A well-attended event in Berkeley on Saturday, May 16 presented the Budist 2025 California Cannabis Harvest Report, with outdoor farmers represented from the report’s covered counties: Humboldt, Trinity, Mendocino, Sonoma, Lake, Nevada and Santa Cruz. Starting from DCC dashboard numbers and adding in the number of licensees producing outdoor crops, the report highlights farmers and cultivars in each region, and looks at statewide trends.

The 2025 outdoor cannabis harvest was the largest since 2022; however all counties in the report except Mendocino lost market share in California’s outdoor market in 2025 vs. 2024, as counties like Santa Barbara and Kings came onboard with large, multi-licensed farms, with much of the output going straight to distillate. There was quite a difference between counties, with Sonoma and Santa Cruz only licensing a handfull of outdoor farmers, with other counties producing millions of pounds at hundreds of farms. Local control, real estate prices, and weather variations impacted each county differently: counties saw a colder summer in 2025, with twice to 6x as much rain during harvest months.

Budist hopes to bring marketing methods from the wine industry’s appellations, terroirs, and vintages to the cannabis space, comparing cannabis-growing regions with the Champagne and Bordeaux valleys of France. Both flower and hash/rosin change year to year, depending on growing conditions and methods of curing or preserving. “Appellations tell the story of the season, and the relationship to variability, which has value in the marketplace,” it was said. Each farm reported its best-performing cultivar in the harvest report.

Caleb Chen of Budist, who presented the data, highlighted regional events such as the Trinity County Fair cannabis competition, open to homegrowers and licensed farmers, and to flower and hash. Also mentioned were the the Sonoma County Harvest Festival, the inspiration for the High Times Cannabis Cup; the Humboldt Showdown, also open to home growers and licensees; Lake County clone swaps; and this year’s Mendo Cup, which donated profits back to farmers.

On a panel on Appellations with Genine Coleman of Origins Council and Zoe Schreiber of CCIA (who also works for both a cannabis provider and a wine producer in Livermore), Hannah Whyte of the Humboldt County Grower’s Association noted that, “Appellations develop a relationship with land” and that legitimization fo the indstry provides the opportunity for keeping records and of “healing a lot of the wounds of hiding.” Working together with other farmers and educating the consumer are goals.

Schreiber, perhaps alluding to a pending bill in the CA legislature that would severly restrict regional elements on cannabis packaging, spoke of “running into a wall of limitations at the state level,” and said the industry needs to be “heard and present in face of new legislation, as a movement.”

Asked by an audience member about how small farmers can combat the attempt to file patents and corner the market in genetics likely to follow the recent federal rescheduling announcement, Coleman said that educating farmers about intellectual property rights is part of Legacy Genetics, a project involving Cal Poly Humboldt and UC Berkeley that will be holding a seminar on the topic in Sacramento on June 26.

Claudio Miranda from Budist spoke of the Medieval Dark Age when “ecclesiastical hierarchies suppressed knowledge, medicine, and light.” He called for a new Renaissance to spread all three. The event was held at the Berkeley Chapel of the Flowers event space, which seems to be part of that Renaissance.

Also present at the Oaksterdam University booth at the event were representatives from the new Oakland Legendary Cannabis Certified Equity Label, the nation’s first initiative to promote city-verified equity businesses in the cannabis industry. The label lets buyers know they are supporting businesses that are invested in creating high-quality products with a priority on equity. “Oakland continues to lead with courage and conviction. During my time in Congress, I co-chaired the Cannabis Caucus and introduced the first bill calling for the establishment of cannabis equity programs to repair the harm done to Black and Brown communities,” commented Oakland Mayor Barbara Lee. “The Oakland Legendary label puts power back where it belongs, helping consumers make informed choices and ensuring those most impacted are leading and thriving in today’s economy. Oakland is proud to lead the way!”

Also see: Sungrown tells a story: Harvest Report shows California’s cannabis shift

Coming events:

Tuesday, May 26 • 12PM – 1 PM
Preparing for Schedule III: A Webinar for Cannabis Producers
National Craft Cannabis Coalition
Register

Thursday, May 28 • 10 AM
Schedule III in Adult Use States
Oaksterdam University
REGISTER NOW

Friday, June 26
Legacy Cannabis Genetics Research Dissemination Event
Capital Events Center, 1020 11th St., Sacramento

Cal NORML participated in Cannabis Unity Coalition lobby day last week in Washington, DC to lobby for full cannabis decriminalization, release of federal marijuana prisoners, and the clearing of records for past marijuana convictions.

Watch the coalition press conference held at the US Capitol at which Cannabis Caucus Co-Chairs Dina Titus (D-NV) and Ilhan Omar (D-MN) spoke, along with Rep. Steve Cohen (D-TN). Read more.

Also speaking were representatives from Latino and Indigenous groups, prisoner advocates, Students for Sensible Drug Policy, NORML, MPP, DPA, and others. Information packets were dropped by Coalition members in all Congressional offices. In addition, 2,148 letters were sent to Congress in support of 44 organizations united around 13 bills, educating all 541 offices in the House and Senate.

Cal NORML’s director Dale Gieringer and deputy director Ellen Komp met with staffers for several Congressmembers, and Senators Adam Schiff and Alex Padilla. We even got a personal moment with Rep. Lateefah Simon (D-Oakland), Senator Schiff, and Rep. Titus. Staffers were interested to hear about the potential effect of the recent rescheduling order on California consumers and businesses.

At a California Constituent Coffee with Sens. Schiff and Padilla, Ellen had asked for both of them to sponsor this year’s expected Senate version of the MORE Act to fully deschedule cannabis, pointing out the pitfalls of partial rescheduling for recreational states like CA.

Californian Jackie Simion from NCIA thanked the Senators for their attention to the issue, and asked the Cannabis Unity contingent to raise their hands in a show of force. We all got a group photo with the Senators (above).

Kristi Kem of Freedom Grow spoke about the effective 70% tax rate on cannabis businesses in California, and about prisoner Pedro Moreno, currently serving a life sentence in Atwater, CA for a cannabis offense, one of 3000 federal cannabis prisoners still incarcerated.

“This was never just about one week,” writes Kat Murti, executive director of SSDP. “Cannabis Week of Unity was a launchpad for ongoing coordination, advocacy, and movement-building. We are just getting started, and the relationships, momentum, and visibility built this week will continue to power our work moving forward.” Cal NORML is following up with California-based members of the unity coalition, working towards reform efforts in our state as well as federally.

Cannabis vape pens expose users to significantly less harmful toxins than smoked joints, according to a new lab study  sponsored by California NORML.  The study compared the emissions of two different vape pens – a disposable and a reusable cartridge model – with pre-roll joints purchased from a San Diego dispensary.  The vape pens emitted significantly cleaner emissions than the joint for almost all toxins tested, and, unlike the joint, were within EPA safe daily exposure limits for regular users.

“The dangers of vapes have been misrepresented by anti-smoking advocates to suggest their emissions are as hazardous as smoke,” says Cal NORML director Dale Gieringer.  “They are not.”

Why Vaporization Research?

Vaporizers are designed to evaporate a plant’s active ingredients – cannabinoids and terpenes in the case of cannabis, nicotine in the case of tobacco  –  at temperatures  below that of burning leaf, where noxious smoke byproducts and carcinogens form.

Unfortunately, academic research on cannabis vape pens has been stifled by federal regulations that prohibit government-sponsored researchers from working with state-legal cannabis products. California NORML accordingly chose to sponsor a first-of-its kind pilot study of  state-legal cannabis vape pens bought off-the-shelf from a California-licensed dispensary.  The study was conducted by NN Analytics, a San Diego laboratory with expertise in nicotine and cannabis vapor testing, in consultation with MayThe5th, a consulting company devoted to the development of safer electronic vaporization devices.

Vape pens differ from herbal vaporizers, which heat natural cannabis leaf and buds, in that they operate at higher temperatures and use concentrates fortified with additives – typically terpenes – to facilitate vaporization.  They also have metal components that might leak into the vape stream.  These present different risk factors from herbal vapes, which have been shown to be effective in reducing harmful smoke toxins in prior studies by Cal NORML and others.

In this current study, a puffing machine was used to draw equal samples from the vape pens and the joint.   The emissions were tested by standard mass spectrometry methods for cannabinoids and a dozen key toxic emissions (for details see white paper report).

KEY RESULTS

• The vape pens completely eliminated benzene and acrolein, two highly noxious compounds that appeared above safe exposure levels in the joint.  Most other toxins were reduced tenfold or more, except for heavy metals and formaldehyde.  High temperatures are known to generate formaldehyde and other toxins from terpenes and vape oils.
• The vape pen concentrates were nearly 4 times more potent than the joint  (83-86% THC vs 23% THC), but emitted only 1.2 to 2.2 times as much delta-9 THC per puff as the joint.  THC delivery varies greatly depending on device design, temperature, and usage – factors that deserve further research. In practice, some users report they can’t get as high from a vape as a joint, while others report the opposite.   “Potency differences are not an accurate gauge of THC vapor delivery,” comments Gieringer.
•  The only toxins for which vapes scored worse than the joint were the heavy metals nickel and chromium.  Both metals are key components of nichrome wire, which is used for vape heating coils but might well be replaced by a less volatile substitute.  The joint had higher levels of lead and cadmium.
• Devices were evaluated for safety to human health based on EPA and OSHA exposure standards.  Exposure to toxins was measured on the assumption that a regular user inhales 22 puffs per day, or about three joints.  The vapes were well within all applicable EPA daily exposure limits, while the joint was not.  Heavy metals were far below OSHA, NIOSH and Cal-OSHA occupational exposure limits for both vapes and joints.

CONCLUSIONS / FURTHER RESEARCH

In sum, the study showed that cannabis vape pens can be a useful harm reduction substitute for smoked cannabis.  The results of the study are consistent with other research, including a recent study by the vape manufacturer PAX, which indicate that vaporizers can drastically reduce harmful smoke emissions.

However, there exist hundreds of different vape products on the market, whose performance remains to be tested.  Many have different power and temperature settings that could affect toxic emissions.  Variations in concentrate composition, terpene content, device design, and metals content could also affect device performance.

Study sponsors (Cal NORML, MayThe5th and NN Analytics) call on the industry and public health agencies to support further research on cannabis vape pens.  Vape products are now outselling flower in California, yet virtually all published research on inhaled cannabis has focused on smoking, not vaping.

“It’s time to end government restrictions that have hindered research into cannabis vape products that are readily available to U.S. consumers,” says Gieringer. The recent federal rescheduling order could help open the way for state-licensed medical cannabis products to finally become eligible for research.

