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Import and Export Controls Proposed for Two Chemicals

Monday, September 16, 2019
Sandler, Travis & Rosenberg Trade Report

The Drug Enforcement Administration is proposing to designate the chemicals N-(1-benzylpiperidin-4-yl)-N-phenylpropionamide (also known as benzylfentanyl), including its salts, and N-phenylpiperidin-4-amine (also known as 4-anilinopiperidine; N-phenyl-4-piperidinamine; 4-AP), including its amides, carbamates, and salts, as list I chemicals under the Controlled Substances Act. Comments are due by Nov. 12.

If finalized, this rule would subject importers, exporters, manufacturers, and distributors of any amount of these substances to all of the regulatory controls (importation and exportation, registration, records and reporting, inspection, etc.) and administrative, civil, and criminal actions applicable to the import, export, manufacture, and distribution of a list I chemical.

This rule would not establish a threshold for domestic and international transactions of these substances, meaning all transactions of chemical mixtures containing these substances would be regulated at any concentration and would be subject to control under the CSA.

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