Federal Schedule III representation for New York Registered Organizations under 21 C.F.R. § 1301.13(k).
Priority Filing Window. 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.
New York Registered Organizations holding a current Office of Cannabis Management (OCM) medical cannabis 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).
New York’s vertically integrated Registered Organization structure under the Compassionate Care Act and the Marihuana Regulation and Taxation Act means a single RO will typically need multiple federal registrations simultaneously (manufacturer, distributor, and one dispenser registration per medical dispensary location) to cover the integrated medical operation in full.
This page is for New York Registered Organizations evaluating the federal pathway, and for adult-use 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 New York-side OCM compliance.
The New York Federal Posture: Pathway, Not Pressure
New York is a dual-market state with a structurally distinctive medical program. The Office of Cannabis Management under the Cannabis Control Board administers two parallel licensing regimes under Cannabis Law § 1 et seq.:
- The medical cannabis program, built around vertically integrated Registered Organizations, originally established by the Compassionate Care Act of 2014 and preserved (with administrative transfer from the Department of Health to OCM) under the MRTA in 2021.
- The adult-use program, established by the MRTA in 2021 with separate tiered license categories — cultivator, processor, distributor, retailer, microbusiness, on-site consumption, delivery, conditional licenses (CAURD, AUCC, AUCP, AUCD), and others.
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 New York operators, this draws a sharp line: only the Registered Organization medical program qualifies for the § 1301.13(k) pathway. Every adult-use license issued under the MRTA — including CAURD, AUCC, AUCP, AUCD, microbusiness, and standard adult-use licenses — remains outside Schedule III. Adult-use operators have no § 1301.13(k) path regardless of corporate structure or operational sophistication.
For Registered Organizations, the federal rule’s cooperative-federalism framing applies. Under § 1301.13(k)(2), a valid OCM 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.
How New York’s Medical Cannabis Program Reached This Point
| Authority | Year | Effect |
|---|---|---|
| Compassionate Care Act | 2014 | Public Health Law § 3360 et seq. Established the medical cannabis program around vertically integrated Registered Organizations. Administered by the Department of Health. |
| First Registered Organizations licensed | 2015 | DOH initially licensed five ROs; the program expanded through subsequent application rounds to approximately ten ROs. |
| DOH medical regulations | 2015–2021 | Originally promulgated at 10 NYCRR Part 1004. |
| MRTA — Marihuana Regulation and Taxation Act | 2021 | Cannabis Law § 1 et seq. Created OCM and the Cannabis Control Board. Transferred medical program administration from DOH to OCM. Established the adult-use market with separate license categories. Preserved RO vertical integration. |
| Adult-use sales authority extended to ROs | 2022–2023 | Existing ROs permitted to engage in adult-use sales at medical dispensary locations under specific conditions, creating co-located medical and adult-use operations. |
| OCM medical and adult-use regulations | 2023+ | Republished under OCM authority at 9 NYCRR (Cannabis Management). RO licenses transitioned from DOH to OCM administration. |
| 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 New York Registered Organization has an operating history that spans two regulatory agencies (DOH 2014–2021; OCM 2021–present), two statutory frameworks (Public Health Law original; Cannabis Law post-MRTA), and — for those that have activated adult-use authority — a parallel adult-use channel layered onto the medical operation since 2022 or 2023.
The Central New York Issue: Registered Organization Vertical Integration
The single most important federal-application question for a New York Registered Organization is the multi-registration analysis.
By statute and OCM regulation, each Registered Organization performs cultivation, manufacturing (extraction, infusion, packaging, labeling), distribution between its own facilities, and dispensing to patients through medical dispensaries — all as a single licensed entity. The federal § 1301.13(k) pathway recognizes three registration categories:
- Manufacturer — covers cultivation, processing, packaging, and labeling
- Distributor — covers transfer between registered entities
- Dispenser — covers patient-facing dispensing
A single Registered Organization performing all four state-licensed functions for the medical channel will need all three federal registration categories simultaneously, and likely multiple dispenser registrations. Section 1301.13(k)(1)(v) explicitly permits a single entity to hold multiple registration types.
The federal compliance footprint scales accordingly:
- Year-one registration fees alone — one manufacturer ($3,699), one distributor ($1,850), and four dispenser registrations ($888 per three-year cycle each) — total roughly $9,100 for a typical RO. Ongoing compliance costs are substantially higher.
