In this guide
- The rule in one paragraph
- Who counts as a trading partner
- What to collect from each partner
- Checking the timely applicant list
- Keeping the file
- After November 29
The rule in one paragraph
DEA’s timely applicant guidance (October 30, 2026) lets timely applicants keep operating under their state medical license while DEA reviews them, but only in dealings with other timely applicants and DEA registrants. Handling Schedule III medical marijuana with anyone else “could be potential grounds” for denying an application or revoking a registration. Timely applicants are expected to verify existing partners and have compliant supply chains by November 29, 2026.
Who counts as a trading partner
Anyone your Schedule III medical product moves to or from:
- Manufacturers and processors you buy from
- Distributors and transporters
- Other dispensaries you transfer product with
- Your destruction partner: the reverse distributor that takes expired, damaged, recalled and returned product
The last one is easy to miss. Unsellable product still leaves your inventory, so the business receiving it has to qualify too. DEA’s guidance includes a narrow exception for de minimis samples sent to state-licensed testing labs; it doesn’t extend to destruction.
What to collect from each partner
DEA lists these as the minimum due-diligence steps during the transition:
| Partner type | Collect |
|---|---|
| DEA registrant (e.g. a reverse distributor) | Copy of its DEA certificate of registration |
| Timely applicant dispensary | Its DEA “Marijuana Dispensary Information Submission” confirmation, with the document control number (DCN) verified on DEA’s site |
| Timely applicant manufacturer or distributor | Its DEA submission confirmation, with the DCN verified |
| Every partner | Copy of its relevant state license, with active status verified, and a record of the checks |
Checking the timely applicant list
DEA posts the timely applicant list on the Medical Marijuana Information page of its Diversion Control website. It’s a text file updated daily, listing each applicant’s state, business activity and control number. It has no business names, so match a partner by the DCN on its confirmation, and re-check before large transfers: the list changes as applicants are registered, withdraw or drop off.
Keeping the file
- One folder per partner: certificate or confirmation, state license, date checked, who checked.
- Note the source of each verification (DEA site, state license lookup) and the date.
- Under 21 CFR Part 1304, records of transactions with a timely applicant can use its DCN where a DEA number would normally go.
- Set a reminder to re-verify when a partner’s status changes from applicant to registrant.
After November 29
DEA keeps registering applicants in phases, so the file is never finished. Keep it current, and keep your disposal records tight: once you’re registered, expired and damaged product is controlled-substance inventory with its own recordkeeping and destruction rules.
Frequently asked questions
What is the November 29, 2026 deadline?
DEA's timely applicant guidance says timely applicants are expected to verify their existing trading partners and establish compliant supply chains no later than November 29, 2026.
Who can a timely applicant do business with?
Other timely applicants and DEA registrants that hold a registration to handle Schedule III medical marijuana. Dealing with anyone else could be grounds for denying the application.
What should I collect from a DEA registrant?
A copy of its DEA certificate of registration, a copy of its relevant state license with its active status verified, and a record of the checks you did.
What should I collect from another timely applicant?
For a dispenser: its Marijuana Dispensary Information Submission confirmation from DEA, with the document control number (DCN) verified on DEA's Diversion Control website. For a manufacturer or distributor: its DEA submission confirmation and verified DCN. Plus its state license, verified active.
Where is the timely applicant list?
DEA publishes it on the Medical Marijuana Information page of its Diversion Control website as a tab-delimited text file updated daily. It lists state, business activity and control number, not business names.
Can I still sell inventory I bought before the guidance?
Yes. DEA says timely dispensers and distributors may keep possessing, dispensing and distributing inventory acquired before the guidance was issued, even if it came from a business that doesn't qualify.
Keep reading
Controlled Substance Inventory & Recordkeeping: A DEA Guide
Initial and biennial inventories, perpetual logs, Form 222 records, the 2-year rule, and how documented disposal closes the loop.
Read guide →Controlled Substance DestructionDrug Diversion in Healthcare: Prevention, Detection & Disposal
Where diversion happens, how facilities prevent and detect it, and why documented non-retrievable destruction closes the loop.
Read guide →Controlled Substance DestructionHow to Properly Destroy Controlled Drugs: DEA Forms 222, 41 & COD Explained
When you need Form 222 vs. Form 41, what a Certificate of Destruction proves, and the steps that keep you audit-ready.
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