WASHINGTON – Americans for Safe Access (ASA)released a new state guidance memorandum to help governors, state legislators, cannabis regulators, health departments, attorneys general, and state agency leaders respond to Acting Attorney General Todd Blanche’s medical-cannabis rescheduling order, AG Order No. 6754-2026. State Preparedness for Federal Cannabis Regulation & Enforcement: Part 1, State Actions Needed to Preserve & Protect Patient Access Before the June 26, 2026 DEA Registration Deadline, is available for download on ASA’s website.
AG Order No. 6754-2026 created a new federal pathway for certain state-licensed medical cannabis activity to seek DEA registration and come into compliance with federal law. The order is a historic opening for patients, caregivers, clinicians, and advocates who have spent decades fighting for federal recognition of cannabis medicines. However, the order does not create a national medical cannabis program, does not legalize adult-use cannabis, and does not automatically protect all state-licensed cannabis activity.
The memorandum urges states to treat the June 26, 2026, DEA registration deadline as both a patient-access deadline and a business-compliance deadline. It outlines emergency actions states can take now, including:
- Supporting DEA registration readiness for existing medical cannabis licensees.
- Creating state verification processes for medical-only activity.
- Rebuilding patient enrollment and education.
- Preserving or restoring medical-only supply chains, especially in adult-use and dual-market states.
- Providing licensee education on the federal medical cannabis registration opportunity.
- Clearing cannabis conviction records that may block patients, workers, caregivers, owners, or legacy operators from participating in the medical cannabis framework.
“States cannot control DEA’s final registration decisions, but they can control whether patients and businesses are ready for this federal transition,” said ASA founder Steph Sherer. “States can remove barriers, improve registration readiness, and better position medical cannabis businesses to document state-authorized medical activity for federal review. That preparation has to begin now.”
The guidance also warns that many patients currently obtain cannabis medicines through adult-use markets or hemp-derived products that may not be protected under the new federal framework. ASA notes that adult-use cannabis has never had the same federal protection as state medical cannabis programs under the CJS medical cannabis appropriations rider (also called the Rohrabacher-Farr amendment), and that federal hemp law changes may further disrupt access to full-spectrum cannabinoid products.
ASA’s memorandum includes recommendations by state program type, including adult-use and dual-market states; medical-only and emerging medical states; and low-THC, CBD-only, limited-program, and no-program states. It also includes model emergency governor actions, model emergency legislation, patient and licensee notification language, background on medical cannabis access in the United States, and a breakdown of AG Order No. 6754-2026.
“States do not need to resolve every federal implementation question before acting,” Sherer continued. “They can take immediate steps to protect patients by rebuilding enrollment, preserving medical-only supply, documenting state-authorized medical activity, and helping eligible businesses prepare for DEA registration.”
Cannabis Businesses & Professionals United for National Medical Cannabis (UNMC) also welcomed the guidance.
“UNBC applauds the vision, urgency, and patient-centered leadership reflected in this framework document,” said UNMC founding member and California dispensary owner Kimberly Cargile. “This document recognizes what many state-licensed cannabis operators have understood for years: Patients deserve safe, regulated, medically focused access pathways that are protected under both state and federal law. We support thoughtful implementation that preserves patient access, strengthens medical cannabis infrastructure, protects existing operators acting in good faith, and creates realistic transition pathways for dual-market states.”
This is the first memorandum in a two-part state guidance series. Part 1 focuses on urgent state actions needed before the June 26 DEA registration deadline, including clearly delineated state medical-only supply chains, automatic relief for cannabis conviction records through expungement and sealing, stakeholder education, and, if necessary, patient enrollment plans.
Part 2 will address federal alignment and access-continuity issues that will need to be addressed in 2026, but not by June 26. These include product safety policies, revisions to track-and-trace procedures, civil rights implementation, tax policy alignment, interstate medical access, hemp transition planning, firearm-related policy updates, and alignment of international treaties with state statutes.
About Americans for Safe Access
Founded in 2002, Americans for Safe Access is a national organization of patients, medical professionals, scientists, providers, and concerned citizens promoting safe and legal access to cannabis for therapeutic use and research.
