In addition, the MCA effects controls on domestic transactions of hydrogen chloride gas. The MCA modifies the exemption for legal drug products which contain either ephedrine, pseudoephedrine or phenylpropanolamine. Whereas the removal of the exemption for ephedrine combination products was effective upon signing of the MCA, most transactions involving legal drug products containing pseudoephedrine and phenylpropanolamine remained exempt through October 3, 1997. This exemption has now expired. The threshold remains zero for ephedrine products which do not contain another active ingredient.
Thresholds differ according to the individual chemical.
This 24 gram threshold is a non-cumulative threshold. Most provisions of the MCA will not significantly impact businesses that are currently registered with the DEA as a retail pharmacy. The DEA has provided an exemption for current Controlled Substance Act registrants in 21 CFR 1309.25. Retail pharmacies will not be required to obtain a separate DEA chemical registration since they are already a controlled substance registrant. However large unexplained losses of prescription products should be reported.