Circular 003/2026: drug precursor chemicals
Published 10 June 2026
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Overview
The Government is introducing changes to control a wider set of drug precursor chemicals (DPCs) in Great Britain, and to ensure that UK-wide criminal offences apply to a wider set of DPCs. This ensures that police forces can act against criminals involved in the import, export, manufacture or supply of potentially harmful DPCs which can be used to make illicit drugs.
Drug Precursor Chemicals controls
This Circular describes changes in the legislation on drug precursor chemicals (DPCs).
It contains information for:
-
Businesses, as the existing requirements to apply to the Home Office for licences and related documents, and to discharge additional responsibilities such as documenting DPC consignments, will now apply to additional DPCs.
-
Law enforcement organisations, as existing criminal offences will now apply to additional DPCs.
Background
DPCs often have legitimate industrial uses but can also be used to make illicit drugs. There are two mechanisms whose aim is to prevent their illicit use:
1. Requirements on those who make legitimate use of DPCs, for example in industry. These are intended to make it harder for DPCs to be diverted to producing illicit drugs.
The Controlled Drugs (Drug Precursors) (Amendment and Revocation) Regulations 2026 (“the 2026 Regulations”) amend the 7 regulations which set out these requirements.
Four of these regulations previously applied across the UK. The 2026 Regulations clarify that they apply only in Great Britain. Links to the Great Britain regulations are below:
Regulation (EC) No 273/2004 of the European Parliament and of the Council
Council Regulation (EC) No 111/2005
Commission Delegated Regulation (EU) 2015/1011
Commission Implementing Regulation (EU) 2015/1013
Similar provisions in EU law apply in Northern Ireland. Links are below:
Regulation (EC) No 273/2004 of the European Parliament and of the Council
Council Regulation (EC) No 111/2005
Commission Delegated Regulation (EU) 2015/1011
Commission Implementing Regulation (EU) 2015/1013
The other three regulations continue to apply across the UK. In some cases the regulations specify the provisions which apply in Great Britain and those which apply in Northern Ireland. Links are below:
The Controlled Drugs (Drug Precursors)(Intra-Community Trade) Regulations 2008
The Controlled Drugs (Drug Precursors)(Community External Trade) Regulations 2008
The 2026 Regulations make some substantive changes to the provisions in the above regulations. Details on these changes are set out below.
The 2026 Regulations come into force on 29 June 2026 at 00:01.
2. Prohibitions making it a crime to make or supply DPCs with the intention of facilitating illicit drug production.
Section 12 of the Criminal Justice (International Co-operation) Act 1990 (“the 1990 Act”) makes it a crime to manufacture or supply a DPC if the defendant knew or suspected it was to be used in or for the unlawful production of a controlled drug. Schedule 2 to the 1990 Act lists the DPCs to which that offence applies.
Schedule 2 to the 1990 Act is being amended by The Criminal Justice (International Co-operation) Act 1990 (Amendment) Order 2026 (“the 2026 Order”). Details on the changes in the 2026 Order are set out below.
The 2026 order comes into force on 1 July 2026 at 00:01. It can be found here.
Statutory instruments are also published by the Stationery Office. Telephone orders and general enquiries can be made to 0330 202 5070.
1. Regulations on legitimate use of DPCs
The regulations divide DPCs into four categories, 1-4. Category 2 is divided into sub-categories 2A and 2B. The responsibilities on businesses vary according to the category a DPC is in.
The 2026 Regulations will add the following substances to Category 1, in Great Britain. They are already controlled in Northern Ireland:
| Substance | CN[footnote 1] designation (if different) | CN Code | CAS[footnote 2] No |
|---|---|---|---|
| DEPAPD (Diethyl (phenylacetyl) propanedioate) | 2918 30 00 | 20320-59-6 | |
| EAPA (Ethyl alpha-phenylacetoacetate) | Ex 2918 30 00 | 5413-05-8 | |
| IMDPAM (Isopropylidene (2-(3,4-methylenedioxyphenyl)acetyl)malonate) | IMDPAM | 2932 99 00 | |
| MAMDPA (Methyl 3-oxo-2-(3,4-methylenedioxyphenyl)butanoate) | Methyl 3-oxo-2-(3,4-methylenedioxyphenyl)butanoate | Ex 2932 99 00 | 1369021-80-6 |
| 4-AP (N-phenylpiperidin-4-amine) | 2933 39 99 | 23056-29-3 | |
| 1-boc-4-AP (Tert-butyl 4-anilinopiperidine-1-carboxylate) | 2933 39 99 | 125541-22-2 | |
| Norfentanyl (N-phenyl-N-(piperidin-4-yl)propanamide) | 2933 39 99 | 1609-66-1 | |
| 1-boc-4-piperidone | tert-butyl 4-oxopiperidine-1-carboxylate | 2933 39 99 | 79099-07-3 |
| 4-piperidone | Piperidin-4-one | 2933 39 99 | 41661-47-6 |
| The ethyl, propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl esters of PMK glycidic acid | 2932 99 00 | Ethyl ester: 28578-16-7 | |
| The ethyl, propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl esters of BMK glycidic acid | 2918 99 90 |
The 2026 Regulations will also add the following substance to Category 2A, in Great Britain. It is already controlled in Northern Ireland:
| Substance | CN Code | CAS No |
|---|---|---|
| Red phosphorus | 2804 70 10 | 7723-14-0 |
The responsibilities on businesses relating to applying for licences and import and export authorisations are set out in detail in this guidance. The responsibilities relating to documentation, recording and labelling are set out in this guidance. Both of these pages should be consulted for full information and details on application processes. A short summary of the requirements as they relate to the above substances is as follows:
For Category 1 substances, businesses must:
- Appoint a responsible officer for their trade in DPCs.
