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The upcoming deadline for medical marijuana entities to apply for DEA registration to ensure expedited review is Friday, June 26, 2026. There are still many unanswered questions about the federal government’s rescheduling of marijuana and how it will impact current licensees. Currently, only medical marijuana has been reclassified as Schedule III. There will be a DEA hearing on a broader rescheduling of marijuana, with such hearing being scheduled to begin on June 29, 2026.
We are recommending that all currently licensed medical marijuana entities in Oklahoma consider applying for DEA registration. There are currently three different registrations for different entities with different pricing:
- Manufacturers (i.e. Gowers and Processors) – may cultivate, produce, process, package, label, and transfer marijuana and products containing marijuana to registered distributors or other registered manufacturers ($3,699 annually).
- Dispensers (i.e. Dispensaries) – may dispense marijuana and products containing marijuana to individuals authorized by state law to possess marijuana and products containing marijuana for medical purposes ($888 For 3 years).
- Distributors – may receive marijuana and products containing marijuana from registered manufacturers and transfer marijuana and products containing marijuana to registered dispensers or other registered distributors ($1,850 annually).
Dispensaries have a dedicated application form that is available here. Manufacturers and distributors must use the current DEA Form 225a and select the appropriate business category. It is unclear whether the DEA will also be implementing a specific form in the future for manufacturers and distributors.
The Oklahoma State Bureau of Narcotics and Dangerous Drugs (“OBNDD”) has published its own guidance regarding medical marijuana manufacturers and distributors. OBNDD’s stated position is that manufacturer and distributor registrants are required to obtain DEA registration. The agency will refrain from pursuing any administrative actions against registrants until January 1, 2027. Notably, the guidance from OBNDD does not address whether it believes dispensers must also register with the DEA.
The Oklahoma Medical Marijuana Authority is not taking the same stringent approach as OBNDD and has instead stated that “[d]ispensaries choosing not to participate may continue to operate in accordance with the existing regulatory framework in Oklahoma and may still be eligible for potential tax breaks.”
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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