G/TBT/N/EU/1023  
26 October 2023  
(23-7227) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  English  
 
  
NOTIFICATION  
The following notification is being circulated in accordance with Article 10.6  
 
1. Notifying Member:  EUROPEAN UNION  
If applicable, name of local government involved (Article 3.2 and 7.2):   
2. Agency responsible:   
European Commission  
Name and address (including telephone and fax numbers , email and website 
addresses, if available) of agency or authority designated to handle comments 
regarding the notification shall be indicated if different from above:   
European Comm ission,  
EU-TBT Enquiry Point,  
Fax: +(32) 2 299 80 43,  
E-mail: grow-eu-tbt@ec.europa.eu  
Website: http://ec.europa.eu/growth/tools -databases/tbt/en/  
3. Notified under Article 2.9.2 [X], 2.10.1 [  ], 5.6.2 [  ], 5.7.1 [  ], 3.2 [  ], 7.2 [  ], 
other :  
4. Products covered (HS or CCCN where applicable, otherwise national tariff 
heading. ICS numbers may be provided in addit ion, where applicable):  Chemical 
substances classified as drug precursors.  
5. Title, number of pages and language(s) of the notified document:  Draft 
Commission Delegated Regulation amending Regulation (EC) No 273/2004 of the 
European Parliament and of the  Council and Council Regulation (EC) No 111/2005 as 
regards the inclusion of the drug precursor isopropylidene (IMDPAM) and other 
substances in the list of scheduled substances; (6 page(s), in English), (3 page(s), in 
English)  
6. Description of content:  This draft Commission Regulation adds isopropylidene 
(IMDPAM) and certain esters of two scheduled substances to Category 1 of the list of 
scheduled substances in Regulation (EC) No 111/2005.  
Operators will have the obligation to hold a licence for category 1. They will also have 
special labelling requirements for any packaging containing this substance according to 
Article 5 of the Regulation.  
7. Objective and rationale, including the nature of urgent problems where 
applicable:  IMDPAM is a pre -precursor in the production of MDMA. The use of these 
drugs poses significant risk to human health. The identified esters of the two already 
scheduled substances can easily replace them in the illicit manufacture of drugs. As there 
is no known legal use for IM DPAM and the respective esters, their inclusion in Category 1 
of drug precursors in Regulation (EC) No 111/2005 is not expected to have an impact on 
trade; Protection of human health or safety  G/TBT/N/EU/1023  
 
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  8. Relevant documents:   
Article 12 of the UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic 
Substances of 19.12.1988;  
Council Regulation (EC) No 111/2005 laying down rules for the monitoring of trade 
between the Union and third countries in drug precursors . 
http://eur -lex.europa.eu/legal -
content/EN/TXT/?qid=1426599802066&uri=CELEX:32005R0111  
9. Proposed date of adoption:  January 2024  
Proposed date of entry into force:  The provisions will enter into force and apply 20 
days after their publication in the Official Journal of the EU. Given that no legal use for 
IMDPAM except research is known, no transitional period is envisaged.  
10. Final date for comments:  60 days from notification  
11. Texts available from:  National enquiry point [ ] or address, telephone and fax 
numbers and email and website addresses, if available , of other body:   
European Commission,  
EU-TBT Enquiry Point,  
Fax: + (32) 2 299 80 43,  
E-mail: grow-eu-tbt@ec.europa.eu  
The text is available on the EU -TBT Website : http://ec.europa.eu/growth/tools -
databases/tbt/en/  
https://members.wto.org/crnattachments/2023/ TBT/EEC/23_13173_00_e.pdf  
https://members.wto.org/crnattachments/2023/TBT/EEC/23_13173_01_e.pdf