DEA Form 222 Explained: Ordering & Transferring Schedule I–II Controlled Substances
DEA Form 222 is the official order form you need to legally transfer Schedule I and II controlled substances between registered entities. If you work in a pharmacy, hospital, research facility, or any organization that handles these highly regulated drugs, understanding this form is not optional. One mistake on your paperwork can lead to delays, rejected orders, or problems during a DEA inspection.
DEA Form 222 serves as both an ordering document and a paper trail that tracks every Schedule I and II controlled substance from supplier to purchaser. The form creates a record of who ordered what, how much was ordered, and where it went. This system helps prevent diversion of dangerous drugs into illegal markets.
This guide walks you through everything you need to know about Form 222. You’ll learn why the form exists, when you must use it, who can sign it, and how to fill it out without errors. You’ll also discover what records you need to keep, what inspectors look for, and how to stay compliant with federal regulations.
Why DEA Form 222 Exists
DEA Form 222 exists to track every transfer of Schedule I and II controlled substances between authorized parties and prevent these drugs from entering illegal channels. The Drug Enforcement Administration created this system to maintain a complete record of where these high-risk substances move within the legal supply chain.
The Closed System of Distribution
The Drug Enforcement Administration designed Form 222 to create a closed system of distribution for the most dangerous controlled substances. This means Schedule I and II drugs can only move between DEA-registered entities using official documentation.
The system works by requiring a paper trail for every transaction. When you order these substances, you must use a serially numbered form that the DEA issues directly to your registration. You cannot download or print this form yourself.
The Diversion Control Division uses these forms to monitor the entire supply chain. Each form creates three points of accountability: your order record, the supplier’s fulfillment record, and the DEA’s oversight copy. This structure makes it nearly impossible for controlled substances to leave legitimate channels without detection.
The closed system also limits who can participate in these transactions. Only active DEA registrants with specific authorization to handle Schedule I or II substances can obtain or fill Form 222 orders. This restriction ensures that these drugs stay within a controlled network of vetted manufacturers, distributors, pharmacies, hospitals, and researchers.
When DEA Form 222 Is Required
DEA Form 222 is mandatory for specific controlled substance transactions involving Schedule I and II drugs. You must use this official order form when purchasing these substances from suppliers or transferring them between registered locations.
Purchasing Schedule I–II Controlled Substances
You need DEA Form 222 every time you order Schedule I or II controlled substances from a supplier. This applies to all DEA registrants who are authorized to handle these substance schedules.
The form creates a paper trail for each transaction. You must complete a separate form for each distribution of Schedule I or II controlled substances.
Each form allows up to 20 line items. If you need to order more than 20 items, you must use additional forms. You can only enter one item per numbered line, and that item must consist of commercial or bulk containers of the same substance in the same quantity and form.
You cannot attach itemized lists or supplemental documents to the form. The regulations prohibit this practice to maintain accurate record-keeping.
Transfers, Returns, and Replacements
DEA Form 222 is required when you transfer Schedule I or II controlled substances between registered locations. This includes situations when you terminate your registration, transfer your registration, or discontinue business operations.
You must also use the form when sending controlled substances to a reverse distributor for disposal. The same documentation requirements apply to returns and replacements of these substances.
If you lose or have a stolen DEA Form 222, you must execute a new form and attach a statement with the original form number and date. You need to report lost or stolen forms immediately to your local DEA Diversion Field Office.
Who May Sign and Execute DEA Form 222
Only specific individuals have the legal authority to sign DEA Form 222 for ordering Schedule I and II controlled substances. DEA registrants hold primary signing authority, but they can delegate this responsibility through a properly executed power of attorney.
Authorized Signatories and Power of Attorney
The DEA registrant is the primary individual authorized to sign Form 222. If you are an individual registrant, you can sign the forms yourself. For partnerships, any partner may sign. For corporations, any officer of the corporation can execute the forms using the DEA registration number issued to the company.
You can authorize other individuals to sign DEA Form 222 on your behalf by granting them power of attorney. The person you authorize does not need to be located at your registered location. To create a valid power of attorney, you must follow specific requirements under 21 CFR 1305.05.
The power of attorney form requires three signatures. The registrant (or a partner for partnerships, or an officer for corporations) must sign first. The person receiving the authority must also sign. Two witnesses must sign to validate the document.
You must keep the power of attorney form on file with your executed DEA Forms 222. The form does not get submitted to the DEA, but you must make it available for inspection at any time. You can revoke the power of attorney whenever needed by signing a revocation with two witnesses.
Common Authorization Errors
Signing before completion is a frequent mistake. You should never sign Form 222 before filling out all required information on the form. This creates security risks and compliance issues.
