In our April 30, 2026 blog post, we reported that the DEA application portal for expedited registration of medical marijuana dispensaries was open, and noted that "the DEA application form for expedited registration of medical marijuana manufacturing and distribution businesses is not yet available." In the past 48 hours, DEA has now published registration links specific to medical marijuana manufacturers, distributors, and analytical labs on its Diversion Control Division online registration portal.

The new applications arrive after a somewhat long wait. Earlier this summer, DEA said that updated "Medical Marijuana Manufacturer," "Medical Marijuana Bulk Manufacturer (Grower/Cultivator)," "Medical Marijuana Analytical Lab," and "Medical Marijuana Distributor" applications would be available "[i]n the coming weeks." In the meantime, DEA allowed applicants to use the existing Form 225. Note that DEA guidance suggests that anyone who previously submitted a Form 225 likely does not have to reapply using the new registration form, but should speak with counsel to determine whether there are any other action items that need to be taken.

The new registration applications are accessible through DEA's standard CSA Registration Online Management Tool and require applicants to submit a host of business information, including taxpayer identification, business activity and schedules, state licenses, background information, drug codes, manufacturer details, and payment.

As we said about the dispensary application, DEA registration has likely benefits, including possible access to export licenses and interstate commerce if and when federal and/or state law permits it, and may be a necessary compliance measure for banking, exchange listing, credit facilities, and/or mergers and acquisitions. Please reach out to our team if you are evaluating whether DEA registration is appropriate or beneficial for your manufacturing, distribution, or testing business, or if you would like a consultation on specific questions and standard operating procedure review. Below are some key highlights of the new medical marijuana registration application:

Personal/Business Information

This section asks for the business name (limited to 50 characters), business address, phone number, email, contact name, contact cell phone number, and a mailing address. Applicants must also give a Social Security Number or Taxpayer Identification Number. A fee exemption is available only to certified government employees or institutions operated by a government agency.

Business Activity/Schedules

The applicant must select the drug schedules it will handle, with Schedule III Non-Narcotic as the available option. As with the dispensary application, the applicant must disclose whether it will be handling medical marijuana AND whether it will be handling recreational marijuana.

State License(s)

This section requires the state license number, state, and expiration date. The form warns that "[f]ailure to provide VALID and ACTIVE state licenses will be cause to declare the application as defective and it will be withdrawn WITHOUT refund."

Background Information

Applicants must answer four questions about criminal history, federal controlled substance registration history, and state professional license or registration history. The dispensary application had five liability questions. The following question caught our attention in particular:

• If the applicant is a corporation (other than a publicly traded corporation), association, partnership, or pharmacy, has any officer, partner, stockholder, or proprietor been convicted of a controlled-substance crime, had a federal registration or state license revoked, suspended, restricted, denied, or placed on probation, or is any such action pending?

This question reaches every officer, partner, stockholder, and proprietor, so applicants should conduct a careful internal review before answering.

Drug Codes

Applicants handling medical marijuana must select only the applicable drug codes:

• 7362 (Marijuana)
• 7353 (Marijuana Extract)
• 7386 (Naturally derived delta-9-tetrahydrocannabinols in an FDA-approved product or in marijuana subject to a state medical marijuana license)

Bulk manufacturer (synthesizer/extractor) applicants must also check the "Bulk" box for each Schedule I and II substance they plan to manufacture in bulk, and must make at least one bulk selection.

Manufacturer Details

Applicants must mark the applicable category for Schedule IIIN activity: Bulk, Growing, Extraction, Processing, and/or Repackager. Vertically integrated operators should carefully consider which categories match their actual operations.

Payment

The manufacturer application carries a non-refundable $3,699 fee.

The distributor application carries a non-refundable $1,850 fee.

The analytical lab application carries a non-refundable $296 fee.

Notably, the manufacturer application does not appear to include the detailed compliance section of the dispensary application, which covered supplier identification, SOPs, personnel with access to controlled substances, and security measures. Operators should still expect DEA to look at these issues during review and inspection, as we discussed in our July blog post.

Our cannabis team continues to track all developments in the DEA registration process for medical marijuana businesses, along with the broader rescheduling hearing. Please reach out to us with any questions.