July 17, 2024 — The Cannabis Regulators Association submitted a comment on the proposed federal rule rescheduling marijuana (Docket No. DEA-1362). The comment does not take a position on rescheduling, but rather focuses on the implementation of the proposed federal rescheduling in U.S. states and territories.
The comment calls for additional federal guidance in six areas to support state and territorial regulators in being able to implement the policy:
1. Guidance is needed on how federal priorities, including enforcement priorities, will change under the proposed rescheduling.
2. Guidance is needed on how federal agencies will engage with states and territories under the proposed rescheduling.
3. Guidance is needed on how state governments can interact with each other under the proposed rescheduling.
4. Guidance is needed on how research processes and protocols will change under the proposed rescheduling.
5. Guidance is needed on how to regulate cannabinoids that appear in two different places on the schedule due to the federal legalization of hemp.
6. Guidance is needed on how the proposed rescheduling will impact banking and finance directives and policies.
Guidance in these six areas is vital to the successful implementation of the final rule on rescheduling. Without it, state and territorial government agencies will be left to guess and hypothesize about federal-state dynamics and the potential impacts on state-regulated programs, the state populations affected by those programs, and the states in which those programs operate.
CANNRA remains committed to supporting our members in successfully implementing whatever the final rule on rescheduling is, and respectfully calls on the DEA, the DOJ, and other engaged federal agencies to issue appropriate guidance to guide implementation.
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