Regulation
DEA Sends 26-Question Form to Medical Marijuana Businesses Seeking Federal Rescheduling Protections
A questionnaire obtained by Marijuana Moment shows the DEA's Rocky Mountain Division asking Colorado dispensaries about interstate ordering, product types, suppliers, labeling, and disposal.
The DEA is sending a 26-question follow-up form to medical marijuana businesses in Colorado that register for federal protections under the Trump administration's cannabis rescheduling process. The questionnaire asks about interstate cannabis orders, synthetic cannabinoids, product categories, supplier details, packaging compliance, and disposal of defective products. Industry sources say inspection practices vary by DEA regional office, with Mississippi businesses reporting different questions from the New Orleans division.
The Drug Enforcement Administration is asking medical marijuana businesses seeking federal protections under cannabis rescheduling to answer a detailed 26-question form, according to a document obtained by Marijuana Moment. The questionnaire is being sent to Colorado operators that have filled out the DEA registration form for medical marijuana dispensaries.
The form is used by DEA's Rocky Mountain Division, which covers Colorado, Montana, Utah, and Wyoming, though Wyoming does not have legal medical cannabis. Questions include whether the business will order marijuana or marijuana products from other states, whether it will order synthetic cannabinoids, and whether it will order seeds or plants to grow at the dispensary location.
Businesses are also asked to identify specific product types such as gummies, extracts, concentrates, tinctures, topical products, oils, flower buds, oil cartridge vapes, dry herb vapes, and pre-rolled cannabis cigarettes. The form requests supplier names, addresses, and DEA registration numbers, and asks for copies of labeling, packaging, and sealing policies referencing Title 21 CFR § 1301.13(k)(8).
Another question asks how defective, expired, or discontinued marijuana products are disposed of, including mold, rot, and bug infestation. In June, Mississippi medical cannabis businesses told Marijuana Moment they were visited by DEA officials and asked similar questions, though the New Orleans division's list was not identical, covering license transfers, state disciplinary history, and security plans.
The DEA press office did not respond to a request for comment about why the agency has not standardized the registration process across regions. The agency launched its initial dispensary registration form in April, days after Attorney General Blanche issued an order moving state-licensed medical marijuana products from Schedule I to Schedule III of the Controlled Substances Act.
The currently available registration form asks about storage, ordering, dispensing, inventory, record maintenance, security measures, and whether the firm handles recreational marijuana. It also asks whether anyone involved in ownership or operation previously manufactured, distributed, or dispensed a controlled substance without DEA registration, a question that likely applies to all currently operational state-legal cannabis businesses.
The Treasury Department and IRS plan to issue new tax guidance following rescheduling, which will allow state-licensed marijuana businesses to take federal deductions previously barred under IRS code 280E. The ATF posted a draft update to gun purchase forms acknowledging the federally legal status of medical marijuana, and the Congressional Research Service published a report on the rescheduling move's scope and limitations.