Also see: New Study: Electronic Cannabis Delivery Systems Show 99.7% Lower Screening Hazard Than Pre-Roll Combustion

by  The Law Office of Shay Aaron Gilmore

On April 22, 2026, Acting Attorney General Todd Blanche signed the most consequential federal cannabis order in more than five decades. The order immediately moves both FDA-approved cannabis products and state-regulated medical cannabis products from Schedule I to Schedule III of the Controlled Substances Act (CSA). At the same time, it launches an expedited administrative hearing — beginning June 29, 2026 — to determine whether broader rescheduling of all marijuana, including adult-use products, should follow.

For California medical cannabis licensees and investors, this is not an abstract federal development. It is a live, operational event with immediate legal, tax, corporate, and compliance consequences. This post breaks down what changed, what did not, what is still unresolved — and specifically what California M-license operators and their advisors need to do right now.

As discussed in our prior post Marijuana Rescheduling, If It Happens, Will Be Incremental Progress — Still Not the Answer, and followed up in California Cannabis M&A in 2026: Rescheduling Momentum, Hemp Bans, and State Integration Collide, rescheduling was never going to be a cure-all. What April 22, 2026 delivered is real but narrow — and the narrowness is exactly what California operators need to understand.

How We Got Here

The rescheduling process dates back to October 2022, when President Biden directed HHS and the DEA to review marijuana’s CSA scheduling. In August 2023, HHS recommended Schedule III, finding that marijuana has a currently accepted medical use and a lower abuse potential than Schedule I or II substances. The DEA published a Notice of Proposed Rulemaking in May 2024, attracting more than 42,000 public comments. Hearings were postponed multiple times — first due to procedural challenges, then due to a stay pending interlocutory appeal.

The process appeared stalled until December 18, 2025, when President Trump signed Executive Order 14370 directing the Attorney General to “expedite and complete” the rescheduling process. Rather than restart the cumbersome notice-and-comment rulemaking, Acting AG Blanche invoked 21 U.S.C. § 811(d)(1), which permits the Attorney General to schedule substances by order when necessary to comply with U.S. obligations under the 1961 Single Convention on Narcotic Drugs — without the full procedural requirements otherwise imposed by the CSA. This treaty-based authority allowed the administration to act immediately.

Critically, the order does not cover all marijuana. It covers two categories only: FDA-approved drug products containing delta-9-THC, and marijuana handled under a qualifying state-issued medical marijuana license. All other marijuana — including adult-use cannabis sold under a state recreational license — remains Schedule I pending the outcome of the June 29 hearing. Hemp and synthetically derived THC are expressly excluded.

California’s Dual-License Structure: The Essential Starting Point

To appreciate what this order does and does not do for California operators, the state’s parallel license structure under the Medicinal and Adult Use Cannabis Regulation and Safety Act (MAUCRSA) is the essential starting point.

Under MAUCRSA, the Department of Cannabis Control (DCC) issues two parallel license designations across all activity categories — cultivation, manufacturing, distribution, retail, testing, and event organizers. An M-license (medicinal designation) authorizes a licensee to engage only in medicinal commercial cannabis activity. An A-license (adult-use designation) authorizes activity only in the adult-use market. A business may hold both designations on the same licensed premises, provided it holds both designations for the identical type of activity.

This bifurcation — maintained since MAUCRSA’s 2017 enactment — turns out to be precisely the distinction that determines who receives federal relief under the April 22 order. The federal order tracks state-licensing categories: it reschedules marijuana products subject to a qualifying state-issued medical marijuana license, and a California M-license fits squarely within that definition. A California A-license does not.

Pure M-license operators — those holding only medical designations across their operations — are unambiguously covered. Dual-license operators, sometimes referred to as mixed-use or MSO-affiliated entities, occupy far more complicated ground, addressed in detail below.

The Tax Transformation: Section 280E Relief Is Real and Effective January 1, 2026

The single largest immediate benefit of rescheduling for California M-license operators is the elimination of the Section 280E deduction disallowance.

Internal Revenue Code § 280E prohibits any deduction or credit for ordinary and necessary business expenses incurred in the “trafficking” of a Schedule I or II controlled substance. Because the IRS treated state-licensed cannabis businesses as traffickers in a Schedule I substance, California operators could not deduct payroll, rent, utilities, marketing, professional services, or any other standard operating expense at the federal level — only cost of goods sold (COGS) remained deductible. The result was effective federal tax rates commonly exceeding 70% for California dispensaries and supply-chain operators.

California partially addressed this disparity through Assembly Bill 37 in 2019, which decoupled state tax law from IRC § 280E, allowing MAUCRSA licensees to take ordinary deductions on their California returns. But the federal burden remained crushing — particularly for California operators who also face some of the highest combined state and local cannabis taxes in the country.

The April 22 order eliminates 280E’s reach over qualifying medical operators. The Treasury Department and IRS confirmed the same day that rescheduling “removes section 280E as a bar to claiming deductions and credits” for qualifying businesses and announced forthcoming guidance. Treasury further confirmed that for § 280E purposes, rescheduling applies for a business’s full taxable year that includes the effective date — meaning January 1, 2026 for calendar-year filers.

This is not a future benefit contingent on further rulemaking. For California M-license operators, the 280E burden has been lifted for the full 2026 tax year. The practical cash-flow impact is substantial: the broader industry is estimated to have been absorbing $2.3 billion in excess federal taxes annually above what it would pay as an ordinary business.

Retroactive Relief: Possible but Not Guaranteed

The order also includes precatory language encouraging — though not mandating — the Secretary of the Treasury to consider retrospective relief from § 280E for taxable years in which a state licensee operated under a state medical marijuana license. This language is aspirational, not legally binding. As one detailed analysis notes, the IRS is not obligated to comply, and operators should not amend prior returns or book corresponding assets until the IRS formally confirms the availability, scope, and mechanics of any look-back period. That said, California M-license operators should begin documenting prior-year expenses now to move quickly if Treasury guidance confirms retroactive applicability.

DEA Registration: A New Federal Compliance Obligation with Teeth

The DEA registration requirement is where this order becomes both the most operationally transformative and the most legally technical for California operators. It is not a benefit layered on top of existing operations. It is a new federal compliance obligation that determines whether an operator can legitimately access Schedule III status — and all of the benefits that accompany it.

What the Requirement Actually Means

The CSA has always required registration with the DEA Diversion Control Division for manufacturers, distributors, and dispensers of any controlled substance, including those in Schedule III. Before April 22, 2026, this requirement had no practical enforcement path against state-licensed medical cannabis operators — their activity was federally illegal under Schedule I, and the DEA’s accommodation of state cannabis markets was purely a matter of prosecutorial discretion. Rescheduling changes the legal architecture fundamentally: state-licensed medical operators are now engaged in a federally recognized activity, and federal law requires that recognized activity to be registered.

The order codifies a new registration pathway under 21 C.F.R. § 1301.13(k) — titled “Medical marijuana registrations” — which directs the DEA to establish an expedited review process for entities holding state medical marijuana licenses seeking registration as manufacturers, distributors, or dispensers. This is not aspirational guidance. It is now codified in the Code of Federal Regulations. And critically, the order is explicit: operating without DEA registration while handling Schedule III-controlled substances is a federal violation.

The practical implication for California operators is significant: to be entitled to the benefits of Schedule III status — most importantly, 280E relief — an M-license operator must obtain and maintain federal DEA registration. An operator who continues business-as-usual under their DCC M-license without filing for DEA registration is not simply missing an optional federal benefit; they are operating outside federal law in a newly codified way.

The 60-Day Window: Why It Is Critical

State-licensed medical marijuana licensees that submit DEA registration applications within 60 days of Federal Register publication — by approximately June 22, 2026 — may continue operating under their state license while the DEA processes the application. This “interim operating authority” provision protects operators from the disruption of having to cease operations while awaiting federal processing. Operators who miss this window forfeit the protection and face the risk that their Schedule III activity may be federally unauthorized during any gap between application and approval.

The DEA has committed to processing applications filed within the 60-day window within six months of receipt. For applications filed after that window, no such processing timeline commitment applies. The practical message: file within 60 days, or accept the risk of an uncertain processing timeline during which your federal compliance status is ambiguous.

Why a California M-License Is Uniquely Valuable — and the Public-Interest Factors That Can Still Block You

The new regulation provides that a state medical marijuana license “shall constitute conclusive evidence that the applicant is authorized under state law to engage in the activity for which registration is sought.” This is a significant legal accommodation. Under standard DEA registration procedures, an applicant must independently establish state-law authorization, and the DEA has substantial discretion to investigate and question that showing. The April 22 order eliminates that ambiguity for California M-license holders: the license is, by regulation, conclusive.

However, conclusive state authorization does not guarantee federal registration. The DEA must register the applicant unless doing so would be inconsistent with the public interest under 21 U.S.C. § 823 or with the requirements of the Single Convention. The § 823 public interest factors include:

• Maintenance of effective controls against diversion of controlled substances;
• Compliance with applicable state and local laws;
• Prior conviction record relating to manufacture, distribution, or dispensing of controlled substances;
• Lack of experience in the distribution of controlled substances; and
• Other factors relevant to and consistent with public health and safety.

For California operators, the most significant factor is compliance with applicable state and local laws. A DCC license with a clean compliance history — no suspensions, no enforcement actions, no unresolved violations — satisfies this factor readily. But operators with prior DCC disciplinary history, unresolved local permit violations, or any federal criminal exposure should carefully assess their § 823 posture before filing, not after. A denial triggered by public-interest concerns creates a federal record that is substantially more damaging than simply not filing.

Historical DEA precedent on this point is sobering: when the DEA reviewed manufacturer registrations for research cannabis in 2021, it noted that conducting cannabis activities compliant with state law but in violation of the CSA “may constitute grounds to deny an applicant’s registration” under the public-interest factors — citing such activity as relevant to the “promotion and protection of public health and safety.” While the new framework is designed to accommodate qualifying state licensees, the public interest factors remain live legal criteria that operators must treat as such.

Registration Is Location-Specific

A frequently overlooked aspect of DEA registration mechanics is that registration is tied to each principal place of business — each licensed premises where controlled substances are stored, administered, or dispensed requires a separate DEA registration. For California operators with multiple licensed locations — a common structure among vertically integrated businesses and those holding cultivator and retailer licenses at separate premises — this means a separate DEA registration application for each location.

This has direct compliance budget implications. A California operator with a licensed cultivation facility in Humboldt County and two licensed retail dispensaries in the Bay Area must file three separate DEA registration applications, each tied to the DCC license for that specific premises. Operators with multi-site portfolios need to inventory their licensed locations and plan registration filings accordingly — and within the 60-day window.

The Automatic Suspension Linkage: A New Federal Risk Tied to DCC Compliance

The April 22 order includes a provision that the DEA registration issued under the § 1301.13(k) expedited pathway is automatically suspended if the underlying California M-license is suspended, revoked, or expires. This is one of the most practically significant provisions in the entire order for California operators and their compliance counsel.

