On April 23, 2026, the U.S. Department of Justice and the Drug Enforcement Administration (DEA) announced an order to reschedule FDA-approved drug products containing marijuana and marijuana covered by a state medical license to Schedule III of the federal Controlled Substances Act. The effective date of the final published rule for this order is April 28, 2026. This action also establishes an expedited registration process for entities holding state medical marijuana licenses, enabling them to engage in the manufacture, distribution, and/or dispensing of marijuana for medical purposes under federal law. Along with that was the initiation of an expedited administrative hearing process to consider the broader rescheduling of marijuana from Schedule I to Schedule III.
These moves come after President Donald Trump issued an executive order in December 2025 directing the Attorney General to take “all necessary steps” to complete the rulemaking process to reschedule marijuana to Schedule III of the Controlled Substances Act. A prior rulemaking was proposed in 2024 under President Joe Biden’s administration.
Defining Federal Classifications
The transfer of these drugs to Schedule III means that federally they are classified as:
- Having a lower potential for abuse (when compared to schedules I and II drugs),
- Having an accepted medical use in treatment in the U.S., and
- May lead to moderate or low physical dependence or high psychological dependence.
By contrast, a federal Schedule I classification defines drugs as:
- Having a high potential for abuse,
- Having no accepted medical use in treatment in the United States, and
- Lacking accepted safety for use under medical supervision.
It is important to note that this action did not “legalize” marijuana across the country. Non-FDA approved marijuana products and those not subject to a qualifying state-issued license are still considered Schedule I under federal law, pending the noted expedited administrative hearing process, which will take at least a few months to play out.
Rescheduling Implications
The federal rescheduling of marijuana, per this limited order and more broadly in the future, may cause a cascading effect on the states and the industry by expanding the legal use of marijuana medically. As a Schedule I drug, several states previously prohibited its use (and at times its workers’ compensation reimbursement.)
Shifts in the broader marketplace may include:
- Expanded pharmaceutical research and development
- Greater involvement by traditional pharmaceutical manufacturers
- Normalization of DEA registration and compliance based on federal Schedule III requirements
Actions in the workers’ compensation space may include:
- Potential influence on prior and future judicial and administrative interpretations that relied on federal prohibitions
- Pressure on workers’ compensation systems to revisit compensability exclusions, with a shift in arguments from federal illegality to medical necessity
- More options for employers reimbursing for medical marijuana
Considering Treatment Guidelines
From a clinical perspective, treatment guidelines commonly adopted by several states characterize marijuana as generally not recommended for pain. The Official Disability Guidelines (ODG) state that cannabinoids are not recommended as a first- or second-line option for pain and have shown to have significant harmful effects on the central nervous system, cognitive function, and mental health, particularly with higher doses. According to the American College of Occupational and Environmental Medicine (ACOEM) evidence-based guidelines, cannabinoids are not recommended for the treatment of acute or chronic pain arising from conditions with a reasonable probability of being work related.
In addition, ACOEM does not recommend cannabinoid use among safety critical workers due to concerns regarding impairment and workplace safety. Cannabis use is associated with adverse cognitive, psychomotor, psychiatric, and physiologic effects—including impaired attention, memory, judgment, reaction time, coordination, sedation, and abuse potential—which pose significant safety risks, particularly in occupational and safety‑sensitive work settings.
Following Developments
While this federal order is now in effect, there is still much to play out, both legally and practically at the federal and state levels. The noted expedited hearing process to consider the broader federal rescheduling of marijuana from Schedule I to Schedule III commences on June 29, 2026. Individual states will react to these federal actions in various ways. The MyMatrixx Clinical and Regulatory Affairs teams will be following these developments. For more clinical updates, visit our Pharma Watch webpage. For more on legislative and regulatory developments, visit our Statehouse Watch webpage.
Nothing in this content should be considered legal or medical advice nor should it be construed as such.