- Apply to the Home Office’s Drugs and Firearms Licensing Unit (DFLU) for a licence before doing any of the following things with the DPC: possession, supply (whether in return for payment or free of charge), storage, manufacture, production, processing, trading, distribution or brokering for the purpose of supply in the UK.
- For domestic business, get a declaration from the end user showing the specific intended use(s) of the DPCs.
- Apply to DFLU for an authorisation to export or import them. A licence, as above, is also necessary to do this.
- Document consignments of DPCs and keep records.
- Label consignments of DPCs.
- Tell the National Crime Agency about any circumstances (e.g. unusual orders or transactions) which suggest the DPC might be diverted to make illicit drugs. You can find more information about the process here.
- Supply DFLU with an annual return about their trade in DPCs.
- Demonstrate the DPC’s licit purpose when it enters the UK, if asked to do so by His Majesty’s Revenue and Customs.
These responsibilities apply to the DPC itself, or to a mixture or natural product containing it, unless the mixture or natural product is compounded in such a way that the DPC cannot be easily used or extracted by readily applicable or economically viable means.
For Category 2A substances, businesses must:
- Appoint a responsible officer for their trade in DPCs.
- Apply to the Home Office’s Drugs and Firearms Licensing Unit (DFLU) for a registration (similar to a Category 1 licence) before doing any of the following things with the DPC: possession, supply (whether in return for payment or free of charge), storage, manufacture, production, processing, trading, distribution or brokering for the purpose of supply in the UK.
- For domestic business, get a declaration from the end user showing the specific intended use(s) of the DPCs.
- Apply to DFLU for an authorisation to export them. A registration, as above, is also necessary to do this.
- Apply to DFLU for a registration to import them. But there is no need to obtain an import authorisation.
- Document consignments of DPCs and keep records.
- Label consignments of DPCs.
- Tell the National Crime Agency about any circumstances (e.g. unusual orders or transactions) which suggest the DPC might be diverted to make illicit drugs. You can find more information about the process here.
- Supply DFLU with an annual return about their trade in DPCs.
- Demonstrate the DPC’s licit purpose when it enters the UK, if asked to do so by His Majesty’s Revenue and Customs.
These responsibilities apply in relation to the DPC itself, or to a mixture or natural product containing it, unless the mixture or natural product is compounded in such a way that the DPC cannot be easily used or extracted by readily applicable or economically viable means.
For red phosphorus, the following requirements apply only if the user is dealing with more than 0.1kg of red phosphorus over the course of a year:
- Appointing a responsible officer
- Obtaining a registration for domestic purposes (rather than for export)
- Getting an end use declaration
- Documenting consignments
Criminal offences
Breach of any of these requirements is a criminal offence, with a maximum sentence of two years’ imprisonment. This includes knowingly or recklessly providing information that is false in a material particular.
The relevant Home Office offence codes are:
| Offence | Code |
|---|---|
| Failure to comply with regulations made by the Secretary of State as regards documentation, record keeping, labelling etc | 077/52 |
| Operator failing to comply with requirements imposed by Article 3 of Community Regulation | 077/61 |
| Operator who fails to comply with requirements imposed by regulation 6 - EXPORTS | 077/62 |
| Operator who fails to comply with requirements imposed by regulation 7 - IMPORTS | 077/63 |
| Operator who fails to comply with requirements imposed by Article 6 or 7 of council regulation (EC) No 111/2005 - licensing and registration of operators | 077/64 |
So just as the above requirements will now apply to the new DPCs, so will the criminal offence of failing to observe those requirements.
However, there have previously been some DPCs where some of the requirements did apply, but the criminal offences for failing to observe those requirements did not. Those requirements are:
- Documenting consignments of DPCs and keeping records.
