Priority Filing Window — Open Through June 27, 2026. Applications filed within 60 days of the April 28, 2026 publication of AG Order No. 6754-2026 receive priority processing (decision within six months under § 1301.13(k)(7)) and conditional operating authority during pendency. After June 27, the registration pathway remains available without those advantages.

Massachusetts Medical Marijuana Treatment Centers holding a current Cannabis Control Commission medical license may apply for federal Drug Enforcement Administration registration as a manufacturer, distributor, or dispenser under the expedited pathway at 21 C.F.R. § 1301.13(k). Massachusetts’s defining structural feature is the co-location pattern: most MTCs operate medical and adult-use cannabis from the same physical premises under separate but parallel CCC licenses, with shared inventory, shared staff, and shared retail floor space. The federal Schedule III pathway covers only the medical side of that operation, and the federal-application work for a Massachusetts MTC is fundamentally a problem of cleanly separating and documenting the medical operation inside an integrated retail environment.

This page is for Massachusetts MTCs evaluating the federal pathway and for adult-use Marijuana Establishment operators who need clarity on whether Schedule III applies to their licenses. Kocot Law is admitted in California, Massachusetts, and New York and represents cannabis operators on the federal side of DEA registration in coordination with Massachusetts CCC compliance.

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The Massachusetts Federal Posture

Massachusetts is a dual-market state administered by a single regulatory agency. The Cannabis Control Commission, established under Chapter 55 of the Acts of 2017, oversees two parallel licensing programs:

• The medical cannabis program under M.G.L. ch. 94I (the Humanitarian Medical Use of Marijuana Act, passed by ballot initiative in 2012), with implementing regulations at 935 CMR 501.000.
• The adult-use cannabis program under M.G.L. ch. 94G (the Regulation and Taxation of Marijuana Act, passed by ballot initiative in 2016), with implementing regulations at 935 CMR 500.000.

The unified-regulator structure is unusual. Most dual-market states maintain separate agencies or separate divisions for medical and adult-use. The CCC’s combined administration creates operational efficiencies for licensees, but it does not create federal Schedule III coverage for adult-use activity. The April 2026 federal order rescheduled marijuana to Schedule III only when it is in an FDA-approved drug product or subject to a state medical marijuana license. For Massachusetts operators, only MTC operations licensed under M.G.L. ch. 94I and 935 CMR 501 qualify for the § 1301.13(k) pathway. Adult-use Marijuana Establishment licenses issued under M.G.L. ch. 94G — including Marijuana Cultivators, Product Manufacturers, Retailers, Microbusinesses, Craft Marijuana Cooperatives, Independent Testing Laboratories, Marijuana Research Facilities, Transporters, Delivery Operators, Delivery Couriers, and Social Consumption Establishments — remain outside Schedule III and have no § 1301.13(k) pathway.

Under § 1301.13(k)(2), a valid CCC medical cannabis license is “conclusive evidence that the applicant is authorized under state law to engage in the activity for which registration is sought.” Under § 1301.13(k)(3), DEA registration automatically suspends upon suspension, revocation, or expiration of the underlying state license. Federal scope cannot exceed state scope.

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How Massachusetts’s Medical Cannabis Program Reached This Point

Authority	Year	Effect
Question 3 — Humanitarian Medical Use of Marijuana Act	2012	M.G.L. ch. 94I. Established the medical cannabis program by ballot initiative. Originally administered by the Department of Public Health.
DPH medical regulations	2013	Original medical regulations promulgated at 105 CMR 725.000.
First Registered Marijuana Dispensaries licensed	2015	DPH licensed initial RMDs as vertically integrated entities authorized to cultivate, process, and dispense medical cannabis.
Question 4 — Regulation and Taxation of Marijuana Act	2016	M.G.L. ch. 94G. Established the adult-use program by ballot initiative.
Chapter 55 of the Acts of 2017	2017	Created the Cannabis Control Commission as the unified state regulator.
CCC operational and DPH-to-CCC transition	2018	CCC assumed administration of both medical and adult-use programs. RMD licenses renamed Medical Marijuana Treatment Center (MTC) licenses. Medical regulations republished at 935 CMR 501.000.
Adult-use retail sales begin	2018	First adult-use Marijuana Establishments licensed; many existing MTCs added co-located ME licenses.
Chapter 180 of the Acts of 2022 — Cannabis Equity Reform Act	2022	Reformed Host Community Agreement framework; capped community impact fees; granted CCC review authority over HCAs.
AG Order No. 6754-2026	April 28, 2026	Schedule III placement for state-medical-licensed marijuana; expedited DEA registration pathway at 21 C.F.R. § 1301.13(k).

