The expedition provision in 21 CFR 1301.13(k)(7) applied to applications submitted within 60 days of the Final Order's publication in the Federal Register on April 28, 2026, and that period ended in late June. DEA continues to accept applications from state licensed medical operators under the same regulation. What changed for later applicants is the timing of review and the authority to operate while an application is pending. The standard DEA applies, and the preparation that supports a clean review, are the same.
What the expedition provision provided
Paragraph (k)(7) did two things for applicants who filed within the 60 day period. It directed the Administrator to make every effort to process their applications within six months. It also allowed them, notwithstanding 21 CFR 1301.13(a), to continue manufacturing, distributing, or dispensing medical marijuana in conformity with their state license while the application was pending.
What applies to applications filed now
An application filed after the expedition period is governed by the general rule in 21 CFR 1301.13(a). Any person required to be registered may apply at any time, and no person required to be registered may engage in the activity for which registration is required until the application is granted and a Certificate of Registration is issued. A later applicant's state licensed operations continue under state law, and the federal authority to conduct them begins on the date DEA issues the registration. Review proceeds without the six month processing goal.
For operators that have not filed, 21 U.S.C. 822 requires registration of every person who manufactures, distributes, or dispenses a controlled substance. Marijuana subject to a state medical license has been a Schedule III substance since April 28, 2026. Filing establishes the operator's position with DEA and starts the review that leads to registration.
The standard for approval
The substantive standard is unchanged by the date of filing. Under 1301.13(k), the Administrator registers an applicant holding a state medical marijuana license unless registration would be inconsistent with the public interest under the factors in 21 U.S.C. 823 or with the Single Convention on Narcotic Drugs. The regulation adds that registration of an applicant operating under a state regime with robust protections against diversion, recordkeeping and reporting requirements, and safety and inspection measures will generally be consistent with the public interest. Under paragraph (k)(2), the state license is conclusive evidence that the applicant is authorized under state law for the activity. Under paragraph (k)(3), the registration cannot exceed the scope of the state license, and it is automatically suspended if the state license is suspended, revoked, or expires.
Choosing the right registrations
Paragraph (k)(1) establishes three registration types. A registered manufacturer may cultivate, produce, process, package, label, and transfer marijuana to registered distributors or other registered manufacturers. A registered distributor may receive product from registered manufacturers and transfer it to registered dispensers or other registered distributors. A registered dispenser may dispense to individuals authorized by state law to possess marijuana for medical purposes. A single entity may hold multiple registration types, and under 21 CFR 1301.12 a separate registration is required for each principal place of business where controlled substances are handled.
A vertically integrated operator with a cultivation site, a processing facility, and several dispensaries will usually need a registration for each activity at each location. Dispensers apply through DEA's Medical Marijuana Dispensary Registration Portal. DEA has directed manufacturers and distributors to apply on Form 225 while it prepares dedicated Schedule III applications, and it has stated that applicants who already filed on Form 225 do not need to reapply. Dispensing registrations run three years, and manufacturing and distributing registrations run one year, under the schedule in 21 CFR 1301.13(e)(1). Manufacturers also enter the crop purchase and storage framework in paragraph (k)(6).
What happens after filing
After an application is filed, a Diversion Investigator from the regional field office makes contact, issues a written request for supporting documents, and conducts an inspection of the facility. Under 21 CFR 1316.07, no administrative warrant is required to inspect an establishment applying for initial registration.
If DEA concludes that registration would be inconsistent with the public interest, it serves an Order to Show Cause under 21 U.S.C. 824(c) and 21 CFR 1301.37, and the applicant may request a hearing under 21 CFR 1301.43. Investigators have also raised issues informally before that stage. The Mississippi dispensary we wrote about in our employee screening article received options from its investigator that included seeking a waiver or referring the application for an Order to Show Cause. Issues identified and resolved in the application file before filing do not reach that stage.
Operators with adult use lines
Registrations under paragraph (k) do not authorize the manufacture, distribution, or dispensing of marijuana for nonmedical purposes, as stated in paragraph (k)(1)(iv). An operator that also holds adult use licenses should expect the investigator to ask how medical inventory, records, and activity are separated from adult use operations at shared locations. The answer should be documented in SOPs and visible in the state tracking records.
Preparing a complete application
A complete application starts with confirming that each state license covers the activity and location for which registration is sought. From there, the operator maps the registrations required by activity and location, screens every person with access to controlled substances against 21 CFR 1301.76(a) and 1301.90, reconciles the ownership disclosures on the application to the entity's actual structure, indexes SOPs to the federal provisions they satisfy, and establishes the inventory baseline that will support the initial inventory under 21 CFR 1304.11.