The Medical Marijuana Caregivers of Maine Trade Association would like to provide members with a brief update regarding recent federal action by the U.S. Department of Justice (DOJ) and Drug Enforcement Administration (DEA) concerning the rescheduling of certain marijuana-related substances.

The federal government has initiated a shift to place certain marijuana products into Schedule III of the Controlled Substances Act, recognizing potential medical use and a lower level of risk compared to Schedule I substances. This represents a significant policy change at the federal level and may signal the beginning of a longer-term transition toward a more structured federal framework for medical cannabis.

Current Understanding:

At this time, it is important to emphasize:

There is currently no clear operational guidance from the DEA regarding how existing state-licensed medical cannabis providers, including Maine caregivers, will be integrated into or affected by this new framework.

The federal system appears to be developing as a separate and more highly regulated pathway, distinct from existing state programs.

Maine’s medical cannabis program remains in place and unchanged at this time, and caregivers may continue operating under current state law.

While a federal registration pathway is being introduced, many critical details—including supply chain requirements, compliance expectations, and practical implementation—remain unclear.

Regarding DEA Registration:

At this stage, the Association’s position is as follows:

As presented by the federal government, aspects of this new framework may suggest that federal registration could become necessary in certain contexts in the future; however, it is not clearly defined at this time whether this will be mandatory for existing state-licensed caregivers.

The DEA has provided an early registration window of approximately 60 days, currently understood to run through June 22, for those considering initial application.

It remains unclear what advantages, obligations, or long-term implications are associated with applying within this early window versus applying at a later time.

We do not yet have clarity on how federal requirements may be implemented alongside Maine’s current medical cannabis program.

It is also unclear how the State of Maine will respond or adapt to these federal changes, or whether additional state-level requirements may be introduced.

Given these uncertainties:

The Association is not encouraging or discouraging members to apply for a DEA registration at this time.

The decision to apply should be made individually, based on each caregiver’s business model, risk tolerance, and consultation with qualified professionals.

Members are encouraged to:

Stay informed

Seek legal and financial guidance

Avoid making rushed decisions based on incomplete or evolving information

What the Association Is Doing.

The Association is actively consulting with legal experts, regulatory professionals, and industry leaders

Monitoring developments at both the federal and state levels

Working to ensure that Maine caregivers remain informed, represented, and prepared

Upcoming Networking Meeting:

At this month’s networking meeting, we are pleased to welcome Guest Speaker, Attorney Jill Cohen.

Attorney Cohen will provide her legal perspective on:

Current federal developments

Potential implications for Maine caregivers

Considerations surrounding DEA registration

What to watch for as this situation evolves

This is an evolving and complex situation. While federal recognition of medical cannabis represents an important shift, the practical impact on Maine caregivers is still uncertain.

At this time, caregivers should continue operating in compliance with Maine law while remaining attentive to new developments. The Association will continue to provide updates as clearer guidance becomes available.

LD 1847 a bill proposing mandatory testing and tracking for Maine’s medical cannabis program, is currently in a contested phase after moving through the Legislature with multiple competing versions. The Hickman amendment, introduced by Craig Hickman, was not brought forward and never voted in the House. Instead, the House adopted the Boyer “Ought Not to Pass” position, rejecting the bill. In the Senate, the Hickman amendment was the only version taken up and passed; however, it was immediately tabled by Sen. Hickman for further amendment. The amendment was not returned for a vote before adjournment. As a result, it was never sent back to the House for reconsideration.

Importantly, the original version of LD 1847 was met with widespread opposition from across Maine’s medical cannabis community. A broad coalition of stakeholders, including caregivers, dispensaries, patients, and members of the adult-use sector, came together in a unified effort to push back on the bill as initially written. The Medical Marijuana Caregivers of Maine trade association was one of many voices involved, joining alongside industry leaders and advocates who worked collectively to raise concerns and educate policymakers.

This unified response was especially visible during a State House protest rally organized by Lizzy Hayes and Mark Barnett, which drew one of the largest turnouts the medical cannabis community has seen in recent years. The level of engagement throughout the legislative session demonstrated just how deeply Mainers care about protecting patient access and maintaining a system that has safely served patients since 2010. While there is shared support for ensuring clean, safe products and removing bad actors from the supply chain, the proposed mandatory testing framework was widely viewed as overregulation—introducing significant costs and barriers for providers and patients alike. Moving forward, stakeholders, including MMCM, are expected to continue working collaboratively to develop more balanced, practical solutions that reflect the needs and realities of Maine’s medical cannabis program.

The Veterans and Legal Affairs (VLA) Committee held a work session at the Maine Legislature to review LD 1365 and LD 1847.
The work session on LD 1365 concluded with an “Ought Not to Pass” vote by the committee. However, several committee members expressed interest in revisiting and potentially reworking the bill at a later date.
The committee received a significant volume of emails and phone calls from constituents, including patients, caregivers, and dispensary owners, expressing concerns—particularly regarding LD 1847.
Key concerns raised about LD 1847 included:
Mandated testing and tracking down to the milligram
A proposed standard dosage limit of 10 mg, with any product exceeding 10 mg requiring blister packaging
Additional labeling and warning requirements
A proposal to classify future rulemaking as routine technical, which would remove oversight from the VLA Committee — a change not supported by stakeholders
At times, discussion during the work session was heated, with visible disagreement among committee members. Representatives from the Office of Cannabis Policy (OCP) were present to provide testimony, answer questions, and offer their perspectives. Tensions remain elevated between OCP, industry stakeholders, and members of the legislative committee.
Toward the end of the work session, a group of stakeholders was asked to begin working collaboratively on alternative language related to testing and tracking requirements—language the industry could reasonably support. Ideas were shared among stakeholders and then discussed with Senator Jeff Timberlake and Senator Craig Hickman.
Stakeholders were instructed to draft proposed amendment language to be presented alongside amendments being prepared by the bill’s sponsor. These amendments will be reviewed together in a follow-up work group session next week to determine whether compromises can be reached. As a result, LD 1847 is expected to be substantially rewritten to reflect those discussions.
The deadline for this work is February 13, at which point additional details and outcomes are expected.

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