EC Regulation of Drug Precursors
There are certain substances which are designated as drug precursors, which
suppliers will not supply unless they are sure that the purchaser is a member of the
University and being purchased for an appropriate use. In addition we are limited in
the amount we can purchase/use each year.
Although we do not actively trade in these chemicals, the University is bound by the
requirements of EC Regulation No: 273/2004 concerning the control of drug
precursors. The purpose of the Regulation is to prevent leakage of scheduled
substances to illicit drug manufacture whilst minimising the impact on licit activities
such as research.
Drug precursors are divided into three broad categories and these determine the
requirements for compliance.
Catgeory 1
Ephedrine
Ergometrine
Ergotamine
Lysergic acid
1-phenyl-2-propanone (BMK)
Psuedoephedrine
N-acetylanthranilic acid
3-4Methylenedioxy phenylpropan-2-one(PMK)
Isosafrole
Piperonal
Safrole
alpha phenylacetoacetonitrile
Category 2
Anthranilic acid
Potassium permanganate
Phenylacetic acid
Piperidine
Acetic anhydride
Category 3
Acetone
Ethyl ether
Methyl ethyl ketone (MEK)
Toluene
Sulphuric acid
Hydrochloric acid
Category 1 Drug Precursors
To purchase/hold or use this category of substances a license issued by the Home
office is required We currently do NOT possess a license to purchase for these
materials
Category 2 Drug Precursors
A responsible person must be appointed by each group to 'regulate' the use of these
chemicals - that is, to demonstrate vigilance and take reasonable measures to
determine that the chemicals are being used for intended legitimate purposes and to
report any suspicions. There is also a requirement to submit an annual return
declaring purchase, use and stock holdings of acetic anhydride and potassium
permanganate.
License / Registration of Category 2 Drug Precursors
A license is not reguired for Category 2 precursors.
However, if annual purchases or use exceeds a threshold limit, the School will need
to apply for registration from the Home Office. The current threshold limits are shown
below:
Threshold limits:
Substance
Acetic anhydride
Potassium permanganate
Anthranilic acid and its salts
Phenylacetic acid and its salts
Piperidine and its salts
Threshold
100 l
100 kg
1 kg
1 kg
0,5 kg
As of 30 December 2013 the Home Office have amended the regulations such that:
Category 2 Precursors- ‘Category 2’ will remain as an umbrella definition but, the
Category will be sub-divided into Categories 2A and 2B. There will be no changes or
additions to the chemicals controlled within Category 2, but it will be subdivided as follows:
 Category 2A- Acetic Anhydride
 Category 2B- Potassium Permanganate, Phenyl Acetic Acid, Anthranillic
Acid, Piperidine.
This means that some additional controls will apply, domestically, to Acetic Anhydride (AA).
With effect from 30 June 2015, end users of AA (using or expecting to use in excess of 100
litres/ annum (calendar year)) must hold a Home Office Category 2 Precursor Chemical
Registration.
Purchase of Category 2 Precursors
Completion of a Customer Declaration Form is required, this is normally provided by
the supplier but a proforma on School headed paper can be found
(http://www.sussex.ac.uk/lifesci/internal/servicesandsupport/healthandsafety/forms).
One form should be completed for each substance. As no license is required for
category 2 or 3 substances N/A should be entered in the relevant section.
Details of the intended use e.g. research purposes must be entered and must be
signed by a senior member of staff
The completed form should be returned to the supplier and a copy sent to the
Technical Services Manager. This will be kept for a minimum of three years from the
end of the calendar year in which the transaction took place.
Once the substances are on site the following information will need to be recorded:
(http://www.sussex.ac.uk/lifesci/internal/servicesandsupport/healthandsafety/forms)
Supplier
Date of Supply
Substance
Category (1 or 2)
Amount and concentration
Storage Location
Responsible Person
Date and Mode of Disposal
Category 3 Drug Precursors
This category only concerns export of these chemicals and is therefore unlikely to present an
issue for the School.