WeedPress: The Paper Trail

DEA says timely applicants are expected to establish compliant supply chains by Nov. 29, 2026. This plain-English checklist, built from DEA’s own guidance sheet and website, shows how a South Dakota dispensary can check whether a supplier qualifies.

By Jason Karimi, Publisher

Part of WeedPress’s South Dakota DEA Supply Chain series. Start here →

This guide is part of WeedPress’s SD DEA Supply Chain series. The series began with a question a newly registered South Dakota dispensary put to WeedPress: which suppliers can it legally buy from?¹ The DEA points in the checklist below come from what DEA itself has published: its Oct. 30, 2026, DEA Medical Marijuana Timely Applicant Information sheet and its Medical Marijuana Information web page.²,³ It does not say which South Dakota suppliers qualify. The timely-applicant list DEA posts does not name businesses, so a supplier’s federal status has to be confirmed from documents the supplier provides or from DEA.³

This is not legal advice. It is a plain-English summary of DEA’s published guidance. Talk to a lawyer, and confirm with DEA and the South Dakota Department of Health, before you buy.

Who a timely applicant may buy from and sell to

DEA’s sheet covers businesses that submitted a complete application, including the registration fee, for a DEA registration to handle schedule III medical marijuana between April 28 and June 26, 2026. DEA calls them “Timely Applicants.” While their applications are pending, they may keep dispensing, manufacturing or distributing “pursuant to their state medical marijuana license.”²

Two kinds of applicants are not covered, according to the sheet: applicants whose application “is no longer pending before DEA because the applicant has withdrawn the application or because the Administrator has issued a Final Order denying the application,” and applicants “who lack the requisite state medical marijuana license.”⁴

Under the sheet, a timely applicant may engage in schedule III medical marijuana activities with two kinds of partners:⁵

• Other timely applicants. DEA’s example: “a Timely Distributor Applicant can distribute schedule III medical marijuana to a Timely Dispenser Applicant and can obtain schedule III medical marijuana from a Timely Manufacturer Applicant.”⁵
• DEA registrants “that hold a registration to handle schedule III medical marijuana.” DEA’s example: “a DEA-registered dispensary can continue receiving schedule III medical marijuana from a Timely Distributor Applicant.”⁵

Apart from the existing-inventory and testing-lab provisions discussed below, everyone else is off limits. Timely applicants and DEA registrants “may not lawfully engage in any schedule III medical marijuana activities with entities that did not complete an application for DEA registration between April 28, 2026, to June 26, 2026, or that have not applied for a DEA schedule III medical marijuana registration, until those entities become DEA registrants.”⁷ DEA says dealing with anyone outside those two groups “could be potential grounds for denial of a Timely Applicant’s application or revocation of a certificate of registration, respectively.”⁶

The Nov. 29, 2026, deadline

DEA says it “recognizes Timely Applicants may require additional time to verify the status of their existing trading partners as Timely Applicants or registrants and to make necessary adjustments to their supply chain to comply with this information.” The sheet says timely applicants “are expected to complete these activities and establish compliant supply chains no later than November 29, 2026.”⁸ The sheet does not say what DEA will do after that date. WeedPress has asked DEA (see below).⁹

Two exceptions, in DEA’s words

Existing inventory. The sheet says: “Timely Dispenser Applicants and Timely Distributor Applicants may continue to possess, dispense, and distribute existing inventories of schedule III medical marijuana acquired prior to the issuance of this information, including inventory previously obtained from entities that do not qualify as Timely Applicants or DEA registrants. Such inventory may continue to be used in otherwise authorized activities.”⁸ That sentence names timely dispenser and timely distributor applicants. It does not state a date. WeedPress has asked DEA whether the issuance date is Oct. 30, 2026, whether the exception still covers a dispensary that has since been registered, and whether it ends.⁹

Testing labs. DEA recognizes that some states require entities holding state medical marijuana licenses to send “de minimis quantities of schedule III medical marijuana” to state-licensed third-party laboratories for testing, and that some businesses “may not have access to analytical laboratories that are DEA-registered to handle schedule III medical marijuana.” To the extent such labs are unavailable, DEA “does not intend to penalize registrants and Timely Applicants for sending de minimis quantities of schedule III medical marijuana to a laboratory that is not DEA-registered to conduct analytical testing of schedule III medical marijuana,” provided that “(1) the analytical laboratory is located in the same state, and (2) the Timely Applicant/registrant retains detailed records of all such distributions.”¹⁰

The sheet narrows that lab provision, which it describes as an “exercise of the Administrator’s discretion.” It applies “only when the use of a DEA-registered laboratory would violate state law.” Specifically, it applies “only to the extent that either (1) no entities anywhere in the United States are registered with DEA to conduct analytical testing of schedule III medical marijuana, or (2) state law prohibits the Timely Applicant/registrant from sending schedule III medical marijuana to an analytical laboratory in a different state, and no entities in the Timely Applicant/registrant’s state are registered with DEA to conduct analytical testing of schedule III medical marijuana.” It also says it “does not permit Timely Applicants and registrants to receive schedule III medical marijuana from non-DEA-registered analytical laboratories,” and that labs themselves are not covered by the timely-applicant provision.¹⁰

The checklist: verifying a trading partner

DEA says timely applicants and registrants “should take adequate steps to confirm the status of all entities with which they will conduct schedule III medical marijuana activities,” and lists what that “generally would include, at a minimum.”⁶ Here is that guidance as a working checklist, with where to find each item.