The practical consequence: every Massachusetts MTC originally licensed before mid-2018 has an operating history that spans two regulatory agencies (DPH 2013-2018; CCC 2018-present), two regulatory frameworks (105 CMR 725.000 under DPH; 935 CMR 501.000 under CCC).

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The Central Massachusetts Issue: MTC and ME Co-Location

The defining federal-application question for a Massachusetts MTC is the co-location problem. The majority of MTCs in Massachusetts operate co-located MTC and Marijuana Establishment retail operations from the same physical premises, with overlapping inventory, overlapping staff, and combined or adjacent retail floors. The CCC’s regulatory framework permits this co-location and has formalized it through specific operational rules at 935 CMR 500.140 and 935 CMR 501.140.

For DEA purposes, the federal Schedule III pathway covers only the MTC dispensing function. The adult-use Marijuana Establishment function on the same premises remains Schedule I activity under federal law and falls entirely outside the scope of any DEA registration that the MTC obtains under § 1301.13(k).

Three operational consequences follow:

• Inventory separation. Federally, the medical inventory must be identifiable as such. CCC requires MTCs and MEs to maintain separate seed-to-sale tracking accounts in METRC, which provides the foundation for the medical/adult-use distinction. The operational practice of staffing, displaying, and selling medical and adult-use product through the same or adjacent retail areas requires a defensible separation protocol before DEA registration. Section 1301.13(k)(10) accepts state physical-security requirements, but the categorization of which inventory is which must be documented in a manner defensible during DEA inspection.
• Patient-facing dispensing records. Section 1301.13(k)(5) accepts a state-law-sufficient certification document if it is signed and dated on the day issued, contains the patient’s full name and address, and includes the practitioner’s name, address, and state license number. Massachusetts’s certifying healthcare provider framework under 935 CMR 501.020 generally captures these elements at the certification level, but the specific records produced for each patient should be reviewed before federal application. Pre-2018 patient records produced under DPH’s 105 CMR 725.000 framework may have different documentation conventions than post-2018 records under CCC.
• Cross-channel transactions. A patient who is also an adult-use customer cannot have their transaction recorded as a single sale across both channels. Each sale must be characterized at point-of-sale as one or the other in METRC and in any federally-reviewable record. The cross-channel-transaction problem is more operationally complex in Massachusetts than in states without comparable co-location.

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MTC Vertical Integration and the Multi-Registration Footprint

MTCs in Massachusetts are vertically integrated by license. Under 935 CMR 501.050, an MTC is authorized to cultivate, process, and dispense medical cannabis as a single licensed entity, and each MTC may operate up to three medical dispensary locations under its license. The federal § 1301.13(k) pathway recognizes three registration categories — manufacturer, distributor, and dispenser — and a single entity may hold multiple categories under § 1301.13(k)(1)(v).

An MTC performing the full set of state-licensed functions for the medical channel will typically need:

• One manufacturer registration covering the cultivation and product manufacturing facility. Article 23 obligations under § 1301.13(k)(6) attach to this registration: cultivation-area designation, nominal-price mechanism, storage-facility access.
• One distributor registration (or coverage under a coincident-activity provision) covering movement of medical cannabis between the cultivation/manufacturing facility and the dispensary locations.
• One dispenser registration per medical dispensary location. An MTC with three medical dispensaries needs three dispenser registrations.

The federal registration footprint for a fully built-out Massachusetts MTC therefore totals five registrations in many cases, with annual registration fees of $3,699 for the manufacturer, $1,850 for the distributor, and $888 per three-year cycle for each dispenser. Each registration is subject to separate public-interest analysis under 21 U.S.C. § 823(e), (f), or (g) depending on category, separate recordkeeping and reporting obligations, and independent audit authority.

For MTCs that operate fewer than three medical dispensaries or that have not activated all licensed functions, the footprint is smaller. The analytical work at engagement intake is determining which registrations are required for the actual scope of medical activity the MTC intends to maintain.

