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ARTICLE · 29 JULY 2026

What California Operators Must Do After Rescheduling: DEA Registration, License Restructuring, And 280E

Harris Sliwoski
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On April 23, 2026, the DEA rescheduled certain marijuana products from Schedule I to Schedule III, creating new compliance obligations for California cannabis operators. This shift primarily affects state-licensed medical cannabis programs and introduces critical decisions around DEA registration, license restructuring, and IRC Section 280E tax implications that operators must navigate strategically.

United StatesCannabis & Hemp
Jared Schwass
Jared Schwass
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On April 23, 2026, the DOJ and DEA issued a final order rescheduling certain marijuana products from Schedule I to Schedule III of the Controlled Substances Act. The order is subject to litigation, but it remains in effect for now.

The shift applies primarily to FDA-approved cannabis-derived drug products and state-licensed medical cannabis programs that meet federal criteria, not adult-use cannabis. For California operators, it opens a path out of 280E for qualifying medical activity, but it also introduces new federal expectations and deadlines.

In this post, we focus on three questions California cannabis businesses should be asking themselves:

  1. Are we going to hop into the Schedule III framework?

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