UC Comment Letters

This comment letter responds to the Drug Enforcement Agency (DEA)'s Notice of Proposed Rulemaking "Schedules of Controlled Substances: Rescheduling of Marijuana", published in the Federal Register on May 21, 2024. UC supports DEA’s proposal to move marijuana, marijuana extracts, and naturally derived delta-9-THC from schedule I to schedule III as a step toward reducing research barriers, but argues that rescheduling alone will not let researchers study the real-world cannabis products available in state-regulated markets. UC urges DEA to allow universities to access state-legal cannabis products and fresh plant material for research, classify naturally and synthetically derived delta-9-THC consistently, assess THC isomers and derivatives through the eight-factor analysis, and issue updated guidance explaining the regulatory requirements for cannabis research.