Designation of P2P Methyl Glycidic Acid as a List I Chemical
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The U.S. Drug Enforcement Administration (DEA) finalizes the designation of 2-methyl-3-phenyloxirane-2-carboxylic acid (P2P methyl glycidic acid, also known as BMK glycidic acid), including its esters, optical and geometric isomers, salts, and combinations, as a List I chemical under the Controlled Substances Act (CSA). This chemical is critical for illicitly producing phenylacetone (P2P), methamphetamine, and amphetamine, with no legitimate industrial uses. The rule imposes full CSA regulatory controls on all handlers, with no thresholds for domestic or international transactions and no exemptions for chemical mixtures at any concentration. Effective May 4, 2026, handlers must register by that date to continue operations. This fulfills U.S. obligations under the 1988 UN Convention Against Illicit Traffic in Narcotic Drugs. The rulemaking followed a notice of proposed rulemaking (NPRM) on October 2, 2025, with a 30-day comment period, addressing three public comments. DEA certified minimal economic impact on small businesses, as only nine suppliers are affected (0.07% of relevant industries). No exemptions apply unless manufacturers apply under 21 CFR 1310.13 and DEA approves. Handlers face requirements for registration (separate for manufacturing, distributing, importing, exporting), recordkeeping, reporting, and import/export controls. Violations incur civil and criminal penalties. Warehousemen are exempt if in the usual course of business.
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Key Changes
- Designates P2P methyl glycidic acid and derivatives as List I chemical under 21 CFR 1310.02
- No thresholds for domestic/international transactions; all sizes regulated
- Chemical mixtures regulated at any concentration; no automatic exemptions
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Obligations
What this law requires
All handlers of P2P methyl glycidic acid must register with DEA by May 4, 2026 to continue operations, with separate registrations required for manufacturing, distributing, importing, and exporting activities
Maintain records of all transactions involving P2P methyl glycidic acid, with no threshold exemptions for size or concentration of transactions
Report transactions and activities related to P2P methyl glycidic acid handling to DEA as required under CSA chemical regulatory provisions
Subject all import and export transactions of P2P methyl glycidic acid to DEA import/export controls and monitoring requirements
Regulate and control all chemical mixtures containing P2P methyl glycidic acid at any concentration under CSA requirements; no concentration-based exemptions apply