On December 18th, President Trump took the most consequential federal action on cannabis policy in decades, reclassifying cannabis (marijuana) from a Schedule I to a Schedule III drug. This moves cannabis from a classification that defined it as having a high potential for abuse with no accepted medical use—alongside substances such as heroin and LSD—to one that recognizes accepted medical uses and a lower potential for abuse, though still with some risk of physical or psychological dependence. Schedule III substances include anabolic steroids, ketamine, and certain acetaminophen–codeine combinations, meaning cannabis remains a controlled substance, but one with significantly fewer restrictions—an outcome with potentially far-reaching implications for the industry.
What’s Changing (And What’s Not)
Medical Markets & Research:
In practical terms, a move to Schedule III may have a limited immediate impact on consumers. As a federally controlled substance, cannabis production technically remains illegal under the Controlled Substances Act, meaning access will not expand without state-level action (with existing medical programs protected from DOJ prosecution under 2024 legislation). However, the shift should significantly ease restrictions on cannabis research, which was previously extremely difficult due to rigid DEA requirements, creating greater opportunities to explore the plant’s potential uses.
Banking & Compliance:
For businesses, the implications are expected to be far more substantial. Section 280E prohibits companies operating in state-regulated cannabis markets from deducting normal business expenses if their products are classified as Schedule I or II substances, resulting in unusually high effective tax rates. Once rescheduling is implemented, businesses will be able to deduct standard expenses such as wages, rent, utilities, and advertising. This change should meaningfully improve industry profitability and make the sector more attractive to external investors.
While not explicitly stated in the executive order, the rescheduling should also reduce compliance concerns among financial service providers, potentially expanding access to new banking relationships, payment processors, and other financial services.
Refining the CBD & Hemp Landscape:
The order additionally includes language directing Congress to update the definition of hemp-derived cannabinoid products, last revised in November 2025 as part of legislation to reopen the federal government. This framework limits products to 0.4 mg of THC per finished product, which would make many full-spectrum CBD products illegal as of November 2026, when the changes are set to take effect. While the executive order itself does not amend these rules, it states that executive departments and agencies will work with Congress to implement new THC serving limits and CBD-to-THC ratio requirements. The order also authorizes a pilot program to reimburse Medicare patients for CBD-based products, a potential boon for the industry.
Open Questions
Although federal recognition of cannabis’s medicinal value may influence future state-level decisions around medical cannabis programs, it does not automatically legalize cannabis for medical use nationwide. Still, the combination of looser federal restrictions and formal recognition of medical benefits is likely to sustain momentum for state-level medical reforms. It could eventually open the door to some form of insurance coverage.
The implementation timeline also remains uncertain. Before rescheduling can take effect, the Department of Health and Human Services must complete a scientific and medical evaluation of cannabis and provide a scheduling recommendation. The Drug Enforcement Administration must then decide whether to reschedule the drug, followed by a formal public comment period. While the process is expected to move forward without significant obstacles, it is likely to take several months to complete.
Market Research
Brightfield Group data indicates a steady rise in cannabis participation, a trend now poised for acceleration following the December 18th federal rescheduling to Schedule III. While CBD incidence had previously softened, the new federal focus on clinical research and the Medicare CBD pilot program provide a potential floor for the category.
Conversely, hemp-derived THC has seen significant growth via mainstream retail, though it now faces a period of transition as operators align with the new 0.4 mg federal container limits set for late 2026. This shifting landscape is driving a notable convergence: as federal oversight intensifies, the market is favoring operators who can bridge the gap between state-regulated frameworks and traditional healthcare standards.
Bottom Line
The reclassification of cannabis from Schedule I to Schedule III represents a significant improvement for the industry, with a wide range of anticipated operational benefits, most notably improved financial viability for licensed operators. While the move does not create new legal markets, it should accelerate medical cannabis adoption in additional states and enable expanded research into the plant, strengthening its medical credentials over time. Commitments to further refine hemp-derived product regulations and explore Medicare reimbursement also bode well for CBD patients who were facing restricted access beginning in late 2026. Although additional reforms remain necessary, this shift marks a significant milestone for the industry and further cements the legitimacy of cannabis as a medicinal product.
From a market intelligence perspective, rescheduling will likely accelerate segmentation. We expect to see a "flight to quality," favoring companies with strong medical credibility, research partnerships, and the agility to navigate evolving federal compliance. As cannabis moves closer to traditional wellness and pharmaceutical frameworks, the ability to provide standardized, data-backed products will become the primary competitive advantage.
Updated: 12/19/2025
