Federal · DEA registration · Washington

Federal DEA registration for Washington cannabis businesses

Federal DEA registration is separate from state cannabis licensing. This page explains federal registration issues affecting cannabis businesses in Washington, including how the business’s state authorization may affect its application under 21 C.F.R. § 1301.13(k). State licensing decisions and federal registration decisions are related, but they are not interchangeable.

Ryan Kocot is admitted in California, New York, and Massachusetts. He is not admitted in Washington. For businesses in Washington, Kocot Law offers representation before the federal Drug Enforcement Administration and advice reasonably related to those authorized federal DEA matters. This page does not offer representation before Washington licensing agencies or courts, or independent advice on Washington law. Where a federal matter requires a state-law determination, the client should obtain advice from counsel admitted in that jurisdiction, and Kocot Law can coordinate with that counsel.

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Federal status at a glance
Washington licenseesLicense qualification needs review.Washington’s integrated licensing framework raises a federal question about the requisite state medical marijuana license. Filing within the historical window does not resolve that question.
Timely applicationsFiling dates are only part of the test.Qualifying status also depends on the requisite state medical marijuana license, continued application pendency, and the activities covered by the applicable authority.
Orders to show causeA proposed denial is not a final denial.An OSC gives notice of proposed agency action and a process for contesting it. The recipient must evaluate the actual document and applicable response requirements.
Adult-use activityNot authorized by this medical pathway.Section 1301.13(k) does not authorize nonmedical cannabis activities.
Application status

What your application status does, and does not, establish

  • Applied during the April 28 to June 26, 2026 window. A completed application and applicable fee payment during that window are part of the qualifying timely-applicant requirements. The business must also hold the requisite state medical marijuana license, its application must remain pending, and its activities must fall within the applicable authorization. Filing dates alone do not establish eligibility or permit every cannabis activity.
  • Applied after June 26. A later application does not receive the historical pending-application operating benefit under § 1301.13(k)(7). Do not assume that submitting an application authorizes operations before registration is granted. Any independently applicable authority or exception requires separate review.
  • Have not applied. The expiration of the historical timely-filing window does not itself close the application pathway to otherwise eligible applicants. But state licensure alone is not DEA registration, and the federal consequences of operating without the required authority must be evaluated separately.
  • Received an order to show cause. An OSC proposing denial is not a final denial. Review the allegations, filing and service instructions, and response deadlines promptly. Informal discussions should not be assumed to replace a required response.

Sources: 21 C.F.R. § 1301.13 · 21 C.F.R. § 1301.37 · 21 C.F.R. § 1301.43 · DEA, Medical Marijuana Timely Applicant Information

Supply chain

Verifying partners for covered transfers

For covered medical-marijuana transfers, the DEA’s October 30 guidance recognizes transactions among qualifying timely applicants and appropriately registered entities, within their authorized activities. Verification should address both status and scope. The guidance also contains limited provisions concerning existing inventory and laboratory testing that require separate review.

This is not a restriction on every ordinary business relationship, such as using a lawyer, accountant, or landlord, and it is not a statement that patients must hold DEA registrations. How to check a business partner’s DEA status.

Sources: DEA, Medical Marijuana Timely Applicant Information

Washington

Washington’s integrated system and the proposed certification program

Washington’s Liquor and Cannabis Board has identified uncertainty about how Washington’s licensing framework fits the federal medical marijuana registration pathway.

On October 7, 2026, the Board accepted a petition concerning verification of state-authorized medical cannabis activities. On October 9, the agency filed a CR-101 preproposal statement to begin developing a certification program. The announced informal comment period runs through December 4, 2026.

These steps do not establish an adopted certificate or final rule. Nor would a state certificate, by itself, establish that the DEA has accepted the applicant’s license as qualifying under the federal rule. The federal eligibility analysis and any necessary Washington-law analysis should therefore be kept distinct. Read the related Kocot Law article.