- Each registration is subject to its own public-interest analysis under 21 U.S.C. § 823(e), (f), or (g) depending on category.
- Each registration carries separate recordkeeping, reporting, security, and inspection obligations under 21 C.F.R. Part 1304, Part 1301, Part 1302, and Part 1317.
- Manufacturer registration triggers Article 23 of the Single Convention obligations under § 1301.13(k)(6) — cultivation-area designation, nominal-price mechanism, storage-facility access.
- Each registration can be independently suspended or revoked.
The analytical work is not whether to register; it is how to structure the registrations efficiently for an operation that already exists as a single legal entity with multiple dispensary locations and integrated supply chains. This is the operational scale that no operator in a non-vertically-integrated state confronts under § 1301.13(k), and it is the single most underappreciated planning issue for New York ROs in May 2026.
The Multi-Site Dispensing Issue
Each New York Registered Organization operates up to four medical dispensary locations under its OCM authorization. Under DEA registration practice, each separate location typically requires its own dispenser registration. For an RO with four medical dispensaries:
- One manufacturer registration at the cultivation and manufacturing premises
- One distributor registration (or coverage under a coincident-activity provision) for movement between manufacturer and dispensary locations
- Four dispenser registrations — one for each medical dispensary location
The federal registration footprint for a fully-built-out RO can therefore total six or more separate DEA registrations. Each must be applied for separately. Each is subject to separate annual fees and renewals. Each can be independently audited.
For ROs with planned dispensary expansion, the multi-site framework also affects timing. New dispensary locations licensed by OCM after the initial federal registration require an amendment or additional registration under 21 C.F.R. § 1301.51. Pre-planning for the federal-registration sequencing of OCM-approved expansions is part of the engagement.
Co-Located Medical and Adult-Use Dispensaries
Most New York Registered Organizations operate co-located medical and adult-use dispensary locations. The medical dispensing function operates under the RO’s medical license. The adult-use dispensing function operates under separate adult-use authority granted to the RO.
For DEA purposes, the federal Schedule III pathway covers only the medical dispensing function. The adult-use dispensing function on the same premises remains Schedule I activity under federal law and falls entirely outside the scope of any DEA registration that the RO obtains under § 1301.13(k).
Three operational consequences:
- Inventory separation. Federally, the medical inventory must be identifiable as such. OCM seed-to-sale tracking provides a foundation for the medical/adult-use distinction, but the operational practice of staffing, displaying, and selling medical and adult-use product through the same retail floor requires a defensible separation protocol before DEA registration. The federal rule, § 1301.13(k)(10), accepts state physical-security requirements — but the categorization of which inventory is which must be 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.
- New York’s practitioner certification framework typically satisfies § 1301.13(k)(5) better than most states because New York requires the certifying practitioner to be New York-licensed and to hold a valid DEA registration for prescribing controlled substances — meaning the supporting practitioner credentials are documented at the certification level.
- 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 cleanly characterized as one or the other in OCM tracking and in any federally-reviewable record.
Mapping a New York Cannabis License Onto a Federal DEA Registration
| NY License | State Activity | Federal Registration Analysis |
|---|---|---|
| Registered Organization (medical) | Vertically integrated cultivation, manufacturing, distribution, dispensing of medical cannabis through up to four dispensary locations | All three categories under § 1301.13(k)(1): manufacturer, distributor, dispenser. Multi-site dispenser registrations for each medical dispensary. Article 23 obligations apply to manufacturer registration. |
| RO adult-use sales authority | Adult-use retail at co-located dispensaries | Not covered by § 1301.13(k). Adult-use remains Schedule I. |
| Adult-Use Cultivator (AUCC and standard) | Adult-use cultivation | Not covered by § 1301.13(k). Schedule I. |
| Adult-Use Processor (AUCP and standard) | Adult-use manufacturing | Not covered by § 1301.13(k). Schedule I. |
| Adult-Use Distributor (AUCD and standard) | Adult-use distribution | Not covered by § 1301.13(k). Schedule I. |
| CAURD (Conditional Adult-Use Retail Dispensary) | Justice-involved adult-use retail | Not covered by § 1301.13(k). Schedule I. |
| Adult-Use Microbusiness | Adult-use vertically integrated small-scale operation | Not covered by § 1301.13(k). Schedule I. |
| Adult-Use Retail Dispensary (standard) | Adult-use retail | Not covered by § 1301.13(k). Schedule I. |
The application should not be filed as a generic “cannabis registration.” Each registration sought must tie to a specific licensed activity, a specific licensed premises, and the medicinal portion of the operation.
