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Import and Export Controls Imposed on Precursor Chemical

Monday, July 17, 2017
Sandler, Travis & Rosenberg Trade Report

The Drug Enforcement Administration has issued a final rule designating the chemical alpha-phenylacetoacetonitrile and its salts, optical isomers, and salts of optical isomers as a list I chemical under the Controlled Substances Act. Effective Aug. 14 this rule will subject importers, exporters, manufacturers, and distributors of any amount of APAAN to all of the regulatory controls (registration, records and reporting, inspection, etc.) and administrative, civil, and criminal actions applicable to the importing, exporting, manufacturing, and distribution of a list I chemical.

This rule does not establish a threshold for domestic and import transactions of APAAN; as a result, all such transactions regardless of size will be regulated. Chemical mixtures containing any amount of APAAN will also be regulated 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.

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