Today closes the 60-day comment period for the proposed rescheduling of cannabis from Schedule I to Schedule III, as proposed by the Biden Administration. Here’s more info on submitting your own comments, and some sample comments you can copy & edit from NORML.

My name is Brian Applegarth. I am the founder of the Cannabis Travel Association International. I was the sole expert advisor on the first ever cannabis travel audience research in the United States in 2019 and I lead the cannabis & hemp task force for Destinations International, the world’s largest association of destination organizations with over 700 member orgs and more than 7,500 destination professionals from 26 countries and territories around the world. 

I am a cannabis tourism and travel subject matter expert consultant and advisor for destinations.

My comments are as follows:

I agree with the HHS recommendation to move botanical cannabis (marijuana) to Schedule III or lower.

While HHS ultimately recommends transferring cannabis from Schedule I to Schedule III, I propose that these findings similarly provide a factual basis for removing cannabis from the CSA entirely. Although the HHS is not recommending descheduling at this time, I recommend descheduling cannabis be considered in the future.

I agree with the Department of Health and Human Services (HHS) that cannabis “has a currently accepted medical use”. The determination by HHS that cannabis use does not possess the same public health burden as does the use of alcohol (unscheduled), tobacco (unscheduled) or other controlled substances currently regulated in lower schedules of the CSA (e.g., benzodiazepines) is consistent with decades of worldwide scientific literature.

Schedule III or lower will enable medical and/or leisure cannabis tourism innovation throughout the United States creating jobs and opportunities. Cannabis tourism is an emerging health and wellness travel trend straddling both medical and leisure travel.

Rescheduling will also enable standardized regulations, ensuring safety and consistency for US visitors, medical and/or leisure travelers.  Rescheduling is an act of supporting responsible consumption and will mitigate potential negative impacts such as impaired driving.

Many countries are moving towards cannabis legalization and regulation. Rescheduling will enhance international competitiveness of the United States allowing for strategic alignment with global trends. By rescheduling cannabis, the U.S. can align with global trends, making it a more attractive destination for international tourists interested in cannabis tourism, be it medical, leisure or business related travel.