Invalid power of attorney documents cause problems when individuals attempt to sign forms without proper authorization. Missing signatures from any required party makes the power of attorney invalid. Some registrants fail to keep the power of attorney form readily available for inspection, which violates regulations.
Unauthorized individuals signing forms represents a serious violation. Only the DEA registrant or someone with a valid power of attorney can sign. Employees, staff members, or associates cannot sign Form 222 unless they have been granted proper power of attorney through the correct legal process.
Completing DEA Form 222 Correctly
DEA Form 222 requires precise completion and proper execution by authorized signers, with strict requirements for both purchasers and suppliers to maintain compliance with federal regulations.
Required Information and Proper Execution
You must complete sections 1-6 on the official order forms before submitting them to your supplier. Start by entering the supplier’s name and complete address in the designated supplier information section. In the date field, write the current date when you execute the form. The form remains valid for 60 days from this date.
For order details, you can only enter one item per numbered line. Each line must include the number of packages you’re ordering and the size of each package. If you make a mistake on any line, you need to draw a line through it and attach a note explaining the cancellation. You must still count canceled lines when you fill out the “Last Line Completed” section at the bottom of the form.
The purchaser or an individual with valid power of attorney must sign the form. You cannot alter the form in any way or add attachments like itemized lists. If you need to order more than 20 items, you must use additional forms. The order form number appears on each official DEA Form 222 you receive.
Supplier Acceptance and Responsibilities
Your supplier must receive the original DEA Form 222 while you keep a copy for your records. The supplier will verify that all required information is complete and that the form shows no signs of alteration. Any form containing errors will be marked as void and returned to you.
When filling your order, the supplier indicates the number of packages shipped in the designated space for each line item. If you cancel part or all of your order, you must notify the supplier in writing. The supplier then draws a line through canceled items and prints “canceled” in the shipping quantity space on the original form.
Recordkeeping and Retention Requirements
Federal regulations require you to keep DEA Form 222 records for two years and store them separately from your other business documents. You must make these records available to DEA inspectors upon request.
Retention Period and Storage
You must retain DEA Form 222 records for a minimum of two years from the date of execution. As a purchaser, you keep copies of all executed forms. As a supplier, you keep the original forms that you have filled.
The law requires you to store DEA Form 222 records separately from all other business records. This means you cannot mix these forms with invoices, receipts, or other documentation.
If you operate multiple registered locations, you must keep the forms at the specific location printed on each DEA Form 222. You cannot consolidate all forms at a single headquarters or administrative office unless that is the registered location on the form.
Electronic storage is permitted if you can retrieve the forms separately from other records. You can store electronic copies on a system at a different physical location than your registered site, but you must be able to access them quickly at the registered location.
Accessibility During DEA Inspections
DEA inspectors can request to review your DEA Form 222 records at any time during the two-year retention period. You must produce these records immediately when asked.
The forms must be readily retrievable, meaning you can access them within a reasonable timeframe. You cannot delay an inspection by claiming records are stored off-site or need time to locate.
If you supply certain high-risk substances like thiafentanil, carfentanil, etorphine hydrochloride, or diprenorphine, you must maintain those DEA Form 222 records in a separate location from all other Form 222 records. This additional separation helps inspectors quickly review transactions involving these particularly dangerous controlled substances.
Common DEA Inspection Findings
DEA investigators frequently identify two major compliance issues during inspections: forms that contain errors or incomplete information, and records that cannot be located or accessed when requested.
Incomplete or Incorrect Forms
Errors on DEA Form 222 represent one of the most common violations found during inspections. You must complete each form using only a typewriter, computer printer, pen, or indelible pencil. Any erasures, alterations, or changes automatically void the form.
Common errors include:
- Entering multiple items on a single numbered line
- Failing to record the total number of lines completed
- Missing signatures or dates from authorized personnel
- Omitting the supplier’s name and address
- Not documenting the actual number of containers received
- Forgetting to note the date of receipt on Copy 3
You need to list only one item per numbered line with complete details about the substance name, dosage form, strength, package size, and quantity. If you make a mistake, you must keep the voided form and attach a written explanation. The DEA diversion field office expects you to maintain these voided forms as part of your inspection-ready records.
Missing or Unretrievable Records
You must store all DEA Forms 222 separately from your other business records and keep them readily available for at least two years. Inspectors from the DEA diversion field office will request immediate access to these forms, and your inability to produce them constitutes a serious violation.
You must maintain:
- Copy 3 of all executed forms at the registered location printed on the form
- All unexecuted forms in secure storage
- Documentation showing the number of containers received and receipt dates
- Voided forms with explanations attached
If you operate multiple registered locations, you need to keep a copy of each executed form at the specific location shown on that form. You cannot store records at a different address or in a general filing system mixed with other documents. During an inspection, you should be able to retrieve any requested form within minutes.
