Chemical Broker Dear Registrant Letter

U. S. Department of Justice
Drug Enforcement Administration
www.dea.gov
Dear Registrant,
It has come to the Drug Enforcement Administration’s (DEA) attention that some chemical
import brokers who were granted a DEA registration as chemical importers may be using business
practices that fail to comply with DEA regulations. In addition, DEA is concerned that some
pending chemical importer applicants, and some current chemical importer registrants pending
renewal, may be using a business model that is not in compliance with DEA regulations. This letter
serves to advise registrants of DEA’s policy with respect to how the agency intends to apply the
relevant regulation.
The pertinent regulation is 21 CFR 1313.14, which provides that “for list I chemicals, the
final destination of the import transaction must only be the registered location of the importer (i.e.,
drop shipments are prohibited).” DEA interprets this regulation to require that all imported list I
chemicals be delivered at a chemical importer’s registered location prior to distribution.
Accordingly, if a DEA-registered chemical importer allows shipments of list I chemicals to go
directly from the port to a customer it is not in compliance with the requirements of 21 CFR 1313.14
because such drop shipments of list I chemicals are prohibited.
DEA is reviewing all new list I chemical importer applications for registration to ensure that
the applicant’s business model includes compliance with 21 CFR 1313.14. For any applicants
whose business model would include prohibited drop shipments as described above, DEA may take
administrative action to seek to deny the application for registration, unless the applicant changes
their business model to comply with the regulation (i.e., that the final destination of any import
transaction for list I chemicals will be the applicant’s proposed registered location).
DEA will also review the business practices of currently registered list I chemical importers
regarding their compliance with the requirements of 21 CFR 1313.14. If DEA identifies a registrant
whose business practices are not in compliance with 21 CFR 1313.14, as discussed above, DEA will
ask the registrant to comply with the regulation (i.e., by ensuring that the final destination of any
import transaction for list I chemicals will be the registrant’s registered location), or to voluntarily
surrender their DEA registration. If the registrant refuses to change its business practices to
preclude drop shipments, DEA may take administrative action to seek to revoke that list I chemical
importer’s DEA registration. Decisions on whether to take such administrative action against
individual registrants, and applicants for registration, will be made on a case-by-case basis, and will
be guided by the statutory criteria set forth in the Controlled Substances Act, and applicable
regulations.
The contents of this document do not have the force and effect of law and are net meant to
bind the public in any way. This document is intended only to provide clarity to the public
8701 Morrissette Drive
Springfield, Virginia 22152
6-8-2022
DEA Registered List 1 Chemical Importers

DEA Registered List 1 Chemical Importers
6/8/2022
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regarding existing requirements under the law or Department policies.
For more information regarding DEA’s Diversion Control Division, please visit
www.DEAdiversion.usdoj.gov. If you have any additional questions on this issue, please contact
the Diversion Control Chemical Section at 571-362-3352 or email them at DOC@dea.gov.
Sincerely,
Thomas W. Prevoznik
Deputy Assistant Administrator
Diversion Control Division
EO-DEA236, DEA-DC-055, June 8, 2022