Dichloralphenazone (DCP) is a preparation which contains chloral hydrate, which by definition makes it a Schedule IV controlled substance (21 CFR 1308.14(c)). There has been some confusion within industry as to the scheduling of DCP. DCP is not, at this time, subject to the registration, recordkeeping, storage and security requirements of a Schedule IV controlled substance.

DEA is preparing a Federal Register notice making DCP subject to all registration, storage, security and recordkeeping requirements for a Schedule IV controlled substance. This Federal Register notice will establish controls for DCP and a timetable for their implementation. Persons currently involved with the legal manufacture, distribution, import, export or dispensing of this substance are not expected to comply with Schedule IV regulation until such time that notice is given in the Federal Register. Until this notice is published, DCP is not subject to any Schedule IV requirements.

Persons manufacturing, distributing, importing, exporting and dispensing DCP are not required to handle DCP as a Schedule IV controlled substance at this time, regardless of the labeling of the package. However, a DEA registrant may choose to handle DCP as a Schedule IV controlled substance prior to the publication of the Federal Register notice at its discretion.

If you have further questions, please feel free to contact the Liaison and Policy Section of the Office of Diversion Control at (202) 307-7297.

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