Date of Receipt of Sealed Inner Liners by Reverse Distributors

Drug Enforcement Administration
Diversion Control Division
Guidance Document
Title: Date of Receipt of Sealed Inner Liners by Reverse Distributors
Summary: This guidance document addresses when a Drug Enforcement Administration
(DEA)-registered reverse distributor is considered to have received a sealed inner liner from
either DEA registrants authorized as collectors or Federal, State, tribal, or local law enforcement
agencies.
Activity: Receipt of Sealed Inner Liners by Reverse Distributors
To Whom It Applies: DEA-registered reverse distributors.
Question: When is a DEA-registered reverse distributor considered to have received a sealed
inner liner either from a DEA registrant authorized as a collector or a Federal, State, tribal, or
local law enforcement agency (law enforcement)?
Answer: In accordance with 21 CFR 1317.15, 21 CFR 1317.55, and 21 CFR 1304.21(d), a
reverse distributor acquires controlled substances (including sealed inner liners) when it picks up
the controlled substances from a registrant at the registrant’s registered location or authorized
collection site or from law enforcement, or when it receives the controlled substances delivered
by common or contract carrier or delivered directly by a non-practitioner registrant or law
enforcement.
Additionally, 21 CFR 1317.15(d) states, “A reverse distributor shall destroy or cause the
destruction of any controlled substance received for the purpose of destruction no later than 30
calendar days after receipt.” See 21 CFR 1317.05(c)(2)(iv)-(v) regarding authorized methods of
sealed inner liner destruction. DEA reverse distributors are also reminded of their record
keeping obligations with respect to sealed inner liners. See 21 CFR 1304.22(e)(4)-(5).
The contents of this document do not have the force and effect of law and are not meant
to bind the public in any way. This document is intended only to provide clarity to the public
regarding existing requirements under the law, regulations, or Department of Justice policies.
EO-DEA122E, DEA-DC-062, September 15, 2022.