Requirement to Use Multiple Single-Sheet DEA Form 222s (Order Forms) When Transferring Schedule I or II Controlled Substances Upon Termination or Transfer of a DEA Registration, or Discontinuing Business Altogether (EO-DEA117)

Drug Enforcement Administration
Diversion Control Division
Guidance Document
Title: Requirement to Use Multiple Single-Sheet DEA Form 222s (Order Forms) When
Transferring Schedule I or II Controlled Substances Upon Termination or Transfer of a DEA
Registration, or Discontinuing Business Altogether
Summary: This guidance document clarifies the requirement for Drug Enforcement
Administration (DEA) registrant-transferors to use multiple single-sheet DEA Form 222s (order
forms) when transferring schedule I or II controlled substances to a DEA registrant-transferee
when the number of items being transferred exceeds the number of lines available on the order
form.
Activity: Completing Multiple Single-Sheet DEA Form 222s
To Whom It Applies: DEA Registrants
Question: Can a DEA registrant-transferor attach an itemized list or an inventory of schedule I
or II controlled substances to a single-sheet DEA Form 222 in lieu of completing multiple DEA
Form 222s when the number of items to be transferred to a DEA registrant-transferee exceeds
the number of lines on the form?
Answer: No. When transferring inventory from a registrant-transferor to a registrant-transferee
upon the termination of registration, transfer of registration, or discontinuance of business,
transfers of schedule I or II controlled substances require the use of order forms in accordance
with 21 CFR 1305. See 21 CFR 1301.52(e)(1). Under 21 CFR 1305.03, the completion of DEA
Form 222 is required for each distribution of a schedule I or II controlled substance.
Neither the Controlled Substances Act nor its implementing regulations authorize adding
attachments or itemized lists to DEA Form 222s. Rather, DEA regulations state, in relevant part:
“Only one item may be entered on each numbered line. An item must consist of one or more
commercial or bulk containers of the same finished or bulk form and quantity of the same
substance. The number of lines completed must be noted on that form at the bottom of the form,
in the space provided.” 21 CFR 1305.12(b). In addition, Part 1 of the Instructions for the DEA
Form 222 states: “The purchaser fills out no more than twenty line items in this section. If more
items are needed, use another form.” When the registrant-transferor adheres to the requirements
of 21 CFR 1301 and 1305, and follows the instructions set forth on the DEA Form 222, there is
no discrepancy between the number of items ordered, the number of lines completed, and the
controlled substances transferred.
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 or Department of Justice policies.
EO-DEA117, DEA-DC-070, February 26, 2023