The Drug Enforcement Administration (DEA) has launched registration forms written for medical marijuana manufacturers, distributors and analytical labs, not only dispensaries. For California operators whose medical products move through those steps, the change matters because the forms ask about state licensing, medical and adult-use activity, and the criminal and disciplinary history of key personnel.
The details below come from Marijuana Moment’s October 6, 2026 report, which credits Cannabis Business Times for the fee figures. Check the current form and link on DEA’s Diversion Control Division site before you file.
What changed
The Attorney General’s April order moved state-licensed medical marijuana products, along with FDA-approved products, from Schedule I to Schedule III of the Controlled Substances Act. The order covered only those two groups of products. Dispensaries began registering with a new DEA form that same month. Manufacturers, distributors and analytical labs had been able to apply through a standardized federal form, but DEA now has specific registration links for each of them, using a new version of DEA Form 225. A separate DEA hearing on broader rescheduling recently concluded testimony, according to the same report.
The right form depends on which activity the business is registering for, so settle that question before you start an application.
What the form asks
According to the report, the form asks whether the business will handle medical marijuana, recreational marijuana or both, and it requires state license information. It also asks whether the business will work with marijuana, marijuana extract or naturally derived delta-9 THC in a product subject to a state medical license or an FDA-approved product. Applicants must answer questions about the criminal and disciplinary history of the business and its key personnel.
For a California operator that holds both medicinal and adult-use authority, the first question needs a careful answer. DCC’s emergency rule DCC-2026-03-E, effective June 4, 2026 and expiring December 2, 2026, allows existing licensees with combined medicinal and adult-use designations to be issued separate licenses. It also allows those licenses to be issued to a different legal entity if certain requirements are met. Your DEA answers should match how your state licenses are actually structured. Keep a copy of each answer with your DCC license records so the two files tell the same story.
Fees and the dispensary path
The report gives nonrefundable application fees of $3,699 for medical marijuana manufacturers, $1,850 for distributors and $296 for testing labs. Because those figures come from Cannabis Business Times, confirm them on the DEA form before you pay. Because the fee is nonrefundable, an application filed for the wrong activity or with incomplete personnel answers costs money as well as time.
Dispensaries have a different path. They previously could use a specialized form during a 60-day window for expedited consideration, and the report says dispensaries that still want to register can now use the standard DEA Form 224. DEA’s Diversion Control homepage, however, still tells medical marijuana dispensary applicants to apply through a dedicated online portal. Until those line up, confirm which route DEA expects before you apply.
Key personnel history belongs in the file
The report describes DEA personnel conducting inspections of dispensaries that applied earlier, and says the approach varies between DEA’s regional offices. It also describes one dispensary owner who was told that two employees with past felony convictions would require the business to fire them, withdraw its application, seek a waiver that makes it ineligible for expedited processing, or go before a DEA judge. Whatever the outcome in that case, the lesson for any applicant is clear: screen key personnel before you file, not after DEA asks.
The inspections themselves deserve preparation. The same report notes that DEA officials visited Mississippi medical cannabis businesses in June and sent Colorado applicants a list of 26 questions in August, many of them different from those asked in Mississippi. Keep security, inventory and personnel records current, and name one person to handle DEA contact.
What to do now
- Decide which DEA role your business is registering for, and answer the medical versus adult-use question for each entity.
- Pull criminal and disciplinary histories for key personnel now and write down how each case would be handled.
- Match your DEA answers to your DCC license structure, including any combined A/M designation.
- Budget the nonrefundable fee and confirm the current form link on DEA’s Diversion Control Division site before filing.
If you need help matching your DEA and DCC paperwork before you file, book a consultation or call (209) 636-4856.
Sources
- DEA Launches New Registration Forms For Medical Marijuana Manufacturers, Distributors And Testing Labs — Marijuana Moment, 2026-10-06
- DCC-2026-03-E: Modifications to A and M Designation — California Department of Cannabis Control, 2026-06-04
- DEA Diversion Control Division — U.S. Drug Enforcement Administration
This article provides general educational information and does not constitute legal advice. Consult qualified counsel regarding specific facts or jurisdictional requirements.