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Michigan’s Cannabis Regulatory Agency Comments on the Proposed Federal Rule Rescheduling Marijuana

Today, the Cannabis Regulatory Agency (CRA) submitted a comment on the proposed federal rule rescheduling marijuana (Docket No. DEA-1362). It can be read in its entirety on the CRA website here.

In addition to providing information and statistics about Michigan’s Medical Marijuana Program to assist the Drug Enforcement Administration (DEA) in its understanding of whether marijuana has a currently accepted medical use as determined using the Department of Health and Human Services two-part inquiry, the CRA also provided a list of considerations the DEA and other federal agencies should evaluate when determining whether to reschedule marijuana and how rescheduling should be implemented, including information on the following topics:

  • Requirements Applicable to Schedule III Drugs
  • Banking and Taxation
  • Bankruptcy Protection
  • Packaging, Labeling, and Advertising
  • Product Safety Standards
  • Transportation and Interstate Commerce
  • Research
  • Federal Enforcement
  • Federal Regulatory Agencies that will Oversee Activities Related to Marijuana

“The licensees, caregivers, patients, and advocates here in the state of Michigan have invested a tremendous amount of time and energy in developing the best cannabis industry in the country,” said CRA Executive Director Brian Hanna. “As we stand at an important crossroads with the possibility of a federal rescheduling of marijuana, the CRA wanted to make it very clear in our public comment that rescheduling will do little good if the federal government fails to provide clear and robust whole-of-government guidance on the implications of the rescheduling. I stand ready to testify at the federal level, as needed, to share the progress we have made in building a robust regulatory program that has made Michigan the national model for stimulating business growth while preserving safe consumer access to cannabis.”

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