Short answer: Since early October, the Drug Enforcement Administration has had dedicated Form 225 registration links for state-licensed medical cannabis manufacturers, distributors and testing labs, Marijuana Moment reported on Oct. 6. That matters in DC, which has 21 ABCA-licensed non-retail facilities: 10 manufacturers, 9 cultivation centers, 1 testing lab and 1 courier, according to ABCA's license register as of Oct. 13.
What changed
Dispensaries got their own federal form in April, days after the Justice Department moved marijuana under a state medical license into Schedule III (Federal Register, 91 FR 22714). The rest of the supply chain had to use a standard federal form. Now it has specific links, a change DEA "first previewed was coming in May," per Marijuana Moment.
The new form asks applicants whether they'll handle medical and/or recreational marijuana, for their state license details, and about the criminal and disciplinary history of the business and key staff. The nonrefundable application fee is $3,699 for manufacturers, $1,850 for distributors and $296 for labs, as Cannabis Business Times reported. Dispensaries that haven't registered yet now use the standard Form 224.
The DC angle
Every licensed product on a DC shelf starts at one of these 21 facilities. Most of the production base is concentrated: by our count of ABCA's register, 12 of the 21 sit in Ward 5, followed by Ward 4 (4), Wards 2 and 7 (2 each) and Ward 6 (1). Several companies hold both a cultivation center and a manufacturer license, so the 21 licenses belong to 15 distinct businesses. Our guide to DC's licensed cannabis manufacturers lists them, and ABCA's six license types explains what each license allows.
DC is medical-only, so its whole licensed market falls on the side of the line the April order already covers. That's why federal registration is a live question here, not a hypothetical one. Before registering, each DC licensee will have to answer some questions for itself, and we're not answering them for it: whether a DC courier license fits DEA's "distributor" category, and how the background questions apply to staff. Those are for the business and its counsel.
What it means for you
- Patients: nothing changes at the counter. Keep buying only from licensed stores, and check a license with ABCA if you're unsure.
- Industry watchers: the registration path, the inspections and the questions about workers' records will shape which DC producers qualify for federal Schedule III treatment. DEA "personnel are conducting inspections of medical marijuana dispensaries that previously applied," Marijuana Moment reported.
- What's next: the broader question of whether all marijuana moves to Schedule III is still on hold. See where the rescheduling fight stands and our federal cannabis rescheduling explainer.
This article is news and analysis, not legal or tax advice.
Sources
- Marijuana Moment, "DEA Launches New Registration Forms For Medical Marijuana Manufacturers, Distributors And Testing Labs," Oct. 6, 2026
- Cannabis Business Times, DEA Schedule III registration portal report
- ABCA licensed non-retail medical cannabis facilities (DC GIS register), checked Oct. 13, 2026
- Federal Register, 91 FR 22714, Apr. 28, 2026