- Labelling consignments of DPCs.
- Telling the National Crime Agency about any circumstances (e.g. unusual orders or transactions) which suggest the DPC might be diverted to make illicit drugs.
- Supplying DFLU with an annual return about their trade in DPCs.
- Demonstrating the DPC’s licit purpose when it enters the UK if asked to do so by His Majesty’s Revenue and Customs.
When the 2026 Regulations come into force, the criminal offences will also apply to not following those requirements for those DPCs, across the UK. The DPCs are:
| Substance | CN designation (if different) | CN Code | CAS No |
|---|---|---|---|
| MAPA (Methyl alpha-phenylacetoacetate) | 2918 30 00 | 16648-44-5 | |
| APAA (Alpha-phenylacetoacetamide) | 2924 29 70 | 4433-77-6 | |
| APAAN (Alpha-phenylacetoacetonitrile) | 2926 40 00 | 4468-48-8 | |
| N-phenyl-1-(2-phenylethyl)piperidin-4-amine | 4-anilino-N-phenethylpiperidine (ANPP) | 2933 36 00 | 21409-26-7 |
| 1-(2-phenylethyl)-piperidin-4-one | N-phenethyl-4-piperidone (NPP) | 2933 37 00 | 39742-60-4 |
| PMK glycidic acid (3-(1,3-benzodioxol-5-yl)-2-methyl-oxirane-2-carboxylic acid) | 2932 99 00 | 2167189-50-4 | |
| The methyl ester of PMK glycidic acid | 2932 99 00 | 13605-48-6 | |
| BMK glycidic acid (2-methyl-3-phenyloxirane-2-carboxylic acid) | 2918 99 90 | 25547-51-7 | |
| The methyl ester of BMK glycidic acid | 2918 99 90 | 80532-66-7 | |
| (1R,2S)-(-)-chloroephedrine | 2939 79 90 | 110925-64-9 | |
| (1S,2R)-(+)-chloroephedrine | 2939 79 90 | 1384199-95-4 | |
| (1S,2S)-(+)-chloropseudoephedrine | 2939 79 90 | 73393-61-0 | |
| (1R,2R)-(-)-chloropseudoephedrine | 2939 79 90 | 771434-80-1 |
2. Criminal offence for deliberate illicit use of DPCs
Section 12 of the 1990 Act makes it an offence to manufacture or supply a DPC if the defendant knew or suspected the substance was to be used in or for the unlawful production of a controlled drug. DPCs are specified in Schedule 2 to the 1990 Act. The 2026 Order adds the following scheduled substances to Schedule 2, meaning that the section 12 offence will now apply to them too, across the whole UK.
| Substance | CN designation (if different) | CN Code | CAS No |
|---|---|---|---|
| 4-AP (N-phenylpiperidin-4-amine) | 2933 39 99 | 23056-29-3 | |
| 1-boc-4-AP (Tert-butyl 4-anilinopiperidine-1-carboxylate) | 2933 39 99 | 125541-22-2 | |
| Norfentanyl (N-phenyl-N-(piperidin-4-yl)propanamide) | 2933 39 99 | 1609-66-1 | |
| 1-boc-4-piperidone | tert-butyl 4-oxopiperidine-1-carboxylate | 2933 39 99 | 79099-07-3 |
| 4-piperidone | Piperidin-4-one | 2933 39 99 | 41661-47-6 |
| MAPA (Methyl alpha-phenylacetoacetate) | 2918 30 00 | 16648-44-5 | |
| APAA (Alpha-phenylacetoacetamide) | 2924 29 70 | 4433-77-6 | |
| APAAN (Alpha-phenylacetoacetonitrile) | 2926 40 00 | 4468-48-8 | |
| N-phenyl-1-(2-phenylethyl)piperidin-4-amine | 4-anilino-N-phenethylpiperidine (ANPP) | 2933 36 00 | 21409-26-7 |
| 1-(2-phenylethyl)-piperidin-4-one | N-phenethyl-4-piperidone (NPP) | 2933 37 00 | 39742-60-4 |
| PMK glycidic acid (3-(1,3-benzodioxol-5-yl)-2-methyl-oxirane-2-carboxylic acid), and its ethyl, methyl, propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl esters | 2932 99 00 | 2167189-50-4 Ethyl ester: 28578-16-7 Methyl ester: 13605-48-6 | |
| BMK glycidic acid (2-methyl-3-phenyloxirane-2-carboxylic acid), and its ethyl, methyl, propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl esters | 2918 99 90 | 25547-51-7 Methyl ester: 80532-66-7 |
The relevant Home Office offence codes are:
| Offence | Code |
|---|---|
| Manufacturing a scheduled substance | 077/50 |
| Supplying a scheduled substance to another person | 077/51 |