Possession of controlled substances paraphernalia, under California Health & Saf. Code 11364 is not subject to the unidentified substance defense. See Matter of Paulus, 11 I. & N. Dec. 274 (BIA 1965). This is because advocates have not identified any extra substances covered under the relevant California drug schedules that are not listed in the federal Controlled Substances Act. Safer dispositions include accessory after the fact, under Penal Code 32, pre-plea diversion, or other suggestions set forth in the last practice advisory on Withdrawal of Plea after DEJ. As last resort do DEJ and then do new Withdrawal of Plea and ask for 18 month diversion period. See the practice advisory at http://www.ilrc.org/resources/New_California_Drug_Law_1203.43

For a permanent resident who is not already deportable, a plea -- whether regular or DEJ -- to 11377 with the record sanitized so that it reflects only "a controlled substance prohibited under Health & Saf. Code 11377(a)" is a reasonable alternative if a non-drug plea simply is not available, because it will not make the person deportable. Paulus, supra. In that case, DEJ is better than a 'regular' plea. The fact that there is no controlled substance mentioned in the entire record will prevent the person from being found deportable during the 18-month DEJ period, and then the new DEJ Penal Code 1203.43 withdrawal of the plea as legally invalid will eliminate the "conviction" completely. Matter of Pickering, 23 I. & N. Dec. 621 (BIA 2003), vacated on other grounds by Pickering v. Gonzales, 465 F.3d 263 (6th Cir. 2006).

This "non-specified controlled substance" defense does not work for an undocumented person or a permanent resident who already is deportable. They need to apply for some status or relief to avoid being deportable, and the non-specified substance defense does not work there.

Assume that the non-specified substance defense only works for Health & Saf. Code 11377-11379. Although case law currently holds that it works as well for Health & Saf. Code 11350-52, if the government pushed back, counsel might be unable to find a specific controlled substance on those schedules, but not listed under relevant federal law. Thanks to Michael Mehr and Katherine Brady.

Penal Code 381b, nitrous oxide, might work. Its not on the federal schedule, and its a drug charge. Under Mellouli, based on language in the case, the thinking seems to be that whatever drugs are on the schedule at the time of the plea controls, not whatever drugs might be added at a later date.
Thanks to Daniel G. DeGriselles.

To plead safely to Health & Saf. Code 11377, under Coronado v Holder, 759 F.3d 977 (9th Cir. July 18, 2014), counsel should add a new count, charging possession under 11377, dismiss all other counts, plead to violating this statute, do not stipulate to the police report as a factual basis, and give the court "a factual basis" based on counsels independent investigation of the case. See People v Palmer, 58 Cal.4th 110 (2013).
Thanks to Francisco Ugarte.