authorize the manufacture, distribution, dispensing, or use of marijuana or marijuana products for non-medical purposes.

This is one of the most important points for businesses in adult-use, dual-license, or unified-market states.

The order allows a single entity to be granted multiple types of registrations. A registered manufacturer may cultivate, produce, process, package, label, and transfer marijuana and marijuana products to registered distributors or other registered manufacturers, subject to the limits of its state license. A registered distributor may receive and transfer products to registered dispensers or other distributors. A registered dispenser may dispense to individuals authorized under state law to possess medical cannabis.

Businesses must answer DEA application questions truthfully. False or fraudulent information on a DEA application can carry serious federal penalties. This is not the place to guess, minimize, or “clean up” the facts.

If a question is unclear, businesses should document the uncertainty, seek legal or compliance guidance, and avoid submitting unsupported answers.

As the DEA warns on its website: “21 USC 843(d), states that any person who knowingly or intentionally furnishes false or fraudulent information in the application is subject to a term of imprisonment of not more than 4 years, and a fine under Title 18 of not more than $250,000, or both.”

The order is grounded in U.S. obligations under the Single Convention. For growers and manufacturers, that means issues like crop controls, quotas, DEA access, cultivation areas, and the nominal purchase-and-resale mechanism matter.

Cultivators and manufacturers should review cultivation areas, harvest records, storage practices, inventory controls, and state reporting systems.

The order states that, as a consequence of the rule, holders of state medical marijuana licenses will no longer be subject to the deduction disallowance imposed by Internal Revenue Code Section 280E, because 280E applies to businesses trafficking in Schedule I or II controlled substances.

The order also encourages Treasury to consider retrospective relief, but it makes clear that nothing in the rule is a determination of any business’s federal tax liability and that state licensees should consult tax counsel.

DEA has opened a medical marijuana dispensary registration portal: https://mmapplication.diversion.dea.gov/registration-instructions

Form 225 is for manufacturers, distributors, researchers, analytical laboratories, importers, and exporters:

https://apps.deadiversion.usdoj.gov/webforms2/spring/main?execution=e1s1

Medical Marijuana Manufacturer

Medical Marijuana Manuf (Bulk)

Medical Marijuana Distributor

Medical Marijuana Analytical Lab