It’s hard to believe, but it’s been nearly three years since the Michigan Cannabis Regulatory Agency announced that it was seeking stakeholder feedback on proposed changes to its administrative rule sets. The process started in May 2023, with CRA releasing a list of topics and proposed changes to the rules that it was considering. After receiving and considering a substantial amount of comments and stakeholder feedback, CRA then proceeded to undertake a comprehensive rewriting of its administrative rules.
Continue Reading “Final” Draft CRA Rules Are PublishedBreaking Down the Groundbreaking Rescheduling Of Medical Marijuana To Schedule III
On April 23, 2026, Acting Attorney General Todd Blanche announced that the Justice Department ordered the rescheduling of marijuana products that are FDA-approved or regulated by a state medical marijuana program. These products will move from Schedule I to Schedule III of the Controlled Substances Act (“CSA”). Today’s order also creates an expedited DEA registration framework for state-licensed medical marijuana businesses.
We previously covered President Trump’s December 18, 2025, executive order to fast-track rescheduling. But news had been quiet on rescheduling for months, making today’s groundbreaking announcement, while welcome, a bit unexpected. In this post, we quickly highlight what today’s DOJ order does and does not do, and we look ahead at what’s to come.
Continue Reading Breaking Down the Groundbreaking Rescheduling Of Medical Marijuana To Schedule IIIMichigan Treasury Does About-Face on Wholesale Marijuana Tax Issue
Michigan licensees—DO NOT MISS A MAJOR CHANGE IN WHOLESALE TAX ADMINISTRATION!
The first payments for Michigan’s new wholesale are due, ironically, on April 20. As we previously reported, FAQs published by the Michigan Department of Treasury just a few weeks ago announced that product transferred to a retailer before the tax took effect on…
Michigan’s New Wholesale Cannabis Tax (Mis)Guidance
On March 17 (Happy St. Patrick’s Day!), Michigan’s Department of Treasury issued Revenue Advisory Bulletin 2026-3, a formal interpretation of Michigan’s new wholesale cannabis tax.
Continue Reading Michigan’s New Wholesale Cannabis Tax (Mis)GuidanceJanuary 1 for Michigan Cannabis: A New Year, A New Headache
Takeaways
- Michigan’s new 24% wholesale cannabis tax is in effect on January 1; however, Treasury’s last-minute guidance raises significant compliance, pricing, and litigation risks for licensees.
- Treasury’s use of a blanket “average wholesale price” based on assumed markups—not actual transaction data—may conflict with statutory and constitutional requirements.
- With constitutional challenges pending and more litigation expected, cannabis businesses should prepare now for audits, disputes, and rapidly evolving enforcement positions.
As the new year is upon us, Michigan’s wholesale cannabis tax takes effect on January 1. A mere 35 hours beforehand, Michigan’s Department of Treasury published the “average wholesale price” to be used for affiliate transfers and updated its FAQ’s. Treasury has also prepared a draft Revenue Advisory Bulletin—although Treasury has not made this public on their wholesale marijuana tax webpage.
Continue Reading January 1 for Michigan Cannabis: A New Year, A New Headache