Before rescheduling, a DCC enforcement action — a license suspension, a notice of violation, or even an administrative lapse in renewal — was a purely state-level event. Federal law provided no corresponding benefit to suspend; the operator was already in a legally ambiguous federal position regardless of state compliance status. After rescheduling, the calculus is fundamentally different. A California M-license holder who obtains DEA registration now has a federal benefit that tracks DCC license status in real time. A state enforcement action that results in even a temporary DCC suspension triggers automatic federal registration suspension — meaning the operator’s Schedule III status and entitlement to 280E relief are simultaneously interrupted.

The implications for DCC regulatory compliance are substantial:

• License renewals must be timely. A DCC license that lapses due to a missed renewal filing, a bond coverage gap, or a delayed local permit renewal can trigger automatic federal suspension of the DEA registration. California operators are accustomed to state license renewals as administrative calendar items. They are now federal compliance events.
• DCC enforcement actions have federal consequences. An operator facing a DCC notice of proposed action, a license suspension, or a regulatory investigation must now assess the potential federal fallout in addition to the state consequences. Regulatory compliance counsel must communicate the federal suspension risk to clients engaged in DCC proceedings.
• Ownership change compliance has heightened stakes. DCC regulations require notification of ownership changes within 14 days and impose compliance obligations throughout the change process. If a change-of-ownership process creates a lapse or ambiguity in the DCC license during which the license could be deemed suspended, the DEA registration may be affected. Operators and counsel should structure ownership transitions to avoid any gap in DCC license status.

The automatic suspension linkage makes DCC license compliance not just a state business-preservation issue, but a federal one. For California M-license operators who have obtained DEA registration, the quality and currency of their DCC compliance program is now directly tied to their federal regulatory status.

Schedule III Compliance Obligations That Come with Registration

Obtaining DEA registration does not simply confer federal authorization — it subjects registrants to Schedule III compliance requirements under the CSA and DEA regulations. The April 22 order incorporates state compliance systems where possible, but federal requirements are additive, not displaced. Under the order, registered California M-license operators must comply with:

• Recordkeeping: Schedule III registrants are subject to DEA recordkeeping requirements, though the order directs the Administrator to accept state-required records, forms, and reports to the maximum extent permissible under federal law. California DCC recordkeeping systems — track-and-trace via Metrc — should substantially satisfy federal requirements, but operators should verify that their Metrc records are current and audit-ready before filing.
• Security standards: Registrants may generally rely on state-law physical-security requirements in lieu of otherwise applicable federal standards, subject to limited qualifications. California DCC security regulations are generally consistent with CSA Schedule III standards, but operators should confirm that any pending security upgrades or DCC compliance notices are resolved.
• Labeling and packaging: Registered operators must include the federal warning required by 21 U.S.C. § 825(c) where applicable, in addition to California DCC labeling requirements. Review of product labels for compliance with both state and federal requirements is now required for all M-licensed products.
• Disposal: State-authorized disposal procedures generally suffice under the order, but operators should document their disposal protocols to demonstrate compliance with both DCC and federal standards.
• Import/export permits: The order amends 21 C.F.R. Part 1312 to add an import/export permit requirement for Schedule III marijuana. Any California operator currently contemplating international product movement must account for this permit requirement.
• The Single Convention nominal-price mechanism: State-licensed registrants are subject to a nominal-price purchase-and-resale arrangement designed to satisfy Article 23 of the Single Convention on Narcotic Drugs. Cultivators registering as manufacturers should understand this mechanism and its operational implications before completing registration.

The “Practitioner” Registration Category for Dispensaries

The order introduces an additional registration category relevant to California dispensaries. Entities that transfer Schedule III marijuana to patients — including California M-licensed retail dispensaries — must register with the DEA as “practitioners” under 21 U.S.C. § 823(g). This is a distinct registration category from the manufacturer or distributor registration, and the order makes clear that a practitioner registration does not authorize possession or dispensing of Schedule I controlled substances — meaning it does not extend to the adult-use inventory a dual-license dispensary also holds.

For California dual-license retail operators, this creates a layered registration question: the dispensary entity needs a practitioner DEA registration to cover its M-license dispensing activity, and continued state-only authorization (with no DEA registration) for its A-license adult-use activity. Inventory, recordkeeping, and physical custody of product must be maintained consistent with these different legal statuses simultaneously.

The Dual-License Problem: California’s Most Complex Compliance Challenge

Perhaps the most practically urgent compliance question in California concerns operators who hold both M-license and A-license designations. Many California dispensaries, cultivators, manufacturers, and distributors operate in exactly this structure — serving both medical patients and adult-use consumers, often on the same licensed premises.

The April 22 order creates a bifurcated federal schedule for these operators’ activities. Their M-licensed operations are now Schedule III. Their A-licensed operations remain Schedule I. They operate across two federal schedules simultaneously, with no precedent for this kind of split classification at the entity level.

Treasury has announced that forthcoming guidance will address expense apportionment — allocating costs between medical and adult-use activities, with only the former eligible for § 280E relief. From a regulatory compliance standpoint, dual operators need to examine their accounting systems immediately to determine:

• Whether revenue, payroll, inventory, and overhead are tracked separately by license type or commingled;
• Whether existing management agreements, intercompany allocations, or shared-service arrangements satisfy the “genuine separation” standard applied by the IRS and U.S. Tax Court;
• Whether entity structures put in place under prior 280E-minimization strategies remain optimal in a bifurcated Schedule III/Schedule I world;
• What additional documentation and accounting controls should be implemented now, before Treasury guidance issues, to ensure maximum defensibility.

Many California MSO structures were specifically architected to reduce 280E exposure through entity separation. Some of those structures may be redundant for the medical side of the business, or could inadvertently complicate expense allocation for the adult-use side. A comprehensive structural review — the kind of analysis that lives at the intersection of corporate law and regulatory compliance counsel — is not optional for California dual operators. It is urgent.

Capital Markets and Investment: What Investors Need to Know

The order has immediate implications for investors in California medical cannabis operations — both in ongoing cannabis M&A transactions and for those evaluating new positions.

Valuation and Cash Flow

The elimination of 280E for medical operators is the most direct valuation lever. For any California operator with meaningful M-license revenue, 280E removal translates directly to improved cash flow, stronger EBITDA, and lower effective tax rates. Verano Holdings, a major MSO, estimated that rescheduling would save it approximately $80 million annually in 280E expenses. California-specific operators and single-state businesses operate at different scale, but the directional impact is consistent: M-designated revenue streams are materially more valuable post-order than they were on April 21, 2026.

M&A Due Diligence Has Changed

The order “draws a line through the middle of the industry.” For California buyers and sellers in ongoing M&A processes, the regulatory compliance picture is fundamentally different for M-license positions than for A-license positions. Diligence on a California target that holds both designation types now requires separate analysis of each license category. As reflected in our Cannabis M&A Transactions practice, deals must now account for:

• The adequacy of the target’s M-license compliance infrastructure, since that license is now the gateway to DEA registration and 280E relief;
• Whether the target’s DCC license history is clean enough to support federal registration under the § 823 public-interest factors — a clean enforcement record is now a material deal term, not just a background diligence item;
• The DEA registration gap in change-of-control transactions. When a California cannabis business changes ownership, the DCC requires the new owner to submit all information under 4 CCR § 15003, including a background check, and the business may continue operating during the approval process. However, a change of ownership may affect the underlying state license status in ways that trigger the automatic DEA registration suspension provision — particularly if there is any period during which the DCC treats the existing license as having undergone a material change. Buyers and sellers must structure change-of-control provisions to address this risk, including whether responsibility for maintaining uninterrupted DEA registration vests with the seller, buyer, or is addressed through escrow or closing condition mechanics;
• Indemnification structures that explicitly address which party bears the risk if retroactive § 280E relief is or is not granted, and for which license categories.

Representations and warranties in cannabis M&A agreements must now be license-type-specific. A blanket representation that the company is in “regulatory compliance” is insufficient — it must distinguish M-license and A-license compliance postures, address DEA registration status, and account for the automatic suspension risk going forward.

Diligence Matrix for California Cannabis M&A Post-April 22

Banking: Improvement at the Margins

The cannabis banking problem has not been solved by rescheduling. Financial institutions remain subject to the Bank Secrecy Act and the 2014 FinCEN guidance, neither of which is eliminated by Schedule III status. Major banks are unlikely to fundamentally change their posture until the SAFER Banking Act passes or explicit federal safe harbors are legislated. For California cannabis investors and venture capital advisors evaluating debt-financed transactions, the practical takeaway is improved debt service capacity for medical operators and a somewhat more favorable lending environment at cannabis-specialist lenders — but not a transformed one.

Legal Risks: What Could Unwind This

The April 22 order is consequential, but not legally bulletproof. California operators and counsel should understand the primary vulnerabilities.

The Treaty Authority Question

The DOJ bypassed ordinary notice-and-comment rulemaking by invoking 21 U.S.C. § 811(d)(1). Legal commentators have noted that the order relies heavily on a 2024 Office of Legal Counsel opinion regarding treaty compliance — an interpretation not beyond challenge, particularly under the Supreme Court’s Loper Bright framework, which has increased judicial scrutiny of agency statutory interpretations. Whether the treaty-implementation authority extends to the full range of regulatory amendments accompanying the order — including new DEA registration requirements under 21 C.F.R. § 1301.13(k) — is a narrower but potentially significant legal question.

The order includes an express severability clause, acknowledging that individual provisions might be struck down without invalidating the whole. A registered operator who has affirmatively integrated into the federal framework is better positioned to argue for preservation of their status under a severability analysis than an operator who has not yet filed — another reason to act within the 60-day window.

The Ongoing Administrative Hearing

The expedited DEA hearing beginning June 29, 2026 will consider broader rescheduling of all marijuana. If that process results in comprehensive rescheduling, the adult-use gap closes and the current bifurcated structure becomes transitional. If the hearing produces delays — as the prior Biden-era process did — the two-tier system could persist for years, embedding competitive asymmetry between medical and adult-use operators. As analyzed in A Spring 2026 Field Report for California Cannabis Operators and Investors, the legal and market landscape is in genuine flux, and strategic decisions should be made with that uncertainty priced in.

Competitive Dynamics and the Illicit Market

One under-discussed consequence of partial rescheduling is its effect on California’s persistent illicit market problem. Licensed cultivators in California produced approximately 1.4 million pounds in 2024, while unlicensed operations produced an estimated 11.4 million pounds — a ratio that reflects the illicit market’s continued dominance, according to the DCC-commissioned ERA Economics report. The DCC’s head of enforcement has acknowledged the black market remains “very pervasive, and definitely larger than the legal market.”