Sources: LCB recent rulemaking activity · LCB current rulemaking activity · LCB bulletin

The federal review

Federal issues to evaluate in a cannabis DEA application

Patient documentationWhether the documentation supporting medical dispensing satisfies the applicable federal requirements, including § 1301.13(k)(5). State acceptance of a document does not, by itself, establish that every federal condition is satisfied.
Medical and adult-use activityWhether the applicant has the requisite medical authorization and whether the proposed federal activities remain within that authorization. Paper separation should not be presented as a guaranteed solution to the DEA’s concerns.
Employees and agents with accessWhether § 1301.76(a) applies to an employee or agent with controlled-substance access because of a controlled-substance felony or specified adverse DEA-registration history. A waiver request and a granted waiver are not the same thing.
Supply chainWhether the parties conducting covered cannabis transfers have the necessary status and activity-specific authority, and whether the supporting diligence is documented.

Sources: 21 C.F.R. § 1301.13 · 21 C.F.R. § 1301.76 · 21 C.F.R. § 1307.03

Scope

What Kocot Law handles for businesses in Washington

Federal DEA mattersApplication strategy and preparation; analysis of applicable federal registration standards; responses to DEA information requests; employment-waiver requests; representation in DEA administrative proceedings; and related federal DEA compliance advice. The specific work, representation authority, and scope are confirmed before an engagement is accepted. Judicial review or other court litigation requires separate consideration of court-admission requirements and engagement scope.
State-law mattersKocot Law does not offer independent advice on Washington licensing, employment, criminal-record relief, corporate restructuring, or state enforcement through this page. State-law issues are referred to appropriately admitted counsel. Coordination with that counsel can be included in the federal engagement where needed.

Discuss a potential federal DEA engagement

Request a free 30-minute introductory consultation concerning a potential federal DEA matter. Subject to conflict screening, the conversation can identify the issue, the current application stage, and information needed to evaluate a possible engagement. An introductory conversation is not a promise that eligibility or a substantive dispute can be resolved within 30 minutes.

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Questions people ask first

Frequently asked questions

Is Ryan Kocot admitted in Washington?

No. He is admitted in California, New York, and Massachusetts. For businesses in Washington, the firm’s services through this page are limited to authorized federal DEA representation and related federal advice.

Does a Washington license guarantee DEA registration?

No. State licensure alone is not DEA registration. State licensing decisions and federal registration decisions are related, but they are not interchangeable.

Will a Washington verification certificate guarantee DEA registration?

No. The certification program is in the preproposal stage, and state documentation would not itself guarantee the DEA’s acceptance of the applicant’s federal eligibility.

Read the guides

DEA registration under 21 C.F.R. § 1301.13(k)What the medical-channel registration is and who qualifies. Reported DEA orders to show cause in CaliforniaThe reported patient documentation objection and the federal rule’s “other document” language. The DEA’s reported objection to dual-use licensingThe Minnesota order to show cause, a proposed denial, and what it may mean for combined systems. The Federal Cannabis FileThe firm’s newsletter and archive on DEA registration and federal compliance.

Attorney advertising. Ryan Kocot is admitted in California, New York, and Massachusetts, and is not admitted in Washington. Services offered through this page are limited to authorized federal DEA representation and related federal advice. This page provides general information and does not offer independent advice on Washington law.

Viewing this page or sending an initial inquiry does not, by itself, establish an attorney-client relationship. Kocot Law confirms accepted representation and its scope in writing. Duties to prospective clients are governed by applicable law.

Please do not send confidential information or sensitive documents until the firm invites you to do so after appropriate conflict screening. Do not rely on an inquiry to satisfy or extend a legal deadline. No outcome is guaranteed.

Responsible attorney: Ryan Kocot · Kocot Law · (916) 572-6445 · Ryan@Kocotlaw.com

Discuss a federal DEA matter

Free 30-minute introductory consultation on a potential federal DEA matter, subject to conflict screening. Ryan Kocot is not admitted in Washington; federal DEA matters only.

Call or text (916) 572-6445 Book a consultation or email Ryan@Kocotlaw.com
or send a note
Please provide only your contact information, business name, general matter type, and whether a deadline is approaching. Do not submit criminal-history records, patient information, privileged documents, or other sensitive details through this initial inquiry form. Submission alone does not establish representation or extend any deadline. Attorney advertising.
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