Cultivation, Article 23, and the Single Convention for NY Manufacturers
Registered Organizations operate cultivation facilities under OCM authorization with detailed premises specifications including canopy areas, processing areas, storage zones, and security infrastructure. For RO 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 OCM premises diagrams will be the foundation, but federal applications may require additional specificity — GPS coordinates, individual room or greenhouse 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 it requires registration, fee payment, and recordkeeping that no New York RO has previously had to confront.
- 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 OCM’s existing security and inspection regime.
- Quota requirements. Section 1301.13(k) requires the Administrator to consider “the requirements of the Single Convention, including any quota requirement” in evaluating applications. As state-licensed medical marijuana enters the federal Schedule III framework, federal aggregate-quota allocations to individual manufacturers become a live question. New York’s medical cultivation footprint is smaller than California’s but the per-registrant exposure to quota constraints will be a serious planning issue.
OCM Recordkeeping and Federal Compliance
OCM-required seed-to-sale tracking, sales reporting, and patient registration data form the recordkeeping foundation under New York’s regulatory regime at 9 NYCRR. 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.”
This language is favorable to New York ROs but is not self-executing. OCM data was designed for state regulatory needs, not for federal Single Convention reporting under Articles 19 and 20 or federal biennial inventory under 21 C.F.R. § 1304.11. The practical path:
- OCM seed-to-sale data will likely satisfy federal biennial-inventory obligations.
- OCM transfer records between RO sites will likely satisfy intra-registrant transfer records under 21 C.F.R. § 1304.22.
- A separate federal-reporting overlay will likely be required for Single Convention statistical returns.
Practitioner Certification Under § 1301.13(k)(5): NY’s Strong Predicate
New York’s medical program requires the certifying practitioner to be New York-licensed and to hold a valid DEA registration for prescribing controlled substances. The certification system administered by OCM (formerly through DOH’s Health Commerce System; currently through OCM-administered platforms) captures the practitioner’s New York license number, NPI, and DEA registration number at the certification level. The patient registration with OCM provides the user’s name and address. The certifying practitioner must complete a state-approved training course and register with OCM as an authorized practitioner.
For federal purposes under § 1301.13(k)(5), New York medical patient records are typically well-positioned to satisfy the federal threshold:
- The certification document includes the practitioner’s name, the practitioner’s NY license number, and is signed and dated on issuance.
- The OCM patient registration provides the patient’s full name and address.
- The certifying practitioner’s DEA registration is documented at the certification level.
Compare with California, where Prop 215 verbal recommendations and recommendation-only sales create predicate-documentation gaps that New York’s program does not have. Pre-application record review remains essential but the New York record set typically requires less remediation than other states.
The DOH-to-OCM Transition and Predicate Documentation
New York’s medical program transitioned administrative authority from the Department of Health to the Office of Cannabis Management in 2021. For ROs with operating histories spanning the transition, historical records and dispensing data span two regulatory agencies. The federal application predicates on the current OCM license, but recordkeeping retention obligations and pre-rescheduling operations may be referenced in a public-interest analysis under § 823.
Practical implications:
- The current OCM license is the conclusive predicate under § 1301.13(k)(2).
- Historical DOH-era records (2015–2021) remain in the RO’s recordkeeping inventory and may be subject to DEA review.
- The administrative transition itself does not create a registration eligibility issue.
- Any historical compliance matters from the DOH era — license amendments, NOVs, corrective actions — should be inventoried and prepared for federal review.
Local Authority and Medical Premises
Under MRTA, towns, villages, and cities had until December 31, 2021 to opt out of allowing adult-use retail dispensaries and on-site consumption establishments within their jurisdictions. The opt-out applies only to adult-use; medical dispensary locations are not subject to the MRTA opt-out because they were licensed under the pre-existing medical program preserved by the MRTA.
