The 60-day window for medical cannabis companies to apply for expedited registration with the Drug Enforcement Administration (DEA) has come and gone, but a new application process is now open for those who have yet to apply.
The DEA’s Diversion Control Division launched the new application process on Oct. 5 for medical cannabis manufacturers (to cultivate, produce, process, package, label and transfer cannabis), distributors (to receive and transfer cannabis) and analytical labs (to test cannabis) wishing to take advantage of a Schedule III status under the Controlled Substances Act (CSA). These businesses can register under DEA Form 225.
The application registration online management tool for these three license types has been listed as “coming soon” on the division’s website since May.
Medical cannabis dispensaries, meanwhile, can still use DEA Form 224 to register, which was open to licensed retailers during the 60-day expedited window that concluded in June, a deadline that guaranteed the DEA would review their applications within six months. The DEA “must grant registration unless doing so would be inconsistent with public interest under 21 U.S.C. 823,” according to a Trump administration order.
Manufacturers, distributors or laboratories that already submitted their applications to handle Schedule III medical cannabis do not need to reapply, according to the DEA. “We will be in contact with you shortly to continue processing your application,” its website states.
The new registration portal for manufacturers, distributors and labs under Form 225 comes more than five months after then-U.S. Acting Attorney General Todd Blanche announced on April 23 that he signed an order to “immediately” reschedule state-licensed medical cannabis and cannabis products from Schedule I to III under the CSA.
This rescheduling action provides medical cannabis businesses with Section 280E tax relief under the Internal Revenue Code, which otherwise forbids businesses trafficking in a Schedule I or II controlled substance from claiming ordinary business deductions, such as payroll, rent and utilities. A Schedule III listing also provides medical cannabis businesses with the recognition that their products have currently accepted medical use under federal law.
Legal experts have since debated whether businesses must register with the DEA to unlock their 280E allowances and to gain other scheduling-related benefits, such as continuing to do supply chain business with other licensees who chose to register with the DEA.
That said, congressional researchers determined in May that medical cannabis businesses “need to register” with the DEA to be Schedule III compliant but did not go into broad detail about what exactly that meant.
When signing the order, Blanche indicated that the registration process would help satisfy U.S. compliance obligations under the United Nations Single Convention on Narcotic Drugs, an international drug treaty that requires a certain amount of federal oversight to prevent diversion.
“The attorney general has determined that incorporating state licensing systems into the federal registration framework represents the most effective and efficient means of achieving the CSA’s objectives with respect to medical marijuana while promoting the medical benefits of marijuana and causing the least disruption for patients and existing state systems,” Blanche wrote in his April 2026 order. “The rule accordingly leverages existing regulatory infrastructure while preserving the administrator’s authority to deny or revoke registration where specific public-interest concerns arise and to ensure compliance with the Single Convention.”
The online Form 225 registration process for new applicants consists of six sections:
- Section 1. Personal/Business Information
- Section 1b. Email Address Validation
- Section 2. Business Activity/Schedule
- Section 3. State License(s)
- Section 4. Background Information
- Section 5. Payment
- Section 6. Confirmation
The business activity section asks applicants to check off a “Schedule III Non-Narcotic” box and asks:
- Will your firm be handling medical marijuana?
- Will your firm be handling recreational marijuana?
The application also requires businesses to provide their state license number and expiration date.
The background section is where potential applicants will likely grapple the most when deciding whether to submit their registration. It specifically asks:
- Has the applicant ever been convicted of a crime in connection with controlled substance(s) under state or federal law, or been excluded or directed to be excluded from participation in a Medicare or state health care program, or is any such action pending?
- Has the applicant ever surrendered (for cause) or had a federal controlled substance registration revoked, suspended, restricted or denied, or is any such action pending?
- Has the applicant ever surrendered (for cause) or had a state professional license or controlled substance registration revoked, suspended, denied, restricted or placed on probation, or is any such action pending?
- If the applicant is a corporation (other than a corporation whose stock is owned and traded by the public), association, partnership or pharmacy, has any officer, partner, stockholder or proprietor been convicted of a crime in connection with controlled substance(s) under state or federal law, or ever surrendered or had a federal controlled substance registration revoked, suspended, restricted or denied, or ever had a state professional license or controlled substance registration revoked, suspended, denied, restricted, or placed on probation, or is any such action pending?
Those who answer yes to any of the above questions will need to provide a date and location, as well as written explanations of the nature and results of the convictions or actions.
Applicants also must provide information on what types of substances they’ll be handling under the DEA registration, including:
- Marijuana;
- Marijuana extract; and/or
- Naturally derived delta-9 THC in a U.S. Food and Drug Administration-approved product or in marijuana subject to a state medical marijuana license.
Depending on one’s license type, applicants must provide certain business activity details, such as whether they’re involved in bulk growing, extraction, processing and/or repackaging.
Payment via the online application must be made with a credit card, such as Visa or MasterCard, or American Express or Discover. Some businesses might find this peculiar given credit card payment networks like Visa and MasterCard prohibit their cards from being used for cannabis purchases, creating one of the many bottlenecks for cannabis entrepreneurs seeking access to traditional financial services.
The one-year, nonrefundable application fees are listed at $3,699 for medical cannabis manufacturers, $1,850 for medical cannabis distributors and $296 for analytical labs under the Form 225 tab.
Under the expedited registration process for medical cannabis dispensaries from earlier this year, the DEA required either a bank-to-bank transfer through an automated clearing house (ACH) or PayPal as forms of payment for the $794 nonrefundable application fee.
The Diversion Control Division’s website provides a warning that under 21 USC 843(d), 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 four years, and a fine under Title 18 of not more than $250,000, or both.”