By eliminating the 280E burden from licensed medical operators, rescheduling directly reduces one of the largest structural cost disadvantages that licensed operators face relative to the illicit market. The limitation, however, is that adult-use operators serve the far larger share of California’s consumer market and remain subject to 280E, limiting the aggregate competitive effect until broader rescheduling follows.

What California M-License Operators Must Do Now

This section is directed at California operators who hold active M-license designations — either as pure medical operators or as part of a dual M/A-license structure.

Immediate Actions (Next 60 Days):

1. File your DEA registration application — by approximately June 22, 2026. This is the most time-sensitive action item. The 60-day window is the critical window for securing interim operating authority and a committed six-month DEA processing timeline. File a separate application for each licensed premises. Work with regulatory compliance counsel to assemble your DCC license documentation, confirm your license is current and in good standing, and assess your § 823 public-interest factor exposure before filing.
2. Engage your tax counsel on 280E planning now. The effective date is January 1, 2026. Your accountant and tax attorney should immediately assess whether your entity structure, cost accounting systems, and expense tracking are positioned to capture the full benefit of post-280E deductibility. If you are a dual operator, this analysis must address expense apportionment between your medical and adult-use activities before Treasury guidance issues.
3. Audit your DCC license compliance status. Federal registration automatically suspends if your California DCC license is suspended, revoked, or expires. Ensure all renewal filings, bond requirements, local permit renewals, and DCC compliance obligations are current. This is now a federal issue.

Near-Term Strategic Actions (Next 90–180 Days):

1. Review your corporate structure. Many California operators built multi-entity structures specifically to mitigate 280E exposure — separating plant-touching and non-plant-touching entities, establishing management companies, and structuring brand licensing arrangements to shift deductible expenses upstream. Some of those structures may be redundant for the medical side of the business and may create unnecessary complexity in the new environment. A corporate restructuring review with both corporate counsel and regulatory compliance counsel is warranted.
2. Revisit existing transaction documents. If you are party to a pending acquisition, earn-out, management agreement, or lease that was negotiated under the prior 280E economics, review it for provisions that need updating. Allocation of retroactive § 280E relief, representations about regulatory compliance, change-of-control triggers affecting DEA registration, and indemnification carve-outs are live issues in every California cannabis M&A transaction being negotiated today.
3. Monitor the June 29 hearing. The outcome of the expedited DEA administrative hearing on broader rescheduling has direct implications for your competitive position, corporate structure, and transaction strategy. If adult-use cannabis moves to Schedule III through the hearing process, the calculus for restructuring and deal-making changes substantially.

The Bigger Picture for California

California was the first state to legalize medical cannabis in 1996 under the Compassionate Use Act, and it has operated the world’s largest legal cannabis market for nearly a decade. The state’s MAUCRSA framework, which created parallel M and A designation categories, inadvertently positioned California’s medical-designated operators as the first beneficiaries of federal rescheduling — provided they hold M-licenses and take the compliance steps required by the April 22 order.

The irony is not lost that adult-use operators — who serve by far the larger consumer segment in California — are excluded from the immediate order and continue under the crushing weight of Schedule I federal treatment. This creates a bifurcated competitive environment within the California market itself, with medical operators potentially achieving sustainable economics while adult-use operators continue under structurally punitive tax treatment. As anticipated in Marijuana Rescheduling, If It Happens, Will Be Incremental Progress — Still Not the Answer, rescheduling was never going to resolve every structural problem the California cannabis industry faces. But for California M-license operators who act quickly and competently, it is the most significant shift in federal cannabis law in a generation — and the compliance window is narrow.

This post is for informational purposes only and does not constitute legal advice or create an attorney-client relationship. If you hold a California cannabis license and have questions about how the DOJ’s rescheduling order affects your regulatory compliance obligations, corporate structure, or any pending transaction, contact the Law Office of Shay Aaron Gilmore for a consultation.

Shay Aaron Gilmore is a member of California NORML’s Board and Legal Committee. See his Cannabis Marketplace listing for more information 

Cal NORML Voter Guide to Cannabis Candidates

June 2026 Primary Election

Got input on candidates or races? Write here.

Artwork: Ruth Anne

UPDATED 6/6/26

Quick Links: EXECUTIVE / CONGRESS / STATE SENATE / STATE ASSEMBLY / LOCAL

Governor

RESULTS: Democrat Xavier Becerra is projected to be heading to the November run-off, with his opponent being either Republican Steve Hilton or Democrat Tom Steyer. The only terrible candidate on cannabis in the race, Chad Biando, doesn’t appear to be in the running. Hilton’s and Steyer’s positions on cannabis are not known; Becerra has a good record on the issue. More than more than 3 million votes that remain to be counted and are expected to skew Democratic.

Xavier Becerra – In 2016, as California’s Attorney General, Becerra told Politico he would be defending California’s new law legalizing marijuana against possible federal interference, and admitted he tried weed “at a younger time.” Asked if it was illegal then, he compared it to driving over the speed limit. “Cannabis is last century’s argument. We’re beyond that,” he said. He continued the CAMP (Campaign Against Marijuana Planting) program (as have all AGs) and in 2020, he joined 34 other AGs to urge Congress to provide banking services for licensed cannabis businesses. In 2013, as US Secretary of Health and Human Services, oversaw the agency’s recommendation that cannabis should be reclassified as a Schedule III drug under the Controlled Substances Act, something that’s back in the news. Becerra has a longer record of public service in both state and federal government than all the other candidates. He compiled a consistently good voting record over 24 years as a Congressman from L.A.

Chad Bianco – Riverside sheriff Bianco is a crusty, old-style, right-wing Republican who takes a tough line on drug issues.  A former narcotics officer, he is the only candidate on record as opposing legal marijuana, and he thinks legalization has exacerbated the problem of illegal grows. (Cannabis growers can’t be licensed in most of his district; a horrible homicide in Riverside left seven dead at an illicit farm in 2020.) Last year, commenting on news that that California’s Department of Cannabis Control lost a lawsuit alleging they failed to stop illegal operations, Bianco commented, “Another failed agency from a failed State agenda….Legal marijuana was doomed from the start. It was a scam to begin with but once passed it was going to actually take work to make it successful.” Reportedly Bianco said that all marijuana is laced with fentanyl at a campaign event. He seized voting records in Riverside in a MAGA-inspired goose-chase for voter fraud, before the courts stopped him.

Steve Hilton – Former Fox News host Hilton is the other Republican front-runner in the race and the one that Trump endorsed. Like Bianco, he is critical of California’s Democratic supermajority. Unlike Bianco, his views on cannabis legalization are unknown. Given the Trump administration’s bold rescheduling order, timed just before the midterms, it’s not impossible that they are favorable. One of his CalDOGE investigations concluded the $370 million in cannabis taxes earmarked yearly for youth drug prevention is largely misspent, including funding Democratic-leaning organizations. (The same organizations lobbied forcefully to raise the cannabis excise tax last year in order to keep their funding.)

Matt Mahan – The moderate Democrat in the race, Mahan is the popular mayor of San Jose who has made strides against homelessness in the city. He was typically supportive of local dispensaries, except for one zoning vote. Mahan styles himself as a social liberal, but is mostly interested in economic issues. Local activists give him a thumbs up.

Katie Porter – Porter takes pride in being the only candidate who never accepts corporate donations. She is particularly interested in economic issues, but has consistently voted well on marijuana bills. She has co-sponsored the SAFE Banking Act and the MORE Act to legalize at the federal level, with equity and human rights components. She voted well on other bills, and declared support for legal marijuana in response to a questionnaire from Cal NORML in a past race.

Tom Steyer – A self-styled progressive, hedge fund billionaire Steyer has bombarded the air with over $100 million in commercials, spending multiple times more on his campaign than all other candidates combined. Steyer is an outspoken champion of environment and climate legislation, but has made no campaign pronouncements on cannabis (but now that rescheduling has happened perhaps a reporter will actually ask candidates about it).  In 2020, while running for President, Steyer was overheard supporting legalization, saying “I’m from California, are you kidding me?”  He also vocally advocates “restorative justice.”  At a debate on KRON TV in which Bianco and Hilton blamed homeless on drug addiction, Steyer advanced his plan to provide emergency shelter without requiring residents be “clean” (from drugs). Like all candidates, however, he endorses mandatory treatment for delinquent addicts.

Tony Thurmond – State Education Superintendent and solid progressive, Thurmond posted a good voting record in the Assembly, where as chair of the Labor Committee he supported a Cal NORML-sponsored bill for employees’ right to use marijuana off the job.

Antonio Villaraigosa – Former LA Mayor and Assemblyman, labor leader and ACLU president who styles himself as a problem solver and has admitted to using marijuana. As mayor, Villaraigosa presided silently over the introduction of medical marijuana clubs into the city (no one had dared open one during the administration of his Republican predecessor).

Also running:  The ballot is cluttered with another 53(!) candidates for governor.

Lieutenant Governor – ENDORSE FIONA MA

RESULTS: Ma and Republican Gloria Romero are leading in the race. 

As state treasurer, Ma has been a longtime supporter of cannabis and of lowering taxes on cannabis. She responded to Cal NORML/CCIA’s 2026 Candidate Survey, saying she would support addressing “cannabis deserts” with no licensed businesses, streamlining state/local permitting and regulations, and encouraging cannabis tourism in our state. She also supports intensifying enforcement against the illicit market, and measuring enforcement effectiveness in terms of market growth/stability/outcomes. And she’s for providing MediCal and worker’s comp coverage for medicinal cannabis, and funding state-sponsored research into the safety and efficacy of cannabis products.

Ma wrote, “We need to overturn Prop 64. It’s a complete failure,” something she was interviewed about in High Times. She testified before Congress in favor of banking for cannabis businesses. She also offered a response to rescheduling, saying, “I welcome the long-overdue decision to reclassify cannabis from Schedule I to Schedule III, a step that will provide meaningful relief by ending the unjust application of IRS Code Section 280E and beginning to dismantle barriers that have shut legitimate businesses out of the financial system. But let us be clear: reclassification alone is not enough.”

Attorney General – ENDORSE ROB BONTA

RESULTS: Bonta is leading Republican challenger Michael E. Gates; they appear headed for a November run-off. 

Bonta sponsored bills to regulate medical cannabis, lower taxes on cannabis, and protect employment rights of cannabis users while in the Legislature. As AG he helped expedite the clearing of criminal records for past cannabis offenses.  He has also successfully defended California law against federal interference in multiple court cases.

CONGRESS

Here are some of the frontrunners in key new Congressional districts (all are up for election). Many are in crowded fields in these top-two primaries.

Don’t know your district? Look it up.

