Points I took away from the DEA's cannabis rescheduling notice they submitted to the federal register today
see PDF: Schedules of Controlled Substances: Rescheduling of Marijuana
1) Growers, Processors, transporters, dispensaries/pharmacies will all be required to get a DEA registration (you can’t get a DEA registration if you’ve ever had a drug conviction or felony). Employees of DEA registered facilities who have had a felony have to get a DEA waiver in order to be able to work.
2) No interstate commerce will be allowed without an FDA trial and the FDA approval (all stages of FDA clinical trials add up to around 50 million dollars).
3) All rules, regulations, federal laws pertaining to schedule III drugs will apply to cannabis to honor international treaties (This includes prescriptions by doctors and dispensing by pharmacist).
4) Synthesized compounds such as D8, D10, HHC, THCP, etc. will remain schedule I. They will not be moved down to schedule III.
5) GMP, GMP, GMP. GMP will be required. This is a huge one. This is something everyone needs to look into and see if this is an undertaking they are willing to tackle. It’s very time consuming and very expensive. It most likely means 100’s of thousands of dollars needing to be spent to get a facility up to a point to be able to be certified but 100% required to deal with the FDA. (For instance, I see it as almost near impossible to get GMP certified with exposed spray foam insulation).
6) The notice made it clear that manufacturing of schedule III without proper registrations will be subject to current federal laws concerning illegal manufacturing of Schedule III drugs. (Believe first time offense is something like 5 years and a fine around $250k). The way the notice reads, this would apply to home grows.
7) It almost appeared as if they are wanting to go the qualified conditions route. They mentioned specific illnesses and effectiveness of marijuana with those illnesses. They also made sure to mention a moderate risk of dependency.
One thing for certain is the landscape is about to change dramatically, Follow our Instagram below and other channels to stay up to date with further insight and information!