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Import and Export Controls Proposed on Precursor Chemical

Monday, December 12, 2016
Sandler, Travis & Rosenberg Trade Report

The Drug Enforcement Administration is proposing to designate the chemical alpha-phenylacetoacetonitrile and its salts, optical isomers, and salts of optical isomers as a list I chemical under the Controlled Substances Act. This rule would subject importers, exporters, manufacturers, and distributors of any amount of APAAN to all of the regulatory controls and administrative, civil, and criminal actions applicable to the importing, exporting, manufacturing, and distribution of a list I chemical. Chemical mixtures containing any amount of APAAN would also be subject to CSA controls unless the DEA approves an application for exemption.

According to the DEA, APAAN meets the criteria for designation as a list I chemical because it is used in clandestine laboratories to illicitly manufacture the schedule II controlled substances phenylacetone (also known as phenyl-2-propanone or P2P), methamphetamine, and amphetamine and is important to the manufacture of those substances.

Comments on this proposal are due no later than Jan. 11.

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