1. Find out which kind of partner you are dealing with. Is the business a timely applicant or a DEA registrant, and for which activity? DEA’s Medical Marijuana Information page says its timely-applicant list sorts each entry by business activity: medical marijuana dispensary, manufacturer or distributor.³ The steps below differ for applicants and registrants.
2. Timely applicant? Get its DEA submission confirmation. For a dispensary, DEA names the “Marijuana Dispensary Information Submission” confirmation it received from DEA when it applied. For a manufacturer or distributor, it is “the submission confirmation provided by DEA at the time of application submission.”⁶
3. Check its control number on DEA’s timely-applicant list. DEA says to verify a timely applicant’s “document control number (DCN) via the DEA Diversion Control Website.”⁶ DEA’s Medical Marijuana Information page links to the timely-applicant list, a text file with three fields: state, business activity and control number, which DEA describes as a “unique identifier provided for each application.” The list has no business names. DEA says the list “is current as of the date included in the file” and that the file “will be updated daily.”³ Note the file date when you check. At WeedPress’s most recent check, at 1:16 p.m. CST Nov. 2, the file returned a “Page Not Found” error while DEA’s page still linked to it.¹¹ WeedPress has asked DEA how buyers should verify a supplier while the file is unavailable.⁹
4. DEA registrant? Get a copy of its DEA certificate of registration.⁶ Don’t rely on the timely-applicant list alone. DEA’s Medical Marijuana Information page says the list “may change as Timely Applicants are granted DEA registrations, withdraw their applications for DEA registration, or are no longer considered Timely Applicants for any other reason.”³ A registered business may drop off the list once it is registered. But removal from the list is not, by itself, proof of registration. The list does not say why an entry is gone.³ Ask for the certificate.
5. Get a copy of its state license and confirm it is active. DEA’s sheet calls for “[o]btaining a copy of the entity’s relevant state license and verifying its status is active.”⁶ In South Dakota, check the business against the Department of Health’s medical cannabis establishments list. WeedPress tracks that list, with a status for each entry, on its South Dakota Medical Cannabis Establishment Status page.¹² Two limits: the department’s page says it was last updated Aug. 27, 2026, and it lists no certificate numbers. A state license is not a DEA registration.¹²
6. Keep records of every check. DEA’s sheet calls for “[m]aintaining records of all due diligence conducted.”⁶ Keep the partner’s confirmation or certificate, its state license, and a note of what you checked and when. DEA registrants must also keep all records required for schedule III controlled substances under 21 C.F.R. part 1304. When a registrant deals with a timely applicant, those records “can include the Timely Applicant’s DCN number where a DEA registration number would otherwise be required.”¹³
7. Check again later. DEA updates the timely-applicant list daily, and an entry’s status can change as applications are granted, withdrawn or no longer considered timely.³ A check done in early November may not hold on Nov. 29.
8. Sending samples to a lab that is not DEA-registered? Confirm it fits the narrow testing exception above, and keep “detailed records of all such distributions.”¹⁰

What patients should know

DEA’s sheet is written for businesses and does not address patients directly.² It addresses where a dispensary may get schedule III medical marijuana. If you want to know where your dispensary stands, you can ask it whether it is a DEA timely applicant or registrant, and whether it has confirmed its suppliers’ DEA status ahead of Nov. 29.

What DEA’s sheet is, and isn’t

DEA’s sheet says its contents “do not have the force and effect of law and are not meant to bind the public in any way.” It says it “is intended only to provide clarity to the public regarding existing requirements under the law or Department of Justice policies.”¹⁴ The underlying rule is in DEA’s regulations, at 21 C.F.R. § 1301.13(k)(7), which the sheet cites throughout.²

Questions WeedPress has put to DEA

WeedPress sent questions to DEA Media Affairs on Oct. 31 and Nov. 2, 2026.⁹ Answers are pending; WeedPress requested them by Nov. 4 and Nov. 5, respectively. WeedPress asked:

• Oct. 31: how many South Dakota dispensaries DEA has registered; whether DEA will publish registrants’ names; whether a timely applicant that is granted a registration is removed from the timely-applicant list; how many South Dakota applicants have received an order to show cause, been denied or withdrawn; the status of South Dakota manufacturer and distributor applications; and whether the South Dakota entries on the Oct. 30 list represent all South Dakota applicants.
• Nov. 2: whether a registered or timely-applicant South Dakota dispensary may buy directly from an in-state timely manufacturer applicant that is not yet registered, before and after Nov. 29; whether the existing-inventory exception’s issuance date is Oct. 30, whether it covers a dispensary that has since been registered and whether it ends; whether DEA’s Medical Marijuana Information page is the intended place to verify a control number; how to verify a supplier while the timely-applicant file is unavailable; and how a buyer can tell why a control number left the list.

WeedPress will update this guide with any answers.

More from the series

• Ruthie’s Dispensary in Wagner Got Its DEA Registration, Then Asked WeedPress Who It Can Legally Buy From by Nov. 29¹
• South Dakota Medical Cannabis Establishment Status¹²
• Federal Medical Cannabis Compliance Matrix
• How WeedPress verifies: how WeedPress checks DEA and state records for this series.

Any South Dakota business, patient or attorney with a correction, a document from DEA or a question for this guide can reach WeedPress at weedpressnewstips@gmail.com. This guide is not legal advice.