Find office holders’ NORML ratings.

Got input on candidates or races? Write here.

CD 1 – Susanville, Red Bluff, Chico, Ukiah

RESULTS: McGuire and Gallagher are headed for a November run-off. 

Mike McGuire (A rating at NORML) has a strong voting record and authored one of the three bills that regulated medical marijuana in California in 2015. He favors adult-use legalization, but opposed Prop. 64 until such time as regulation of medical cannabis could be solidified. He strongly supports local regulation and was a key opponent of outlawing local delivery bans.
James Gallagher (D- rating) has a bad voting record in the state legislature, slightly improved in 2024 with yes votes on ending double cannabis taxation at local level, and allowing small farmers to sell directly to consumers.

CD 3 – Parts of Sacramento, Folsom, Rancho Cordova, Auburn, Truckee and South Lake Tahoe.

RESULTS: U.S. Rep. Ami Bera (D-Elk Grove with an A NORML Rating) and Republican Nevada County Supervisor Robb Tucker are projected for a November showdown.

CD 4 – Napa Valley through Yolo County and into the Sacramento Valley

RESULTS: Incumbent Democrat Mike Thompson (A- NORML Rating) will face either Republican Ray Riehle or Democrat Eric Jones in November. 

CD 6 – Roseville, Citrus Heights, parts of West Sacramento

RESULTS: Too close to call with Independent Kiley either facing Democrat Pan or Republican Michael Stansfield in November. 

Martha Guerrero – West Sacramento Mayor has local activist support; she voted in favor of cannabis licensing
Thien Ho – Sacramento’s district attorney
Lauren Babb Tomlinson – Planned Parenthood executive 
Dr. Richard Pan – Along with other Democrats, Sen. Pan voted against a 2012 bill to reduce charges in marijuana cultivation cases, after strong police opposition. As chair of the Senate Health committee in 2018, he voted for a bill to redirect cannabis tax funds for youth programs despite the Dept. of Health Care Services writing an opposition letter saying it would require them to exercise preferential treatment. In 2022, he authored a bill to require costly, badly designed new label warnings on all cannabis products.
Kevin Kiley (D+ NORML rating) voted wrong on nearly every key vote in the Assembly, although he did vote for cannabis compassion programs, automatic resentencing, and a resolution to ask the DOJ to allow cannabis businesses. Switched from Republican to Independent.
Michael Stansfield – the sole Republican in the race. “I wanted to show Christianity and Judaism a God from the Bible who loves Muslims,” Stansfield said in a telephone interview after the election. “I wasn’t necessarily going after it to win a race.”

CD 11 – San Francisco

RESULTS: Wiener is leading, will likely face Chan in November. 

Sen. Scott Wiener (A+ NORML rating) has been a champion for cannabis in the state legislature, sponsoring SB 34 to allow for tax-free compassion programs for patients, and SB 1186, requiring local governments to permit medical cannabis sales or delivery.   Wiener also championed a psychedelics decrim bill that was vetoed by Gov. Newsom.  Wiener has the strongest record of cannabis reform advocacy of any candidate in the race.
SF Sup. Connie Chan has posted a “dismal” voting record on the Board of Supervisors according to local cannabis advocates, despite running as a progressive with Nancy Pelosi’s endorsement.  Chan was one of only three supes to vote against delaying a special cannabis gross receipts tax, and has repeatedly refused to meet with representatives of the Brownie Mary Democrats.
Other candidates include progressive software multi-millionaire Saikat Chakrabarti,  a former aide to Rep. Alexandria Ocasio-Cortez, who like Steyer is running from the left on a social democratic platform funded by himself;  and  multi-generation San Francisco attorney Marie Hurabiell, who styles herself as a “common-sense Democrat” and helped lead the recall campaign against former D.A. Chesa Boudin.

CD 14 – Livermore, Pleasanton, Hayward, Fremont

RESULTS: Wahab is leading, will face another candidate in November. 

Victor Aguilar, Jr. is a Brownie Mary Club Member and San Leandro councilmember
Sen. Aisha Wahab (C NORML rating) – Rather weak voting record for a Democrat. Voted against cannabis cafes and farmers markets, but also against restrictive labeling for cannabis products in 2024.
This is one of many crowded fields.

CD 20 – Tulare; Parts of Bakersfield & Fresno

Vince Fong (D- NORML rating) posted a terrible voting record on marijuana & drug issues in the CA Assembly, just like his former boss, Kevin McCarthy.

CD 22 – Corcoran, Bakersfield

RESULTS: Valadao is leading with Villegas so far beating Bains for the run-off spot. 

Randy Villegas – A progressive who’s said to have a fundraising lead. Endorsed by Bernie Sanders, Dolores Huerta, Ro Khanna, Lateefah Simon, others.
Asm. Jasmeet Bains (B- NORML Rating) – Dr. Bains is the medical director of a network of Bakersfield addiction treatment centers. Has voted well, except on cannabis cafe bills, from which she has abstained. Shut down any discussion of relative harms of cannabis and tobacco smoke in committee, scolding us by saying, “Smoking is bad, people” and leaving in a huff.
David G. Valadao (D+ NORML Rating) – As an Assemblymember, Valadao voted against every marijuana reform measure and opposed recreational legalization, but co-sponsored an industrial hemp bill. In Congress, he supported the SAFE banking act and medical marijuana research, but joined other Republicans in opposing the Democrats’ MORE legalization bill. One of just two Republican House members running for re-election who voted to impeach Donald Trump.

CD 23 – Victorville

RESULTS: Obernolte has a strong lead over Democrat and NPP challengers. 

Jay Obernolte (D+) has had a poor voting record in the legislature and Congress. He did vote yes on a state bill (AB2020) to expand places where cannabis events can be held, and was absent for a vote on a resolution to the federal government to allow state-legal cannabis programs (AJR 27). Twice he voted against cannabis compassion programs for needy patients (SB 34).

CD 26 – Oxnard

RESULTS: Irwin is leading and will likely face a Republican challenger in the fall. 

Asm. Jacqui Irwin (C-) Mixed voting record. Sponsored failed bills to ban cannabis billboards and impose restrictive labeling requirements on cannabis products; voted against cannabis cafes; skipped votes on employment rights, medical access. To her credit, she did move AB 2555, a bill to extend cannabis compassion programs, through a key committee she chaired in 2024.
Fellow Democrat Chris Espinosa is challenging her.

CD 38 – El Monte, Yorba Linda, Montebello

RESULTS: Solis will face GOP challenger Pedro Antonio Casas in November. 

Hilda Solis, a former Congresswoman, championed cannabis business licensing “that is rooted in equitable access, strong and effective enforcement, and community awareness and education” as an LA County Supervisor. She has also championed Prop. 47’s implemetation, saying she is is “deeply concerned about rising deaths within our correctional health system, driven in large part by overdoses….Every person in custody deserves timely, adequate, and humane health care, and we must continue working to achieve this goal.”
Monica Sánchez has the endorsement of Linda Sánchez, who is vacating the seat to run in the 41st. She’s either (or both?) Pico Rivera Councilmember / Montebello Mayor Pro Tem.

CD 40 – Rancho Santa Margarita, Lake Elsinore

RESULTS: Calvert leads; will likely face Kim in November. 

Ken Calvert (F NORML Rating) has voted badly on every cannabis bill in Congress.
Young Kim (D+ NORML Rating) had a poor voting record in the state legislature except on more recent regulatory bills, and she opposed Prop. 64. In Congress, she voted against the MORE Act but supported the SAFE Banking Act.

CD 41 – Santa Fe Springs, Lakewood, La Habra

RESULTS: Republican Mitch Clemmons and Sánchez will face off in the fall. 

Linda Sánchez (B+ NORML Rating) Co-sponsored the SAFE Banking Act of 2021, voted well on other bills.

CD 48 – Temecula, Vista

Daryl Issa’s district. 

RESULTS: Desmond and von Wilpert advance to the November ballot. 

Jim Desmond (R) San Diego County Supervisor
Marni von Wilpert (D) – San Diego Councilmember
Ammar Campa-Najjar (D)  – former Obama official

STATE LEGISLATURE

Find your districts.

Find office holders’ NORML ratings.

Got input on candidates or races? Write here.

Senate

State Senate District 4 – Counties of Alpine, Amador, Calaveras, El Dorado, Inyo, Madera, Mariposa, Merced, Mono, Nevada, Placer, Stanislaus, and Tuolumne

RESULTS: Democrat Jaron Brandon and Republican Alexandra Duarte lead in a race with two winners.

Marie Alvarado-Gil (R) (B- NORML Rating) Mixed voting record in CA Legislature. Voted for cannabis cafes and against restrictive labeling on cannabis products. Was absent for employment rights vote and voted against farmer’s market bill. Sponsored a bill to forfeit property from illicit cannabis growers; took amends from Cal NORML to target grows of 1,000 plants or more. Switched from a Democrat to a Republican in mid-2024.
Also in the race: County Supervisor Jaron Brandon (D) and Alexandra Duarte (R) mother/farmer

State Senate District 10 – South Bay Area, from Hayward down to Santa Clara north of San Jose.
Aisha Wahab’s district. No Democratic party endorsement in the race. 

RESULTS: Price and Sakakihara lead in a race with two winners.

Scott Sakakihara – Union City councilmember/Navy officer; served in Obama White House. Endorsed by State Senator Jesse Arreguín, Assemblymember Bill Quirk (Ret.), East Bay Young Democrats, unions. Just voted against raising cannabis tax in Union City.
Linda R. Price – Republican mediator, coach, consultant, hypnotherapist and trainer
David Cohen is a member of the San Jose City Council
Anne Kepner is a member of the West Valley-Mission Community College District Board of Trustees; has support of SEIU, Ca Teachers Assn., Cal Labor Federation.
Raymond Liu is a member of the Fremont City Council

State Senate District 12 – Fresno, Clovis, Tulare, parts of Bakersfield
Shannon Grove’s district. She’s running for Board of Equalization.

RESULTS: Magsig wins decisively and will face a challenger in the fall. 

Nathan Magsig (R) is a member of the Fresno County Board of Supervisors
Louis Miramontes (R)
William Brown Jr. (L)

State Senate District 14 – Central Valley south of Highway 99. Includes Merced, Madera, Chowchilla, Fresno and Mendota.

RESULTS: RESULTS: Republican DuPont and Democrat Soria are neck-and-neck and will face off in the fall.

Esmeralda Soria (A NORML Rating) – Democratic Assemblymember and clear frontrunner
Esmeralda Hurtado – Sanger City Councilmember and sister of poorly voting Sen. Melissa Hurtado, who is running in SD-16
Darin DuPont – Merced city councilmember

State Senate District 16 – Central Valley district that includes portions of Fresno, Kings, Tulare and Kern counties and much of Bakersfield’s east side

RESULTS: Gonzalez and Hurtado win.