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Mapping a Massachusetts Cannabis License Onto a Federal DEA Registration

MA License	State Activity	Federal Registration Analysis
Medical Marijuana Treatment Center (MTC)	Vertically integrated cultivation, manufacturing, dispensing of medical cannabis through up to three dispensary locations under 935 CMR 501.050	All three categories under § 1301.13(k)(1): manufacturer, distributor, dispenser. Multi-site dispenser registrations for each MTC dispensary location. Article 23 obligations attach to the manufacturer registration.
Co-located Marijuana Establishment (any class)	Adult-use cultivation, manufacturing, retail, or other ME function at the same premises as an MTC	Not covered by § 1301.13(k). Adult-use remains Schedule I.
Marijuana Cultivator (standalone)	Adult-use cultivation under 935 CMR 500	Not covered by § 1301.13(k). Schedule I.
Marijuana Product Manufacturer	Adult-use manufacturing	Not covered by § 1301.13(k). Schedule I.
Marijuana Retailer	Adult-use retail	Not covered by § 1301.13(k). Schedule I.
Marijuana Microbusiness	Adult-use small-scale vertically integrated	Not covered by § 1301.13(k). Schedule I.
Craft Marijuana Cooperative	Adult-use cooperative cultivation/manufacturing	Not covered by § 1301.13(k). Schedule I.
Marijuana Transporter	Adult-use transport	Not covered by § 1301.13(k). Schedule I.
Delivery Operator / Delivery Courier	Adult-use delivery	Not covered by § 1301.13(k). Schedule I.
Social Consumption Establishment	Adult-use on-site consumption	Not covered by § 1301.13(k). Schedule I.
Marijuana Research Facility	CCC-licensed research	Separate analysis under 21 U.S.C. § 823 for research registrations. Not within § 1301.13(k).

Each registration sought under § 1301.13(k) must tie to a specific MTC-licensed activity, a specific MTC-licensed premises, and the medical portion of the operation only.

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Cultivation, Article 23, and the Single Convention for MA MTC Manufacturers

MTC cultivation facilities operate under CCC authorization with premises specifications at 935 CMR 501.110 covering canopy areas, processing areas, storage, security, and other operational elements. For MTC manufacturer registrations under § 1301.13(k)(6), three Article 23 obligations attach:

• Cultivation-area specification. Under § 1301.13(k)(6)(iii), the manufacturer registration “shall specify the areas in which marijuana cultivation is permitted.” Existing CCC premises plans will be the foundation, but federal applications may require additional specificity beyond what 935 CMR 501.110 requires — individual room or canopy identification, supplemental light cycle areas, and any segregated genetics or R&D zones.
• Nominal-price purchase-and-resale mechanism. Under § 1301.13(k)(6)(i), each registered manufacturer establishes a nominal price for marijuana crops, DEA purchases the crops at that price, and DEA sells them back to the manufacturer (or related entity) at the same price plus the administrative fee under 21 C.F.R. § 1318.06(a). The mechanism satisfies the Single Convention’s requirement that a government agency monopolize the wholesale trade in cannabis. Operationally it is a paper transaction but requires registration, fee payment, and recordkeeping that no Massachusetts MTC has previously confronted.
• Storage access for DEA inspection. Under § 1301.13(k)(6)(ii), registered manufacturers must store harvested crops in a facility to which DEA maintains access until the nominal-price transaction is complete. DEA has the right to inspect on demand. The federal access right is independent of CCC’s existing security and inspection regime under 935 CMR 501.110.
• Quota requirements. Section 1301.13(k) requires the Administrator to consider “the requirements of the Single Convention, including any quota requirement” in evaluating applications. Aggregate federal quota allocations to state-licensed manufacturers are a live planning question. Massachusetts MTCs that cultivate at scale will face quota analysis at the federal level even where CCC imposes no comparable cap.

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CCC Recordkeeping and Federal Compliance

Massachusetts requires METRC seed-to-sale tracking for all licensed cannabis operations, with detailed inventory, transfer, and disposal recordkeeping under 935 CMR 501.105. The federal rule, § 1301.13(k)(4), provides that DEA “shall accept state-required reports, records, and forms to the maximum extent permissible” and limits federal recordkeeping under part 1304 to what is “necessary to comply with federal statutory and treaty obligations.”

The practical path for Massachusetts MTCs:

• METRC inventory data will likely satisfy federal biennial-inventory obligations under 21 C.F.R. § 1304.11.
• METRC transfer records between MTC sites will likely satisfy intra-registrant transfer records under 21 C.F.R. § 1304.22.
• METRC’s dual MTC/ME account structure provides a foundation for medical-versus-adult-use inventory tracking but requires defensible documentation of the categorization rules used at the operational level.
• Single Convention statistical returns under Articles 19 and 20 will likely require a separate federal-reporting overlay not satisfied by METRC alone.