Most New York ROs operate medical dispensaries in jurisdictions where adult-use retail is prohibited. The medical license operates independently of the adult-use opt-out. For federal registration purposes:
- The OCM medical dispensary license is the relevant predicate.
- The local adult-use opt-out does not affect medical operations or federal registration.
- Adult-use co-location at the same premises is a separate consideration governed by OCM rules and local zoning.
Conditional Operating Authority During Pendency
For RO 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 New York ROs, conditional operating authority is meaningful but narrow:
- It protects only the medical channel within the OCM license.
- It does not protect the adult-use channel operated by the same RO at co-located dispensaries.
- It does not authorize interstate transfer or activity outside the OCM license.
- It applies to each of the multiple registrations the RO files — manufacturer, distributor, and each dispenser registration — separately.
- It does not extend to applications filed after June 27, 2026.
§ 280E and New York-Specific 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. For New York Registered Organizations operating both medical and adult-use channels, the analysis is more favorable than in many other states because of New York’s existing tax decoupling:
- New York already decoupled from § 280E. Beginning with the 2022 tax year, New York permitted cannabis businesses to deduct ordinary and necessary business expenses for New York State income tax purposes regardless of federal § 280E disallowance. The state-level tax position has been favorable for several years.
- Federal Schedule III prospective relief. The April 2026 order removes state-medical-licensed marijuana from § 280E’s federal disallowance prospectively. For New York ROs, this aligns the federal medical-channel tax treatment with what New York State has already permitted at the state level.
- Bifurcation still applies. The adult-use channel remains subject to federal § 280E. New York State tax decoupling continues to apply to the adult-use channel at the state level, but federal disallowance continues. Cost-of-goods and operating expense allocation between channels becomes a tax-accounting matter requiring defensible methodology.
- Retrospective federal relief. The AG Order encourages Treasury to consider retrospective § 280E relief. No Treasury guidance has been issued. ROs should plan as if retrospective relief will not be granted and should consult tax counsel on amended-return strategy for prior tax years.
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.
What the Federal Rule Does Not Do
The April 2026 order is significant but limited:
- Does not legalize adult-use cannabis federally. Adult-use marijuana remains Schedule I. New York adult-use licenses do not qualify for any federal registration pathway under § 1301.13(k).
- Does not authorize interstate cannabis transfer. State-line crossings — including movement to or from operators in New Jersey, Connecticut, Massachusetts, or any other state — are governed by 21 U.S.C. §§ 951-971 and require import/export permits separately regulated under 21 C.F.R. § 1312.30(b)-(d).
- Does not convert an OCM medical license into a DEA registration automatically. The federal application must be filed under § 1301.13(k) for each required registration category.
- Does not protect activity outside the OCM license. Federal registration scope cannot exceed state license scope under § 1301.13(k)(3).
- Does not exempt registrants from federal labeling categorically. State-law labeling under OCM is accepted, but the 21 U.S.C. § 825(c) warning must appear where applicable.
- Does not eliminate 18 U.S.C. § 1001 false-statement exposure. Each registration application is sworn under penalty of federal criminal liability.
New York-Specific FAQs
I’m a Registered Organization. Do I really need three or more DEA registrations?
For full coverage of an integrated medical operation, yes. Each cultivation and manufacturing function, each distribution function, and each medical dispensary location may need its own registration. A typical RO with one cultivation/manufacturing facility, one distribution function, and four medical dispensaries will need six registrations: one manufacturer, one distributor, and four dispenser registrations. Section 1301.13(k)(1)(v) permits a single entity to hold multiple registration types.
My organization is a CAURD, AUCC, AUCP, AUCD, or microbusiness 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. New York adult-use licenses under the MRTA 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. Operators in the adult-use channel should consult separately on federal posture; the federal exposure analysis for adult-use is materially different from the medical-side analysis on this page.
My RO operates adult-use sales at medical dispensary locations. How does federal registration affect that?
Federal Schedule III registration covers only the medical dispensing function. Adult-use sales at co-located dispensaries 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 registrant. Inventory separation, sales characterization, and recordkeeping must distinguish the two channels in a manner defensible during DEA inspection.
Are New York’s practitioner certifications sufficient under § 1301.13(k)(5)?
