No, you do not need a DEA Form 41 when you destroy your controlled substances with 123 Compliant Logistics. A DEA Form 41 is only needed when you witness the destruction yourself. When you ship your pharmaceuticals to a DEA Reverse Distributor, you are actually transferring your controlled substances (for the purpose of destruction.) 123 Compliant Logistics will provide you a Record of Transfer for your CII-V substances plus a DEA Form 222. These documents fulfill your recordkeeping requirements.