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Practitioner Certification Under § 1301.13(k)(5)

Massachusetts permits qualifying patient certification by certifying healthcare providers — including MDs, DOs, NPs, PAs, and other practitioners authorized under 935 CMR 501.020 — who hold valid Massachusetts professional licenses and (where required by their license type) valid DEA registrations to prescribe controlled substances. The CCC operates a patient registration system that issues registration cards to qualifying patients and tracks the certifying provider’s credentials.

For federal purposes under § 1301.13(k)(5), the operative requirements are:

• The certification must be signed and dated on the day issued.
• The certification must contain the patient’s full name and address.
• The certification must contain the certifying practitioner’s name, address, and state license number.

Massachusetts’s framework generally captures these elements at the certification level, but the specific records produced for each MTC should be reviewed before federal application. Patients certified under the post-2018 CCC framework typically have cleaner records than patients certified under the pre-2018 DPH framework, where some documentation conventions differed.

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The DPH-to-CCC Transition and the Pre-2018 RMD Legacy

Massachusetts’s medical program transitioned administrative authority from the Department of Public Health to the Cannabis Control Commission in 2018. MTCs originally licensed as Registered Marijuana Dispensaries under DPH (2015-2018) have an operating history that spans both agencies and two regulatory frameworks. The federal application predicates on the current CCC license, but recordkeeping retention obligations and pre-rescheduling operations may be referenced in any public-interest analysis under § 823.

Practical implications for MTCs with RMD legacy operations:

• The current CCC license is the conclusive predicate under § 1301.13(k)(2). The DPH-era RMD designation does not affect federal eligibility.
• Historical DPH-era records (2015-2018) under 105 CMR 725.000 remain in the recordkeeping inventory and may be subject to DEA review during application or post-registration inspection.
• DPH-era enforcement matters — license amendments, deficiency findings, corrective actions — should be inventoried and prepared for federal review along with CCC-era records.
• The DPH-to-CCC transition itself is not a registration eligibility issue.

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Host Community Agreements and Local Authority

Host Community Agreements are required under M.G.L. ch. 94G § 3(d) for adult-use Marijuana Establishments and have historically been required for MTCs operating in many municipalities. Chapter 180 of the Acts of 2022 (the Cannabis Equity Reform Act) reformed the HCA framework, capping community impact fees at three percent of gross sales, limiting the duration of HCAs to eight years, and granting the CCC review authority over HCA terms.

For federal registration purposes:

• The current CCC license is the conclusive predicate under § 1301.13(k)(2). The HCA itself is not a federal registration requirement.
• Local municipal approvals — HCA, special permit, site plan approval, zoning compliance — must be in good standing for the CCC license to remain valid. CCC license suspension or revocation triggers federal registration auto-suspension under § 1301.13(k)(3).
• HCA disputes or municipal enforcement issues that threaten CCC license status should be resolved before federal registration is filed.

Municipal opt-outs from cannabis licensing under M.G.L. ch. 94G § 3 apply to adult-use Marijuana Establishments specifically. MTCs are subject to municipal zoning and site approval but operate under a separate state authorization structure.

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Conditional Operating Authority During Pendency

For MTC applications filed within the 60-day window (through June 27, 2026), § 1301.13(k)(7) provides that the applicant “may engage in the manufacture, distribution, and/or dispensing of marijuana or products containing marijuana for medical purposes in conformity with a state-issued license during the pendency of the application.” DEA must make every effort to process priority applications within six months.

For Massachusetts MTCs, conditional operating authority is meaningful but narrow:

• It protects only the medical channel within the CCC MTC license.
• It does not protect the adult-use channel operated by the same operator under a separate Marijuana Establishment license at the co-located premises.
• It does not authorize interstate transfer or activity outside the CCC license.
• It applies to each of the multiple registrations the MTC files — manufacturer, distributor, and each dispenser registration — separately.
• It does not extend to applications filed after June 27, 2026.