Best Practices for DEA Form 222 Compliance
Strong internal systems and thorough staff education reduce errors and prevent compliance violations. Proper oversight ensures all Schedule I and II controlled substance orders follow federal regulations.
Internal Controls and Staff Training
You need to designate one person, such as a compliance officer or pharmacist-in-charge, to oversee all Form 222 transactions at your facility. This person should verify that every form is completed accurately before submission and maintain all required records.
Your staff members who handle controlled substances must receive training on proper form completion procedures. They should understand that any alteration, erasure, or change voids the form entirely. Train them to use a typewriter, computer printer, pen, or indelible pencil when filling out forms.
You should establish a monthly reconciliation process to review all Form 222 transactions against your inventory records. This helps you catch discrepancies early and maintain accurate documentation.
Consider implementing CSOS (Controlled Substance Ordering System) as an electronic alternative to paper forms. CSOS reduces common errors associated with manual form completion and provides automatic record-keeping features.
Store all executed and unexecuted forms separately from other business records. You must keep them readily available for DEA inspection for at least two years. Use bound logs or secure digital systems to organize and track all forms by date and supplier.
Frequently Asked Questions
DEA Form 222 comes with specific requirements for obtaining, completing, and using the forms to order Schedule I and II controlled substances. Understanding the proper procedures helps you maintain compliance and avoid processing delays.
How can I obtain a DEA Form 222 for controlled substances ordering?
You receive DEA Forms 222 directly from the Drug Enforcement Administration when they grant you permission to use Schedule I or II controlled substances. The forms arrive in mailing envelopes containing a predetermined number based on your business activity.
The DEA limits the number of forms you can receive based on your registrant activity level. Each form consists of a single sheet designed for ordering controlled substances.
If you need additional forms, you must submit an order form request to the DEA. The agency evaluates your business needs before issuing more forms.
What is the process for filling out DEA Form 222 correctly?
You must prepare and execute DEA Form 222 using a typewriter, computer printer, pen, or indelible pencil. The form requires accurate information to process your order.
You can only enter one item on each numbered line. Each 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 purchaser can fill out no more than twenty line items per form. If you need to order more items, you must use another form.
You must note the number of lines completed at the bottom of the form in the space provided. This helps verify that the order matches the items listed.
Are there specific instructions for completing DEA Form 222 electronically?
DEA Form 222 can be signed electronically when granting power of attorney to authorized individuals. Electronic signatures are permitted for the power of attorney documents under DEA regulations.
You can also use the Controlled Substance Ordering System (CSOS) for electronic order forms. This system provides an alternative to paper DEA Forms 222 for ordering Schedule I and II controlled substances.
The electronic system still requires you to follow the same ordering rules and limitations. You must comply with DEA requirements regardless of whether you use paper or electronic ordering methods.
What types of drugs necessitate the use of DEA Form 222 for their transfer?
DEA Form 222 is required for each distribution of Schedule I or II controlled substances. You must use these forms when ordering any medication classified in these controlled substance categories.
The form requirement also applies when transferring inventory between registrants. Transfers of Schedule I or II controlled substances require order forms when you terminate registration, transfer registration, or discontinue business.
You cannot add attachments or itemized lists to DEA Forms 222. Each controlled substance must be listed individually on the form according to DEA regulations.
Can DEA Form 222 be used for returning controlled substances to the supplier?
DEA Form 222 is designed for ordering and receiving controlled substances, not for returns. The form establishes a record of substances moving from supplier to purchaser.
You can cancel part or all of an order by notifying the supplier in writing. The supplier must indicate the cancellation on the original form by drawing a line through the canceled items and printing “canceled” in the space provided.
If you need to return controlled substances to a supplier, you must follow separate DEA procedures for reverse distribution. Standard DEA Form 222 procedures do not cover return shipments.
What should be done if mistakes are made while completing DEA Form 222?
If you lose or have a stolen DEA Form 222, you must execute another form and attach a statement to the new form. The statement must contain the order form number and date of the lost or stolen form, indicating that you did not receive the goods.
You must keep a copy of the second form and a copy of the statement with a copy of the initial form. The supplier receives a copy of the statement attached to the copy of the second form.
If the supplier finds the first form, they must mark “Not Accepted” on the face and return it to you with the statement attached. You must immediately report the loss or theft of used or unused forms to your local DEA Diversion Field Office.
You need to provide the serial numbers of each lost or stolen order form when reporting to the DEA. If you later recover an unused order form, you must immediately notify your local DEA Diversion Field Office.
