If you are licensed to work with marijuana extracts, you have 30 days from today to update your paperwork. Also, Cannabidiol (CBD) extracts are now Schedule I substances and can't cross state lines. Also, Happy Holidays!

Stranger things than coffee were brewing on the morning of December 13, when the DEA filed a bizarre and unsettling document into the Federal Register's system which appears to have banned CBD. The final rule, submitted by Acting DEA Administrator Chuck Rosenberg himself, is titled:

"Establishment of a New Drug Code for Marihuana Extract"

Why the 'h' in marihuana - not just in the title, but throughout the document? Neither 'marijuana' nor 'hemp' appears. It would be churlish to suggest this was intentional, so the article wouldn't pop up under any searches for changes in marijuana policy.

So what is this new drug code about? Currently the Controlled Substances Act uses the identifying code 7360 for marijuana (with a separate code for THC itself). The NEW rule creates a category expressly for non-resinous extracts (like dabs)- i.e. anything that isn't hash.

Marihuana Extract—(7350)
Meaning an extract containing one or more cannabinoids that has been derived from any plant of the genus Cannabis, other than the separated resin (whether crude or purified) obtained from the plant.

And if that isn't enough bureaucracy for you, later on the document spells out exactly what this means for anyone licensed to handle marijuana. Well, not quite exactly...

Entities registered to handle marihuana (under drug code 7360) that also handle marihuana extracts, will need to apply to modify their registrations to add the new drug code 7350 to their existing DEA registrations and procure quotas specifically for drug code 7350 each year.

Even THAT doesn't seem too unreasonable - entities just have to update their paperwork next time they register, right?

Wrong.

Because I called the DEA to make sure such a ludicrous requirement couldn't just be foisted on people - on the 11th day of Christmas of all times. I called the number in the document, whereupon I was transferred to a liaison office of some sort, whereupon I was transferred to a brusque (if helpful) gentleman who explained that no, businesses could not wait until their next registration. If, 30 days from the publication of the document (today), anyone licensed to handle marijuana extracts who doesn't update their registration will be in violation.

Also, anyone in a state that hasn't passed medical marijuana legislation who has been getting their medicine delivered by CBD providers is probably going to have to figure something else out in 2017. I hear opiates are popular?

And just so you can fully appreciate how totally unintentional any difficulties imposed on the industry are - by making them restructure their business models, or at least update their online registrations, during the holidays; by crafting the document in a way that doesn't turn up unless you search for "cannabis" which isn't how most Americans think of or refer to it; by not trumpeting this announcement far and wide, as the DEA ought to do if it was even pretending to operate in good faith; do you know what day it is in 30 days?

Friday the 13th of January.

What are the chances that Chuck Rosenberg is a Freemason?

(Note: I would love to be wrong about this. If anyone has a more refined understanding of the situation, please by all means educate me.)