Melissa Hurtado (D NORML Rating) – Worst voting record of any Democrat in State Senate 2021-2, and just as bad in 2023-4. Did vote in favor of parental rights.
Guillermo Gonzalez – a field representative for the cannabis unfriendly Rep. David Valadao
Manpreet Kaura – Bakersfield Vice Mayor

State Senate District 24 – Coastal Los Angeles County; Malibu, Santa Monica and Torrance
Ben Allen’s district (running for Insurance commissioner)

RESULTS: Republican Marshall and Democrat Goldsmith lead.

Dr. Sion Roy is a physician, professor, and education advocate who is Vice Chair of the Santa Monica College Board. Endorsed by Democratic party.
Brian Goldsmith – Democratic media consultant, has a roster of prominent names behind him and has out fundraised the others
John Erickson – West Hollywood City Councilmember
Eric Alegria is a member of the Palos Verdes Peninsula Unified School District school board
Zennon Ulyate-Crow was shot in the face with a rubber bullet while peacefully protesting ICE. Gen Z.
G. Rick Marshall – clinical informatics specialist at UC Irvine Health; one of two Republicans in a crowded field

State Senate District 26 – Downtown Los Angeles
Maria Elena Durazo’s District (running for LA County supervisor). No Democratic Party endorsement in the race. 

RESULTS: Hernandez wins. One additional candidate will win in this race.

Wendy Carrillo was a communications manager for SEIU ULTCW (United Long Term Care Workers) and a communications and social media deputy for the City of Los Angeles
Sara Hernandez is a member of the Los Angeles Community College Board of Trustees
others…

State Senate District 38 – Coastal north of San Diego, including Mission Viejos, Carlsbad, Encinitas and La Jolla

RESULTS: Blakespear and Bassett win in an uncontested election.

Catherine Blakespear (A NORML Rating) – Democratic State Senator who flipped the district and faces her first re-election
Laura Bassett (R) – a small businesswoman.

State Senate District 40 – Inland San Diego County, north and east of city of San Diego (includes Escondido)
Brian Jones’s district

RESULTS: Elliott wins. Will face a Republican challenger in the fall. 

Mara Elliott (D) was the San Diego City Attorney
Kristie Bruce-Lane (R) – twice unsuccessful Assembly candidate endorsed by cannabis-unfriendly Asm. Carl DeMaio
Ed Musgrove (R) – San Marcos city councilmember

Assembly

State Assembly District 3 – Butte, Glenn, Placer, Sutter, Tehama, Yuba counties
Gallagher’s district – he’s running for Congress

RESULTS: Dom Belza and James Johansson lead in a race with two winners.

3 Republicans running

State Assembly District 12 – Petaluma
Damon Connolly’s district (running for state Senate)

RESULTS: Cervantes and Lucan lead in a race with two winners. Elward a strong third. 

Jackie Elward is a labor organizer and the first Black woman elected to the Rohnert Park City Council. Born in the Congo. Endorsed by: Congressmember Mike Thompson, Former Congressmember Lynn Woolsey, State Assemblymember Tina McKinnor, Former State Senator Steven Bradford, State Treasurer Fiona Ma
Eli Beckman – Corte Madera Mayor
Eric Lucan – Marin County Supervisor
Steve Schwartz – nonprofit executive
Holli Thier – Tiburon Councilmember
Eryn Cervantes (R) – a corrections official who also ran in 2024

State Assembly District 27 – Fresno
Esmeralda Soria’s district (running for state Senate)

RESULTS: Mike Murphy wins. Will likely face Pacheco in the fall. 

Brian Pacheco (D) – Fresno city councilmember, has support of leading Democrats, including Soria.
Mike Murphy (R) – attorney and former Merced mayor
Japjeet Singh Uppal (D) – Livingston Councilmember

State Assembly District 34 – Barstow
Tom Lackey’s district; he’s termed out

RESULTS: Republican Charles Frederick Hughes and Putz lead in a race with two winners.

Randall Putz (D) – Former school board member, city councilmember, and three-time Mayor of Big Bear Lake. Endorsed by California Democratic Party, California Teachers Association, California Young Democrats, Communication Workers of America, and San Bernardino County Professional Firefighters Local 935, State Treasurer Fiona Ma, Superintendent Tony Thurmond, Senator Tom Umberg, Assemblymembers Josh Lowenthal, Juan Carrillo, John Harabedian, Nick Schultz, James Ramos, Robert Garcia, Corey Jackson, and Congresswoman Norma Torres.
3 Republicans are also in the race. 

State Assembly District 35 – Bakersfield
Jasmeet Bains’s district (running for Congress)

RESULTS: Ayon and Gonzales lead in a race with two winners.

Andrae Gonzales (D) – Bakersfield councilmember
Ana Palacio (D) – ER nurse
Saul Ayon (R) – mayor of McFarland

State Assembly District 36  – Coachella

RESULTS: Gonzalez wins. One additional candidate will win in this race.

Jeff Gonzalez (R) – incumbent; voted for cannabis tax reform in his first term. A retired Marine, pastor and business owner.
Oscar Ortiz (D) – Indio Councilmember
Tomas Oliva (D) – former El Centro councilmember
Marlon Ware (D) – college professor
Ida Obeso-Martinez (D) – Imperial Councilmember

State Assembly District 42 – Thousand Oaks
Jacqui Irwin’s district (running for Congress)

RESULTS: Lopez and Nordblum lead in a race with two winners.

Deborah Klein Lopez (D)
Ted Nordblum (R)
Rocky Rhodes (R)

State Assembly District 47 – Palm Springs

RESULTS: Wallis and Namvar lead in a race with two winners.

Greg Wallis (D) – (A NORML rating)
Leila Namvar (D) – former local labor leader and city planner; has labor support
Jason Byors (D) – computer programmer

State Assembly District 58 – Corona

RESULTS: Castillo and Cervantes win in an uncontested election.

Leticia Castillo (R) – the incumbent; voted for a hemp bill and didn’t vote on the cannabis tax reform bill
Clarissa Cervantes (D) – Riverside councilmember who narrowly lost to Castillo in 2024.

State Assembly District 65 – Compton
Mike Gipson’s district; terming out

RESULTS: Davis wins. One additional candidate will win in this race.

Fatima Iqbal-Zubair (D) – chair of the California progressive caucus
Ayanna Davis (D) – trustee for the Compton Unified School District; backed by the state Democratic Party
Eugene Allen (D) – former candidate for insurance commissioner
Lamar Lyons (D) – president of the San Pedro Central Neighborhood Council
Magali Sanchez-Hall (D) – project manager at UCLA
Lydia A. Gutiérrez (R) – public school teacher

State Assembly District 66 – Torrance
Muratsuchi’s district

RESULTS: Paul Seo (D) and Jessica Zonia Maldonado (R) lead in a race with two winners.

State Assembly District 67 – Fullerton
Quirk-Silva’s district

RESULTS: Paulo Morales (R) and Mark Pulido (D) lead in a race with two winners.

State Assembly District 68 – Anaheim
Avelino Valencia’s district

RESULTS: Ruiz and Penaloza lead in a race with two winners.

Jessie Lopez (D)
David Penaloza (D)
Shannon Wingfield (D)
Mayra Ruiz (R)

State Assembly District 72 – Huntington Beach
Diane Dixon seat

RESULTS: Kluwe and Van Der Mark lead in a race with two winners.

Chris Kluwe (D)  An ex-NFL football player for the Minnesota Vikings, Kluwe is a strong believer in medical cannabis.
Matthew Harper (R)
Gracey Van Der Mark (R)
Frank Wagoner (No party preference)

State Assembly District 74 – Oceanside

RESULTS: Davies and Farias win in an uncontested election.

Laurie Davies (D NORML Rating) – has a pretty bad voting record
Sergio Farias (D) – San Juan Capistrano councilmember and former mayor

Local Measures

City of Los Angeles – Measure CB, Apply Marijuana Tax to Unlicensed Marijuana Businesses Measure
A “yes” vote supports applying the city’s tax on cannabis businesses to unlicensed cannabis businesses, amounting to:
10% on cannabis sales; 5% on medical cannabis sales; 2% on manufacturing, cultivation, or other commercialization; and 1% on testing, research, or transportation.
A “no” vote opposes applying the city’s tax on cannabis businesses to unlicensed cannabis businesses.

RESULTS: Measure CB has a strong lead in early results. 

San Benito County (Unincorporated Area) – Measure D, Marijuana Business Tax Increase Measure
A “yes” vote supports changing the county’s cannabis cultivation tax in unincorporated areas from a per-square-foot rate to a per-acre rate, with the cultivation tax set within a range of $1,000 to $10,000 per acre.
A “no” vote opposes changing the county’s cannabis cultivation tax in unincorporated areas from a per-square-foot rate to a per-acre rate.

RESULTS: Nearly 68%, or 2,009 voters have voted “yes” to the measure. 

UPDATE 5/19/26 : The DCC has issued a Notice of Rulemaking to allow for existing licensees who hold a license with both a medicinal and Adult-Use designation to be issued separate Medicinal and Adult-Use licenses.

Acting Attorney General Todd Blanche has signed an order immediately placing both “FDA-approved drug products containing marijuana, and medicinal marijuana products subject to a qualifying state-issued license” in Schedule III. The action is taken “under his authority to reschedule drugs to carry out the United States’ obligations under the Single Convention on Narcotic Drugs,” according to a press release from DOJ. “This action recognizes the longstanding regulation of medical marijuana by state governments and the need for a common-sense approach to this reality,” the release states.

The order states:

“State medical marijuana regulatory systems have matured significantly since California first authorized medical use in 1996, and today the vast majority of States maintain comprehensive licensing frameworks governing cultivation, processing, distribution, and dispensing of marijuana for medical purposes. These state regimes have developed robust infrastructure for preventing diversion, ensuring product safety, maintaining records, and conducting facility inspections—functions that fulfill the objectives of federal registration and recordkeeping requirements. The Attorney General has reviewed the operation of these state systems and finds that, taken as a whole, they demonstrate a sustained capacity to achieve the public-interest objectives that underlie the CSA’s registration framework, including protecting public health and safety and preventing the diversion of controlled substances into illicit channels.”

“The Acting Attorney General further notes that, as a consequence of this rule, state licensees will no longer be subject to the deduction disallowance imposed by Section 280E of the Internal Revenue Code, which applies only to businesses engaged in trafficking in controlled substances… in a schedule I or II…qualifying state licensees should consult with tax counsel regarding the applicability of Section 280E to their specific circumstances.”