New York’s practitioner certification framework is well-positioned to satisfy § 1301.13(k)(5). New York requires the certifying practitioner to be New York-licensed and to hold a valid DEA registration. The certification document, OCM patient registration, and practitioner credentials capture the required elements: patient name and address, practitioner name, practitioner state license number, and date and signature on issuance. Pre-application record review confirms that specific records meet the federal threshold, but the structural fit is stronger in New York than in most states.
Will the DOH-to-OCM transition affect my application?
The current OCM license is the conclusive predicate under § 1301.13(k)(2). Historical DOH-era records (2015–2021) remain in the recordkeeping inventory and may be subject to DEA review during the application process or post-registration inspection. The transition itself is not a registration eligibility issue.
My RO has a medical dispensary in a jurisdiction that opted out of adult-use. Can I still register federally for that location?
Yes. The MRTA opt-out applies only to adult-use retail and on-site consumption — not to medical dispensaries, which were licensed under the pre-existing medical program and are not subject to the opt-out. The medical dispensary location is the relevant premises for federal registration purposes regardless of the local adult-use posture.
Does federal registration let me transfer medical product to a New Jersey or Connecticut 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 OCM suspends or revokes my 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. ROs in any active OCM enforcement matter should resolve the state issue before federal registration.
My RO has a new medical dispensary location approved by OCM after I file my federal application. What happens?
A new dispensary location requires either an amendment to an existing DEA registration or a new dispenser registration under 21 C.F.R. § 1301.51. Pre-planning for federal registration sequencing of OCM-approved expansions is part of the engagement. New locations cannot operate federally under Schedule III status until the corresponding registration is in place.
Will New York’s § 280E decoupling matter for federal Schedule III tax treatment?
New York’s state-level decoupling has applied since 2022, meaning the state tax posture has been favorable to cannabis businesses for several years. Federal Schedule III prospective relief aligns federal medical-channel treatment with what New York State has already permitted. The combined federal-state position post-rescheduling is materially favorable to medical-channel revenue. Federal retrospective relief, if Treasury issues guidance, would be an additional benefit. Federal-state interaction should be reviewed with tax counsel.
Documents to Gather Before Filing — New York Specific
- Current OCM Registered Organization license and all amendments
- License history covering the DOH-to-OCM transition (DOH-era license documents and OCM transition documentation)
- Premises diagrams for all licensed locations — cultivation, manufacturing, distribution, and each medical dispensary
- Adult-use sales authority documentation if applicable (separate from medical license)
- OCM ownership and financial-interest disclosures
- Seed-to-sale tracking enterprise structure and badge/user inventory
- For cultivation/manufacturing: canopy area mapping, processing room layouts, security infrastructure
- For distribution: transport SOPs, manifests, vehicle inventory
- For medical dispensaries: patient certification verification procedures, sales records, and dispensing logs
- Practitioner registration records and certifications
- Historical DOH-era enforcement records (2015–2021), NOVs, and corrective actions
- OCM inspection reports and enforcement records (2021–present)
- Insurance certificates required under OCM regulation
- Internal compliance audit reports and remediation evidence
- Any pending OCM amendment, transfer-of-ownership, or change-of-premises application
Scope of Representation
Kocot Law represents New York Registered Organizations on the federal side of the DEA registration process and the New York-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.
- New York-side scope: OCM license-alignment review for federal predicate; medical-versus-adult-use bifurcation planning for co-located dispensaries; OCM premises-diagram-to-federal-cultivation-area mapping; seed-to-sale reporting overlay analysis; DOH-to-OCM transition documentation review.
- Outside scope, with referral coordination: New York State and federal tax matters (§ 280E interaction, New York State income tax conformity for cannabis, and amended-return strategy) are referred to specialist tax counsel. Federal criminal defense matters are handled separately.
Book a Free Consultation With a New York DEA Registration Attorney
If your organization holds an OCM Registered Organization license, the priority filing window is open. A short eligibility call typically identifies the full federal registration footprint required, the medical-versus-adult-use bifurcation issues to address before filing, the Article 23 implications for cultivation operations, and the sequencing of multi-site dispenser registrations.
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 New York Cannabis Law and OCM regulations are to provisions in effect on the date of publication.
Last updated: May 13, 2026.