DEA opened federal registration for medical cannabis manufacturers, distributors, and testing labs on October 5. What it costs a USVI grower

October 8, 2026. The Drug Enforcement Administration’s Diversion Control Division opened federal registration on October 5 for three kinds of medical cannabis business: manufacturers, distributors, and analytical laboratories, per High Times and Marijuana Moment. All three apply on DEA Form 225, the standard application for anyone handling controlled substances in a non-practitioner capacity. It follows the dispensary registration window that ran after April’s rescheduling order.

Cultivation and manufacturing, which the Office of Cannabis Regulation licenses as two separate activities, both land in the costliest of the three new categories.

The fees are the old fees

The figures carried in the trade coverage are not a cannabis fee schedule. They are DEA’s standing registration fees by business activity, which have been in federal regulations for years:

• Manufacturing. Form 225 new, 225a renewal. $3,699. One year.
• Distributing. Form 225 new, 225a renewal. $1,850. One year.
• Chemical Analysis. Form 225 new, 225a renewal. $296. One year.
• Dispensing and retail pharmacy. Form 224 new, 224a renewal. $888. Three years.

The regulation’s label for the testing category is Chemical Analysis. The trade press calls it an analytical laboratory. It is the same category.

Marijuana Moment, which reported the launch on October 6, says applicants must state whether they will handle medical or recreational marijuana or both, provide their state licensing information, and specify whether they will work with marijuana, marijuana extract, or naturally derived delta-9 THC under a state medical license or in an FDA-approved product. The form also asks about the criminal and disciplinary history of the business and its principals. Businesses that already filed a Form 225 for Schedule III medical cannabis do not need to file again.

Why the manufacturer category is the one that matters here

DEA did not publish a separate cultivator category. Per High Times, the manufacturer registration may cover cultivation, production, processing, packaging, labeling, and transfers. The Controlled Substances Act’s own definition of manufacture includes “propagation,” language broad enough to reach a grow.

That would put a Virgin Islands commercial cultivator in the $3,699 category. The Cannabis Advisory Board set the territorial Tier 1 Commercial Cultivation License fee at $2,500 in October 2024, the lowest of the three plant-count tiers in the territorial fee schedule. The federal registration for the same activity costs $1,199 more than the territorial license to do it.

The one commercial grower in the territory holding a Certificate to Operate is a Tier 1 cultivator on St. Croix, announced at the September 24 board meeting. OCR approved eight manufacturing license applicants on a notice published August 4. If they registered, all of them would fall in the $3,699 category.

The testing side is cheaper by an order of magnitude. Every product sold in a licensed dispensary must first pass the St. Croix lab that went under construction in March, and the testing requirements guide sets out what has to be screened. A federal Chemical Analysis registration for that facility would cost $296 a year.

The distributor category has the least local use. Cannabis cannot legally move between St. Thomas, St. Croix, and St. John under territorial law, so each island’s supply chain stays on that island.

One license, two answers to the medical question

The form asks whether the applicant handles medical marijuana, recreational marijuana, or both. The Virgin Islands Cannabis Use Act does not issue separate licenses for the two. A cultivation license is one license covering medical, adult-use, and sacramental supply.

The proportions are lopsided. Executive Director Joanne Moorehead reported 40 active medical patients to the board on September 24, a count she said moves between 40 and 45 with renewals. Adult use is the rest of the market, and adult use was left in Schedule I by the April order, which Vibe High covered in the piece on the Justice Department’s final order. A registration keyed to medical activity reaches the smaller side of a license that does not divide.

Where territorial licenses fit

The April 28 rule defines a qualifying state medical marijuana license to include one issued by “a federal territorial entity,” so a Virgin Islands license is not excluded on geography. The open question is whether a license that covers medical and adult-use sales together counts as a license to operate “for medical purposes.” DEA has not addressed that for the territory, and OCR has not published guidance to licensees on federal registration.

A discrepancy on the dispensary form

Marijuana Moment reports that dispensaries which still want to register can now use the standard DEA Form 224, the specialized form having been available during an expedited window. High Times dates that window from April to June 26, 2026, with a six-month processing target and permission to keep operating under the state license while DEA reviewed.

DEA’s registration page, read on October 8, routes medical marijuana dispensary applicants to a dedicated Medical Marijuana Dispensary Registration Portal and lists Form 224M for both new and renewal dispensary applications. No Virgin Islands dispensary holds a Certificate to Operate, so none has a reason to file yet, but the form number will matter when one does.

What to watch

• October 13, the response deadline in the DEA rescheduling proceeding the chief administrative law judge stayed on September 29. That proceeding is the one that would reach adult use.
• October 22, the next advisory board meeting, and whether federal registration comes up alongside the intoxicating hemp rules.
• October 26 on St. Thomas and October 28 on St. Croix, the Cannabis Industry Career Expo.
• Whether OCR issues any guidance to licensees on whether to file a Form 225, and on which box to check when one license covers both tracks.
• The first dispensary Certificate to Operate, which is the point at which the Form 224M question becomes practical.