G/TBT/N/EU/921  
12 September 2022  
(22-6690) 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 CC CN where applicable, otherwise national tariff 
heading. ICS numbers may be provided in addition, where applicable):  Chemical 
substances classified as drug precursors  
5. Title, number of pages and language(s) of the notified document:  Draft 
Commission Dele gated 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 certain drug precursors in the list of scheduled substances; (7 
page(s), in English), (3  page(s), in English)  
6. Description of content:  This draft Commission Regulation adds 4 -AP, 1 -boc-4-AP, 
norfentanyl, DEPAPD and PMK ethyl glycidate to Category 1 of the list of scheduled 
substances in Regulation (EC) No 111/2005 laying down rules for the  monitoring of trade 
between the Community and third countries in drug precursors.  
Operators engaged in import, export or intermediary activities involving scheduled 
substances listed in Category 1 of the Annex have the obligation to hold a licence. Special 
labelling requirements apply for any packaging containing these substances according to 
Article 5 of the Regulation.  
7. Objective and rationale, including the nature of urgent problems where 
applicable:  4-AP is a substitute chemical for N -phenethyl -4-piperidone (NPP) to 
synthesize 4 -anilino -N phenethylpiperidine (ANPP), which itself is an immediate precursor 
for the manufacture of fentanyl and some of its analogues.  
1-boc-4-AP is a chemically protected derivative of 4 -AP, which could be co nverted to 4 -
AP, norfentanyl or a number of norfentanyl analogues.  G/TBT/N/EU/921  
 
- 2 - 
 
  Norfentanyl is an immediate precursor of fentanyl and a number of fentanyl analogues.  
DEPAPD is used to produce 1 -Phenyl -2-propanone (P -2-P), also known as benzyl methyl 
ketone (BMK). BMK i s a precursor of amphetamine and methamphetamine.  
PMK ethyl glycidate is a precursor of 3,4 -Methylenedioxyphenyl propan -2-one (PMK), 
which, in its turn, is used to produce 3,4 -methylenedioxymethamphetamine (MDMA), 
commonly known as 'ecstasy'. The use of th e drugs: fentanyl, amphetamine, 
methamphetamine and ecstasy, is causing serious social and public health problems in 
some regions of the Union. As there is no known legal use for 4 -AP, 1 -boc-4-AP, 
norfentanyl, DEPAPD and PMK ethyl glycidate except for rese arch purposes, their inclusion 
in Category 1 of drug precursors in Regulation (EC) No 111/2005 is appropriate to address 
those risks, and any additional restriction on trade is justified by the objectives pursued. 
; Protection of human health or safety  
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:  Autumn 2022 
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 
above mentioned substances except research is known, no transitional perio d 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/2022/TBT/EEC/22_6034_00_e.pdf  
https://members.wto.org/crnattachments/2022/TBT/EEC/22_6034_01_e.pdf