Hearings Set for Broader Rescheduling

In addition, DOJ announced “procedural updates to expedite the ongoing rulemaking process required to fully remove marijuana from Schedule I and place it into Schedule III under the Controlled Substances Act.”

According to Marijuana Moment, DOJ is moving to end a prior administrative hearing process on the rescheduling proposal that stalled near the end of the Biden administration amid litigation from pro-reform parties that alleged improper agency communications and witness selection decisions. The DOJ release states that DEA is “terminating those proceedings in order to move more efficiently toward the completion of marijuana’s complete redesignation.”

Beginning on June 29, there will be a new expedited administrative hearing process to consider the broader rescheduling of marijuana from Schedule I to Schedule III. Terry Cole, administrator of the Drug Enforcement Administration (DEA), said that the agency is “expeditiously moving forward with the administrative hearing process—bringing consistency and oversight to an area that has lacked both.” The hearing process will conclude no later than July 15, 2026, according to the notice that Blanche signed. It would then have to be published in the Federal Register for 30-90 days before it could take effect.

DEA Involvement to Satisfy Treaty Obligations?

The proposed amendments establish “a new registration pathway for state-licensed medical marijuana entities seeking federal DEA registration as manufacturers, distributors, and/or dispensers.” The regulation creates an expedited review process under which the Administrator must take action in 60 days.

The order states, “Pursuant to a 2018 OLC opinion, DEA must buy marijuana crops from registered manufacturers, be the seller of that marijuana to any eligible registered purchaser, and establish prices for such purchase and sale. Marijuana growers must pay DEA an administrative fee for such transactions. These actions are necessary for the United States to meet its obligations under articles 23 and 28 of the Single Convention.”

Looking Forward

Rescheduling from Schedule I (“no accepted medical use”) to Schedule III won’t federally legalize cannabis, but it could remove barriers to research as well as offer tax benefits to cannabis businesses. And it could have other benefits for patients in the areas housing, employment, and medical care, where discrimination against medical cannabis users continues.

Cal NORML will be closely monitoring the effect of this announcement and subsequent actions on state laws and regulations, and exploring possible future legislation and regulation to advance cannabis consumers’ rights. Join us at the Cannabis Unity Coalition Lobby Week May 12 – 14 in DC to meet with Congressmembers and their staffs on reforms at the national level, including pending bills to allow VA doctors to recommend cannabis, and more.

NORML first sued the DEA to reschedule marijuana in 1972. Read National NORML’s release: Justice Department Moves to Federally Reschedule State-Approved Medical Cannabis Products.

This is a developing story. Check back for updates. 

Also see:

VIDEO: Cannabis Rescheduling Update 2026: Schedule III Medical Marijuana, June 29 Hearing & Litigation
With NORML, MPP, and attorneys from Vicente LLP

California M-License Operators in a Bifurcated Federal World: A Legal Deep Dive on DOJ’s April 2026 Rescheduling Order
From Cal NORML board member and attorney Shay Gilmore

DEA Medical Marijuana Dispensary Portal Opening April 29, Annual Application Fee Set at $794
The DEA registration created by the order covers M-license activity only. Nothing in the order requires exclusive M-only operations, and nothing in it prohibits the same entity from simultaneously holding an A-license for adult-use activity at the same premises.

DEA Schedule III Registration Asks Cannabis Businesses to Admit to Drug Trafficking
Attorneys on Cal NORML Legal Committee will be weighing in on this

California Cannabis Regulators Streamline Medical License Designation Process Following Federal Rescheduling
The DCC said it has requested a meeting with the DEA team handling the federal implementation plan. However, according to the department, the DEA has indicated that it will release information publicly and all at once, rather than through state-specific briefings.

CANNRA Issues Overview of DOJ Order on Marijuana Rescheduling
CANNRA’s analysis states explicitly that the 280E tax burden is removed for state medical marijuana licensed businesses regardless of whether they pursue a DEA license. Also, that state authorized medical marijuana certifications or similar documents will be sufficient to permit dispensing of medical marijuana to users, provided they have the user’s name and address, are dated and signed, and include the name of the issuing practitioner and their address and state license number.

Treasury Department Says Tax Guidance Is Forthcoming for State-Licensed Medical Cannabis Businesses

BTA Cannabis CPA Tax – Position Statement on Cannabis Rescheduling and 280E Tax Relief

Federal Marijuana Rescheduling Will End Discrimination In Housing, Healthcare And Employment For Medical Cannabis Patients (Op-Ed)

Join Cal NORML through 4/30 with a discounted $42 Gold Membership and get a free thank-you gift: Our popular gold lapel pin in the shape of a pot leaf. It’s a great way to represent your support for Cal NORML and cannabis!

As another special offer, Cal NORML Business or Legal Committee Memberships, usually $500/year, are discounted to $420 through the end of the month.  Get your discounted membership today!

Introduction: Returning To India With Purpose

 When I first visited India in 1981, cannabis cultivation was still legal in certain regions. During that trip, I photographed a large, government-regulated ganja farm—an experience that left a lasting impression. The plants were grown openly, harvested responsibly, and taxed by the state.

Today, cultivation is no longer legal anywhere in India. Yet cannabis remains widely available throughout the country—typically of poor quality, harvested prematurely before flowering, and sold through unregulated channels. Prohibition has not eliminated cannabis use; it has simply ensured inferior products while generating no public benefit.

On earlier trips, I came to India as a tourist. This time, I returned with a purpose: to support the growing re-legalization movement and to help spark what civil rights leader John Lewis once called “good trouble.” At a recent meeting with activists, I was asked to outline clear reasons why India should re-legalize ganja. That outline is now circulating throughout the country.

What follows is a practical, historically grounded case for reform.

Cannabis And India — A Deep Historical Relationship

Cannabis is not foreign to India. The plant originated in Central and South Asia and has grown naturally in the Himalayan foothills for millions of years. Humans have used cannabis on the subcontinent for at least 10,000 years—for food, fiber, medicine, ritual, and pleasure.

For centuries, ganja and charas were cultivated, traded, regulated, and taxed. Cannabis use was woven into daily life, Ayurvedic medicine, and religious practice long before modern drug laws existed.

Why India’s Cannabis Laws Are Ineffective

Cannabis Is Widely Available Despite Prohibition

After nearly four decades of prohibition, ganja and charas remain easy to obtain across India. Criminalization has failed to reduce demand or supply. Instead, it has pushed cannabis into an unregulated underground market.

Poor Quality And Premature Harvesting

Because cultivation is illegal, growers often harvest plants early to reduce risk. The result is cannabis of poor quality, low potency, and inconsistent effects. Prohibition has degraded the plant itself.

Enforcement Encourages Corruption

When a widely used plant is illegal, enforcement becomes selective. This fosters bribery and corruption while diverting law enforcement resources away from serious crimes. Over time, the law loses credibility.

Public Health And Safety Considerations

In legal cannabis markets, products are tested for pesticides, heavy metals, and microbial contamination. In India’s unregulated market, consumers have no such protections.

Prohibition also produces unintended consequences. When cannabis becomes scarce due to enforcement actions, some users turn to alcohol—an intoxicant associated with greater social and health harms.

Regulation allows risk to be managed responsibly.

Economic And Scientific Opportunities

Lost Tax Revenue And Rural Opportunity

India forfeits significant revenue by keeping cannabis illegal. A regulated market could generate tax income, create agricultural jobs, and support rural economies—especially in regions where cannabis grows naturally.

Protecting India’s Landrace Cannabis Genetics

India is home to unique landrace cannabis varieties—genetically distinct plants shaped by geography, climate, and centuries of open pollination. These landraces contain rare cannabinoid and terpene profiles with potential medical and scientific value.

Under prohibition, these genetics are neither studied nor protected—and are often exported illegally with no benefit to India.

Barriers To Medical Research

Indian pharmaceutical companies are currently restricted to immature cannabis plants with low cannabinoid content. Legal access to mature flowers would enable meaningful research and allow India to compete globally in cannabis-based medicine.

Cultural And Religious Significance

Cannabis has long played a role in Indian religious traditions, particularly in connection with Shiva and festivals such as Holi and Shivaratri. While bhang remains legal, the continued prohibition of ganja forces traditional users into unsafe, unregulated markets.

Re-legalization would acknowledge cultural reality rather than deny it.

What Sensible Cannabis Regulation Could Look Like

A practical regulatory framework could include:

• Licensed cultivation and distribution
• Mandatory testing and labeling
• Age-restricted sales
• Taxation to support public health and education
• Protection for traditional and religious use
• Inclusion of small farmers and cooperatives

This is not radical policy—it is responsible governance.

Ganja In India — A Historical Record

Ganja in India is a photographic and historical record of a legal cannabis farm during my 1981 visit. At that time, ganja was cultivated openly, regulated by the government, and taxed.

The book documents a moment in Indian history that is now largely forgotten—a reminder that legalization is not a new idea, but a return to a system that once worked.

Conclusion — A Return To Reason

India’s cannabis prohibition has failed to eliminate use, protect public health, or reduce harm. Instead, it has produced inferior products, empowered illegal markets, and erased economic opportunity.

Re-legalizing ganja would not be a leap into the unknown. It would be a return to regulation, tradition, and common sense—guided by history, science, and lived experience.

FAQ — Cannabis Legalization In India

Is Cannabis Completely Illegal In India?

Cannabis flowers and resin are illegal under the NDPS Act, but bhang made from leaves remains legal in many states.

Why Was Ganja Banned In India?

India criminalized ganja primarily due to international pressure following the 1961 UN Single Convention on Narcotic Drugs.

What Are Landrace Cannabis Varieties?

Landraces are genetically distinct cannabis plants that evolved naturally in specific regions over centuries. India’s Himalayan landraces are among the most unique in the world.

Could Legalization Benefit India’s Economy?

Yes. Regulation could generate tax revenue, support rural agriculture, reduce enforcement costs, and enable scientific research.

Did India Ever Regulate Cannabis Legally?

Yes. Cannabis cultivation was legal and taxed in parts of India until the mid-1980s, including during Ed Rosenthal’s 1981 visit.

Ed Rosenthal’s expert advice has advanced marijuana cultivation and know-how for decades, helping gardeners achieve his strategy of over-growing the government to propel marijuana normalization. At the same time, he was active in the legalization movement. Now he is interested in classic varieties, breeding strategies, and landrace research. His books have sold over 1 million copies, including his latest grow guide “Cannabis Grower’s Handbook.” Ed’s warning: “Marijuana may not be addictive, but growing it is.”

EdRosenthal.com is a proud member of California NORML. See their Cannabis Marketplace listing here. 

Join Cal NORML now through the end of April with a discounted $42 Gold Membership and get a free thank-you gift: Our popular gold lapel pin in the shape of a pot leaf (shown). It’s a great way to represent your support for Cal NORML and cannabis!

