CANNABIS REFORM TAKES A NEW TURN

Federal cannabis policy is entering a new phase. The Trump administration's executive order to reclassify marijuana under the Controlled Substances Act (CSA) marks a historic shift with broad implications for regulatory compliance, research, and business strategy. While implementation details remain uncertain, stakeholders should prepare for evolving federal requirements.

On December 18, 2025, U.S. President Donald Trump signed Executive Order 14370, instructing the Attorney General to expedite the reclassification of cannabis under the Cannabis Substances Act (CSA). The executive order requires moving cannabis from Schedule I, where it has been listed since 1970 alongside heroin, to Schedule III, a category reserved for substances with accepted medical uses and lower potential for abuse, such as ketamine and testosterone. The most significant changes related to the reclassification concern medical use, FDA approval, prescription availability, CSA registration, research oversight, and manufacturing and distribution.

Reclassifying cannabis from Schedule I to Schedule III would represent a significant policy change, but it would not require state medical or recreational programs to comply with federal law. Schedule III drugs can be prescribed if approved by the FDA, but cannabis is not yet FDA-approved. If approved, companies would have to register with the DEA and comply with federal controlled substance regulations. Patients would also need valid prescriptions. These requirements differ from those of most state programs. Overall, reclassification does not unify state and federal systems. Instead, it creates a separate pathway between the FDA and the DEA that requires its own compliance planning.

The reclassification could ease some research barriers because Schedule III substances face less stringent CSA registration requirements than Schedule I substances. However, specialized procedures under the Medical Marijuana and Cannabidiol Research Expansion Act would still apply.

Alexandra Suárez

CHIEF FINANCIAL OFFICER

@highmommas