Colorado Leads Submits Public Comment in Support of Federal Rescheduling
Colorado Leads submitted a public comment in support of the Department of Justice’s proposed rule to transfer marijuana from schedule I to schedule III of the Controlled Substances Act.
As the leading marijuana business association in the nation’s longest- running state-regulated marijuana market, we are uniquely positioned to help inform DOJ’s analysis. We also felt it was imperative that we participate in the rescheduling process since it will directly and substantially impact our businesses, our industry as a whole, and our state and local communities.
Our comment begins by explaining how Colorado’s experience and public policies support HHS’s conclusions that:
- marijuana has a currently accepted medical use in treatment; and
- marijuana has less potential for abuse than substances in schedules I and II, as well as alcohol, which is an unscheduled substance.
DOJ specifically solicited comments on the economic impact of the proposed rule, recognizing it may significantly affect a substantial number of small entities, including state-regulated marijuana businesses that would no longer be subject to section 280E of the Internal Revenue Code. It could also impact entities that engage in marijuana research, which may be subject to different protocols set by the DEA.
Colorado Leads surveyed its membership regarding the impact they expect it could have on their businesses, and we offered some of the insights that were shared, along with our analysis of the impact rescheduling could have on our industry, state, and local communities. We also reached out to leaders of Colorado’s marijuana research community to get their thoughts.
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