DEA Clamps Down on PMK Glycidic Acid Esters for Drug Labs
Published Date: 8/3/2026
Proposed Rule
Summary
The Drug Enforcement Administration is proposing to modify the listing of the list I chemical 3,4-MDP-2-P methyl glycidic acid (also known as PMK glycidic acid) to include esters of 3,4-MDP-2-P methyl glycidic acid, not listed elsewhere in the Controlled Substances Act (CSA), as list I chemicals under the CSA. The current listing of 3,4- MDP-2-P methyl glycidic acid includes its salts, optical and geometric isomers, and salts of isomers. DEA proposes the new listing to read as follows: 3,4-MDP-2-P methyl glycidic acid (PMK glycidic acid) and its esters, not listed elsewhere in the CSA, its optical and geometric isomers, its salts, salts of its optical and geometric isomers, salts of its esters, not listed elsewhere in the CSA, and any combination thereof, whenever the existence of such is possible.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Seven Esters Added to List I
DEA proposes to add esters of 3,4-MDP-2-P methyl glycidic acid (PMK glycidic acid) — specifically the ethyl, propyl, isopropyl, butyl, isobutyl, sec-butyl, and tert-butyl esters — to the List I chemical listing. If finalized, these esters, when not already listed elsewhere in the Controlled Substances Act (CSA), would be treated as List I chemicals and subject to CSA controls upon publication of the final rule.
Registration, Reporting, and Penalties
If finalized, persons who manufacture, distribute, import, or export these esters must obtain DEA registration and comply with recordkeeping, reporting, import/export rules, security requirements, and allow administrative inspections; unauthorized activities may result in civil or criminal penalties. Annual registration fees identified in the proposal are $3,699 for manufacturers and $1,850 for distributors/importers/exporters; DEA proposes a temporary exemption from the registration requirement if a properly completed application is received on or before 30 days after publication of a final rule, but recordkeeping and reporting become effective on the final rule's effective date.
Any Quantity or Mixture Regulated
DEA proposes that chemical mixtures containing any amount of the esters of 3,4-MDP-2-P methyl glycidic acid (not listed elsewhere in the CSA) would not be exempt at any concentration. All transactions of such esters or mixtures, regardless of size or concentration, would be regulated unless a manufacturer obtains a DEA exemption under 21 CFR 1310.13.
Chemical-Mixture Exemption Route Exists
Manufacturers may apply for an exemption of a chemical mixture under 21 CFR 1310.13; DEA may grant an exemption by final rule if it determines the mixture cannot be readily used to make illicit controlled substances and the listed chemical cannot be readily recovered. This provides a formal—but discretionary—path to avoid regulation for mixtures that DEA accepts for exemption.
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Key Dates
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