Join Cal NORML through 4/30 and we will send your gift to you by mail. Membership renewals qualify; email here if you are unsure of your membership status. Members receive our printed newsletter and discounts on events and items throughout the year.

As another special offer, Cal NORML Business or Legal Committee Memberships, usually $500/year, are discounted to $420 through the end of the month.  Get your discounted membership today!

Business memberships include a listing in our online cannabis marketplace and guest blog post on the high-authority CaNORML.org, plus other great promotional benefits and discounts. Contact kharla@canorml.org, 707-337-9747 for more info. Sign up by 4/30 for this $80 discount.

Cal NORML is completely funded by personal and business memberships and donations from within California. We are the only organization advocating for the rights of all cannabis consumers in our state.

Read more about Cal NORML and Our 50 Years of Progress.

LAST UPDATED 6/4/2026

Cal NORML is tracking the following and has reached out to authors’ offices and stakeholders.

AB 1826 (Lackey) To improve due process around the recall, embargo, and destruction of cannabis products. Sponsored by CCIA. Passed Assembly; ordered to Senate. Cal NORML has joined a sign-on letter in support of this bill.

AB 1965 (Sharp-Collins) Cannabis: testing: quality assurance. Passed Assembly. Heading for Senate Com. on B. P. and E.D. Cal NORML has sent a letter in support of this bill.

AB-2249 (Irwin) Cannabis: labels, packaging and manufacturing. Passed Assembly. Heading to Senate Com. on B. P. and E.D. Set FOR Hearing ON 08-JUN-26 10:30 a.m.
The Dept. of Cannabis Control (DCC) estimates annual costs of approximately $3 million to $4 million from the Cannabis Control Fund, explaining the majority of costs are associated with implementing a pre-approval process for cannabis labels and the expansion of prohibited imagery in advertising and marketing. A smaller portion of estimated costs are attributable to expansions of prohibited packaging design content.

AB-2532 (Irwin) Cannabis: labels, packaging and manufacturing (beverages). Passed Assembly. Referred to Senate Com. on B. P. and E.D. Set FOR Hearing ON 08-JUN-26 10:30 a.m.
An amendment added on 5/7 says, “If the cannabis product is a cannabis beverage containing more than one serving, the bill would require a consumer to be offered, at the time of purchase and at no additional charge, a measuring instrument or measuring device that allows the consumer to measure a single serving for consumption.”
Cal NORML has taken a neutral position on this bill following the news that amendments have been worked out with the cannabis industry removing the 10 mg cap on beverages and requiring industry-wide precision dosing and product identification features on all multi-serving cannabis beverages, warning label standards, child-resistant container requirements, while prohibiting single-serve marketing and supporting a funded, statewide campaign on responsible, informed cannabis beverage consumption, potentially modeled on alcohol responsibility campaigns. We will be continuing to follow this bill as amendments are published. Thanks to all who have taken our Beverage Safety survey; you can continue to provide input there. 

AB 2250 (Aguiar-Curry) Modify AB 8 to exclude CBN from the definition of cannabis concentrate. Passed Assembly. Referred to Senate Coms. on B. P. and E.D. and REV. and TAX. Set FOR Hearing ON 15-JUN-26 10:30 a.m.

AB 2506 (Hart) Cannabis: tribal-state agreements. Passed Assembly.
Would allow the Governor to enter into agreements on behalf of tribes with CA licensees, other states authorizing medicinal or adult-use commercial cannabis activity, and foreign licensees, subject to “federal approval or toleration” of cross-border commerce. The amended language mimics SB 1326 (Caballero, 2021/22) which authorizes Gubernatorial agreements between other states and countries, should the US DOJ issue an opinion “allowing or tolerating interstate transfer of cannabis.”

AB 2537 (Chen) Cannabis Enforcement Accountability and Public Health Prioritization Act of 2026. Passed Assembly.
Would “require the DCC to prioritize its enforcement of MAUCRSA in a manner consistent with a risk-based enforcement framework that focuses on material threats while applying less intensive and less punitive measures on minor technical or administrative violations by licensees.” Sponsored by CaCOA.

AB 2697 (Pellerin) Cannabis drive-throughs. Passed Assembly. Referred to Com. on B. P. and E.D. in Senate. Set FOR Hearing ON 08-JUN-26 10:30 a.m.
Would authorize a local jurisdiction to allow a licensed cannabis retailer to conduct sales or deliveries at a drive-through, pass-out window, or slide-out tray, if the sales and deliveries are made through a fixed-pane security window with a security drawer.  TAKE ACTION: Write to your California Senator in support of AB 2697.

AB 2667 (Hadwick) Vape products: household hazardous waste: advertising. Passed Assembly.
Would allow authorize hazardous waste collection facilities to mechanically disassemble vape pens and devices, and prohibit nicotine or cannabis vapes using branding to appeal to minors, packaged to conceal the nature of their use, or including interactive videogame capabilities. 

AB 1884 (Hadwick/Sharp-Collins) Interscholastic athletics: drug testing: suspensions: nicotine use. Passed Assembly Committee on Arts, Entertainment, Sports, & Tourism; hearing in Education committee cancelled at request of the author.
This bill has been amended to allow schools with drug testing programs to also test for nicotine, limit it to athletics, and require diversion instead of banning participation for a positive drug test. We will continue to watch.  

SB-1272 (Menjivar) – Local ordinances: administrative fines or penalties. Passed Senate. Referred to Assembly Com. on L. GOV.

BILLS NOT ADVANCING:

AB-2420 (Caloza) Cannabis: donations: seniors. Authorizes cannabis retailers to donate cannabis or cannabis products to persons 65 years of age and older. 14-APR-26 hearing in Asm. B & P cancelled at request of author.  

AB-2617 (Schiavo) NO LONGER A CANNABIS BILL. It’s now the Protecting Kids from Online Gambling Act.

AB-2246 (Wicks) NO LONGER A CANNABIS BILL. It’s now the Youth Social Media Protection Act: report.

Winning a cannabis license can feel like the hardest part: months (sometimes years) of applications, capital outlays, community positioning, and regulatory scrutiny distilled into a single approval. In limited-license states, that approval is scarce by design. It carries value the moment it’s issued.

But a license is not yet a business. It’s a permission slip with a timeline, and the next choice you make (build it out or sell it now) will largely determine whether you capture a quick premium or create a larger, more durable asset.

At Green Life Business Group®, Inc., we work with operators and investors nationwide who reach this fork in the road. The “right” answer isn’t universal, and it’s rarely ideological. It usually comes down to one decisive factor: capitalization, paired with a clear-eyed strategy.

When to Build-Out

If you have meaningful capital reserves and access to funding and you can withstand the time it takes to construct, clear inspections, secure final approvals, and ramp operations—building before selling can expand what a buyer is willing to pay. In this industry, buyers pay up for reduced execution risk. A license on paper is potential; a compliant facility with systems, staffing, and real operating traction is certainty. When the heavy lifting is done: buildout, municipal signoffs, regulatory inspections, early hiring, and initial revenue an acquirer is no longer buying a plan. They’re buying a functioning enterprise with far fewer unknowns.

That premium can be substantial, but it’s not “free money.” The build-first path asks you to carry the business through its most vulnerable phase, when delays are common, cash burn is steady, and a single compliance miss can set the timeline back. In many jurisdictions, the practical runway from approval to stable operations can stretch from six months to eighteen, depending on local processes, construction realities, and how quickly your team can operationalize compliance. The operational burden is also real: cannabis is heavily regulated, and early-stage execution requires experience, discipline, and a willingness to manage details most industries never face.

For well-capitalized license holders who want to maximize long-term value, that effort can be worth it. If your aim is to build an asset that commands a higher multiple—because it is already operating, already compliant, and already de-risked—then building out can be the strategic move.

When to Simply Sell

The opposite strategy can be just as rational (and sometimes more profitable) when the goal is speed, liquidity, and risk reduction. If you prefer to avoid construction exposure, permitting drag, cost overruns, staffing complexity, and the day-to-day grind of compliance, selling the license prior to buildout may be the smarter business decision. In that scenario, you’re monetizing scarcity and the work you’ve already completed: the approval itself, the credibility required to win it, and the buyer’s urgency to enter the market. Instead of spending months converting the license into an operating company, you transfer the opportunity to someone else who has the balance sheet and operating appetite to finish the job.

This approach limits downside in a market where timing matters. Cannabis valuations are not static. They rise and fall with licensing scarcity, competitive intensity, pricing conditions, and capital availability. A build that looks sensible on day one can become far less attractive if the market softens while you’re mid-construction, or if new entrants flood the category and compress margins. Selling earlier can protect you from that cycle—and from the risk of becoming a forced seller if timelines slip and reserves thin out.

There’s also a market-timing layer that many license holders underestimate. If you’re pursuing multiple applications across states with an “asset strategy” (winning approvals with the intent to monetize them) the highest premiums often appear in newly legalized or newly regulated markets. Early licenses can trade at outsized values when supply is limited and demand is urgent, particularly from groups racing to establish footprint and brand presence. Over time, that premium often narrows. More licenses enter the market, competition intensifies, pricing pressure builds, and capital becomes more selective. Distressed operators begin to surface, and “last year’s multiples” stop applying. In other words, the value of a license can be as much about when you act as what you won.

So how do you decide?

Start by asking the questions most people avoid. Do you have the capital to build properly (not minimally) without cutting corners that later undermine inspections or operations? Can you carry twelve months or more without meaningful revenue if approvals take longer than expected? Do you actually want to operate a cannabis business, with all the compliance and execution that entails, or do you want to exit while the asset is still simple and scarce? And what does buyer demand look like in your specific state and license category right now not in theory, but in the deals actually closing?

When you answer those honestly, the strategy usually becomes clear. If you’re well-capitalized and positioned to execute, converting a license into a compliant, operating business can materially increase what you can command in an exit because you’re selling certainty and performance. If you want a lower-risk, faster liquidity event, selling pre-buildout may be the most strategic move. And if you’re playing across multiple emerging markets, early-cycle timing can often generate the highest returns: before competitive saturation and valuation compression take hold.

At Green Life Business Group®, Inc., we help license holders evaluate market cycles, buyer demand, capitalization plans, and execution timelines to determine which path is most likely to maximize outcomes. Winning the license was the milestone. Now the work is making sure you extract its full value.

This article is for informational purposes only and does not constitute legal, tax, or investment advice. Regulations and transfer rules vary by jurisdiction.

Green Life Business Group has SOLD over 400 Cannabis Licenses/Businesses all across the Country. Green Life Business Group currently has over 200 Active exclusive cannabis businesses or licenses on the Market Today.

Green Life Business Group is pleased to support California NORML as a Business Member — learn more about their services in their Cannabis Marketplace listing.