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Section 280E and Massachusetts Tax Implications

The federal rule’s most economically significant collateral effect is the end of 26 U.S.C. § 280E for state-medical-licensed activity. Massachusetts’s tax interaction with Schedule III placement differs from neighboring states’ analyses:

• Massachusetts conforms to federal § 280E for state corporate excise tax purposes. Unlike New York, which decoupled at the state level beginning with the 2022 tax year, Massachusetts cannabis businesses have been subject to § 280E disallowance at both federal and state levels. The state’s conformity is set by reference to the Internal Revenue Code as in effect on a specified date, and federal Schedule III placement should flow through to state-level relief as a conformity matter — but verification with tax counsel is essential.
• Federal Schedule III prospective relief removes state-medical-licensed marijuana from federal § 280E disallowance. For MTCs that have been carrying the full federal-and-state § 280E burden, the post-rescheduling combined federal-state position is materially improved.
• Bifurcation still applies. The adult-use channel — both the federal disallowance and the Massachusetts state-level conformity — remains subject to § 280E. Cost-of-goods and operating expense allocation between MTC and co-located ME operations becomes a tax-accounting matter.
• The AG Order encourages Treasury to consider retrospective § 280E relief. No Treasury guidance has been issued. MTCs should plan as if retrospective relief will not be granted and should consult tax counsel on amended-return strategy.

Tax matters are referred to specialist tax counsel. Kocot Law coordinates the federal-registration eligibility analysis but defers tax matters to retained tax counsel for each operator.

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What the Federal Rule Does Not Do

The April 2026 order is significant but limited:

• It does not legalize adult-use cannabis federally. Adult-use marijuana remains Schedule I. Massachusetts Marijuana Establishment licenses do not qualify for any federal registration pathway under § 1301.13(k).
• It does not authorize interstate cannabis transfer. State-line crossings — including movement to or from operators in Connecticut, New York, Rhode Island, New Hampshire, Vermont, or any other state — are governed by 21 U.S.C. §§ 951-971 and require import/export permits under 21 C.F.R. § 1312.30(b)-(d).
• It does not convert a CCC MTC license into a DEA registration automatically. The federal application must be filed under § 1301.13(k) for each required registration category.
• It does not protect activity outside the CCC MTC license. Federal registration scope cannot exceed state license scope under § 1301.13(k)(3).
• It does not exempt registrants from federal labeling categorically. State-law labeling under 935 CMR 501.105 is accepted, but the 21 U.S.C. § 825(c) warning must appear where applicable.
• It does not eliminate 18 U.S.C. § 1001 false-statement exposure. Each registration application is sworn under penalty of federal criminal liability.

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Massachusetts-Specific FAQs

My MTC operates co-located adult-use sales at the same premises. How does federal registration affect that?

Federal Schedule III registration covers only the MTC dispensing function. Adult-use sales at the co-located Marijuana Establishment remain Schedule I activity under federal law. The DEA registration does not extend to adult-use activity even when conducted at the same premises by the same operator. Inventory separation in METRC, sales characterization at point-of-sale, and recordkeeping must distinguish the two channels in a manner defensible during DEA inspection.

I’m an adult-use Marijuana Establishment operator. Does Schedule III apply to me?

No. The April 2026 federal order applies only to FDA-approved drug products and marijuana subject to a state medical marijuana license. Massachusetts Marijuana Establishment licenses under M.G.L. ch. 94G — including cultivators, product manufacturers, retailers, microbusinesses, cooperatives, transporters, delivery operators, and social consumption establishments — are not medical licenses. Adult-use marijuana remains Schedule I under federal law. There is no § 1301.13(k) pathway for adult-use operators regardless of license type.

My MTC was originally licensed as an RMD under DPH. Does that affect my federal application?

The current CCC MTC license is the conclusive predicate under § 1301.13(k)(2). The DPH-era RMD designation does not affect federal eligibility. Historical DPH-era records (2015-2018) remain in the recordkeeping inventory and may be subject to DEA review, but the transition itself is not a registration eligibility issue.

My MTC operates three medical dispensary locations. Do I need three DEA registrations for them?

Yes, typically. Each medical dispensary location requires its own dispenser registration under DEA practice. An MTC with three medical dispensaries, one cultivation/manufacturing facility, and a distribution function will need approximately five DEA registrations — one manufacturer, one distributor, and three dispenser registrations.

Are Massachusetts practitioner certifications sufficient under § 1301.13(k)(5)?

Massachusetts’s certifying healthcare provider framework under 935 CMR 501.020 generally captures the required elements: patient name and address, practitioner name and license number, signed and dated on issuance. Pre-application record review confirms that specific records meet the federal threshold. Post-2018 CCC-era records are typically cleaner than pre-2018 DPH-era records.

Does federal registration let me transfer medical product to a Connecticut, Rhode Island, or New York operator?

No. Interstate transfer requires separate compliance with 21 U.S.C. §§ 951-971 and import/export permits under 21 C.F.R. § 1312.30(b)-(d). The April 2026 order added marijuana subject to a state medical marijuana license to the permit-required list. Registration under § 1301.13(k) does not include interstate authority.

What if the CCC suspends or revokes my MTC license after I’m federally registered?

Under § 1301.13(k)(3), the DEA registration automatically suspends upon suspension, revocation, or expiration of the underlying state medical license. There is no independent federal status that survives loss of the state license. MTCs with any active CCC enforcement matter should resolve the state issue before federal registration.

My MTC has a Host Community Agreement dispute. Does that affect my federal application?

The HCA itself is not a federal registration requirement. The federal predicate is the current CCC MTC license. However, HCA disputes that escalate to municipal enforcement or threaten CCC license status can affect federal registration through § 1301.13(k)(3) auto-suspension. HCA matters that touch license validity should be resolved before federal registration is filed.

Will Massachusetts state tax treatment change with federal Schedule III placement?

Massachusetts conforms to federal § 280E for state corporate excise tax purposes. Federal Schedule III placement should flow through to state-level relief on the medical channel as a conformity matter, but state tax counsel should verify the specific mechanics for each operator. The combined federal-state tax position post-rescheduling represents a materially favorable change from the pre-rescheduling baseline.

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Documents to Gather Before Filing — Massachusetts Specific

• Current CCC MTC license and all amendments
• License history covering the DPH-to-CCC transition (DPH-era RMD documents and CCC transition documentation)
• Co-located Marijuana Establishment license documents if applicable (separate from MTC license)
• Premises plans for all licensed locations under 935 CMR 501.110 — cultivation, manufacturing, and each medical dispensary
• CCC ownership and financial-interest disclosures
• Host Community Agreements for each licensed location
• Local approvals — special permits, site plan approvals, zoning verifications
• METRC enterprise structure showing separate MTC and ME accounts where applicable
• For cultivation and manufacturing: canopy area mapping, processing room layouts, security infrastructure
• For distribution: transport SOPs, manifests, vehicle inventory
• For dispensaries: patient certification verification procedures, sales records, and dispensing logs
• Certifying healthcare provider registration documentation
• Historical DPH-era enforcement records (2015-2018), deficiency findings, and corrective actions
• CCC inspection reports and enforcement records (2018-present)
• Insurance certificates required under 935 CMR 501
• Internal compliance audit reports and remediation evidence
• Any pending CCC amendment, transfer-of-ownership, change-of-premises, or change-of-location application

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Scope of Representation

Kocot Law represents Massachusetts Medical Marijuana Treatment Centers on the federal side of the DEA registration process and the Massachusetts-side compliance issues that intersect with it.

Federal scope: § 1301.13(k) application strategy and preparation for the full multi-registration footprint; public-interest analysis under 21 U.S.C. § 823(e)-(g) for each registration; Single Convention quota and reporting analysis for manufacturer registration; Article 23 cultivation-area, nominal-price, and storage-access compliance; multi-site dispenser registration coordination; post-registration federal compliance (Parts 1301, 1304, 1312, 1317, and 1318); federal status-change client advisories.

Massachusetts-side scope: CCC MTC license-alignment review for federal predicate; MTC-versus-Marijuana-Establishment bifurcation planning for co-located operations; CCC premises-plan-to-federal-cultivation-area mapping; METRC reporting overlay analysis; DPH-to-CCC transition documentation review; Host Community Agreement status review.

Outside scope, with referral coordination: Massachusetts state and federal tax matters (§ 280E interaction, Massachusetts conformity analysis, and amended-return strategy) are referred to specialist tax counsel. Federal criminal defense matters are handled separately.

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Book a Free Consultation With a Massachusetts DEA Registration Attorney

If your organization holds a CCC Medical Marijuana Treatment Center license, the priority filing window remains open through June 27, 2026. A short eligibility call typically identifies the full federal registration footprint required, the MTC-versus-co-located-ME bifurcation issues to address before filing, the Article 23 implications for cultivation operations, and the multi-site dispenser registration sequencing.

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Attorney Advertising. This page is for general informational purposes only and is not legal advice. Visiting this page or contacting Kocot Law does not create an attorney-client relationship. Past results do not guarantee future outcomes. Kocot Law is admitted in California, Massachusetts, and New York. References to federal statutes and regulations are to the United States Code and the Code of Federal Regulations as in effect on the date of publication; the rule discussed above is AG Order No. 6754-2026, published at 91 Fed. Reg. 22714 (April 28, 2026). References to Massachusetts General Laws and Cannabis Control Commission regulations are to provisions in effect on the date of publication.

Last updated: May 13, 2026.