DEA Form 222 is the federal order form that every DEA registrant must use to purchase or transfer Schedule I or Schedule II controlled substances between registrants. No Schedule I or II substance can lawfully change hands without either a completed Form 222 or its electronic equivalent through the Controlled Substance Ordering System.1Office of the Law Revision Counsel. 21 USC 828 – Order Forms The form creates an auditable paper trail from supplier to purchaser, and small mistakes on it are one of the most common triggers for a DEA compliance action.
When You Need a Form 222
The form applies only to Schedule I and Schedule II substances. That covers Schedule I research chemicals and Schedule II drugs like oxycodone, fentanyl, morphine, methylphenidate, and amphetamine salts. Schedule III, IV, and V substances do not require a Form 222; they can be ordered on a standard purchase order or invoice, though you still have to keep readily retrievable records of what came in and when.2eCFR. 21 CFR Part 1305 Subpart B – DEA Form 222
Three substances get special treatment. Orders for carfentanil, etorphine hydrochloride, and diprenorphine must appear on forms containing only those substances, with no other Schedule II drugs mixed in.3eCFR. 21 CFR 1305.12 – Procedure for Executing DEA Forms 222
How to Get Order Forms From the DEA
You cannot download, photocopy, or print a Form 222 anywhere. The DEA issues them directly, and each single-sheet form arrives pre-printed with a unique order form number along with your name, address, DEA registration number, authorized activity, and authorized schedules. None of that pre-printed information can be altered. If any of it is wrong, the fix is to correct the underlying registration through your local DEA Division Office or the Registration Section.4eCFR. 21 CFR 1305.11 – Procedure for Obtaining DEA Forms 222
To be eligible, you need an active DEA registration authorizing you to handle Schedule I or II substances. Once registered, you request forms through the DEA’s secured network connection or by contacting a Division Office or the Registration Section through the customer service center. The DEA caps how many forms it will send per request based on your business activity, and you have to demonstrate need to receive more.4eCFR. 21 CFR 1305.11 – Procedure for Obtaining DEA Forms 222
Filling Out the Form
Prepare the form using a typewriter, computer printer, pen, or indelible pencil. Enter the name and address of the supplier. Only one supplier per form.3eCFR. 21 CFR 1305.12 – Procedure for Executing DEA Forms 222
Each numbered line takes exactly one item. An “item” means one or more containers of the same finished or bulk form, quantity, and substance. On each line, list the drug name, dosage form, strength, package size, and number of packages. At the bottom of the form, write the total number of lines you completed. That number blocks anyone from adding lines later. Sign and date the form. Only the registrant or someone with a current Power of Attorney on file can sign.3eCFR. 21 CFR 1305.12 – Procedure for Executing DEA Forms 222
There is no correction process. A single alteration, erasure, or illegible entry voids the form. If a form is defective, you execute a new one from scratch.
Authorizing Someone Else to Sign
A registrant does not have to sign every form personally. You can authorize one or more individuals to sign on your behalf by executing a Power of Attorney for each person. The POA must be signed by the registrant (or a partner if a partnership, or an officer if a corporation or other entity), the person receiving the authority, and two witnesses.5eCFR. 21 CFR 1305.05 – Power of Attorney
Follow the format in the regulation. The document has to include the registrant’s name, address, and DEA registration number, along with the names of both the person granting authority and the attorney-in-fact. Keep the executed POA in your files for the same retention period as any order the attorney-in-fact signs. You can revoke a POA at any time by executing a written notice of revocation.5eCFR. 21 CFR 1305.05 – Power of Attorney
Submitting the Order and What the Supplier Does
Before sending, make a copy of the form for your records. Paper or electronic is fine. Then send the original single-sheet form to the supplier. The substances must be shipped only to the purchaser at the registered address printed on the form by the DEA.6eCFR. 21 CFR 1305.13 – Procedure for Filling DEA Forms 222
The supplier records their DEA registration number on the original form, the number of commercial or bulk containers shipped for each line item, and the date shipped. The supplier keeps the original. Suppliers who are not required to report through the Automation of Reports and Consolidated Orders System (ARCOS), such as practitioners, must also send a copy of the form to the DEA by the close of the month in which the order was filled. Larger distributors and manufacturers reporting through ARCOS satisfy their reporting obligation that way.6eCFR. 21 CFR 1305.13 – Procedure for Filling DEA Forms 222
When the shipment arrives, record on your retained copy the number of containers actually received and the date of receipt. That closes the loop.
The 60-Day Window and Partial Shipments
A Form 222 is valid for 60 days from the date the purchaser signs it. After that the supplier cannot fill it. Partial shipments are allowed, but every shipment must occur within the same 60-day window. The supplier notes each partial shipment on the original and forwards its copy to the DEA at the close of the month when either the final shipment goes out or the 60-day period expires, whichever comes first.6eCFR. 21 CFR 1305.13 – Procedure for Filling DEA Forms 222
Defective Forms, Cancellation, and Endorsement
A supplier is prohibited from filling a form that is incomplete, illegible, improperly prepared, or that shows any alteration, erasure, or change. The supplier returns the original to you with a written statement explaining why it was rejected. Keep both. Execute a new form to place the order again. A supplier who declines an order for business reasons still has to provide a statement that the order is not accepted.7eCFR. 21 CFR 1305.15 – Unaccepted and Defective DEA Forms 222
To cancel all or part of a submitted order, notify the supplier in writing. The supplier marks the cancellation on the original by drawing a line through the canceled items and writing “canceled” in the space for the number of items shipped.8eCFR. 21 CFR 1305.19 – Cancellation and Voiding of DEA Forms 222
If a supplier receives your form but cannot fill some or all of it within the 60-day window, that supplier can endorse the form to a second supplier. The endorsement must include the second supplier’s DEA number and must be signed and dated by someone authorized to sign for the first supplier. Once endorsed, the first supplier cannot fill any part of the order. The second supplier ships directly to you and reports the distribution the same way it would report any other.9eCFR. 21 CFR 1305.14 – Procedure for Endorsing DEA Forms 222
Lost or Stolen Forms
If a used or unused form is stolen or lost (other than during normal mail transmission), report it immediately upon discovery to the Special Agent in Charge of the DEA Divisional Office responsible for your area. Include the serial number of each missing form. If you do not have the serial numbers, a purchaser should provide the date or approximate date the forms were issued; a supplier should provide the approximate date of receipt and the names and addresses of the purchasers whose forms are missing. If a form reported stolen or lost later turns up, notify the same Divisional Office.10eCFR. 21 CFR 1305.16 – Lost and Stolen DEA Forms 222
An unfilled form lost in transit to the supplier is handled differently. Execute a new form and attach a statement noting the order form number and date of the lost form, plus confirmation that you did not receive the goods. Keep copies of the new form and the statement with a copy of the original. If the supplier eventually receives the lost original, the supplier writes “Not accepted” on it and returns it to you.10eCFR. 21 CFR 1305.16 – Lost and Stolen DEA Forms 222
Recordkeeping
All Forms 222 (executed, unexecuted, or defective) must be kept separate from your other business records and available for inspection for at least two years.11GovInfo. 21 CFR 1305.17 – Preservation of DEA Forms 222 If you have multiple registered locations, keep each executed form at the registered location printed on it. Blank forms can be stored elsewhere.
Purchasers keep a copy of every executed form plus all unaccepted or defective forms with their attached statements. Suppliers keep the original of each form they filled. Purchaser copies can be stored electronically and still count as “maintained separately” as long as they remain readily retrievable apart from your other records. Electronic copies may sit on a system at a different physical location, provided they remain readily retrievable at the registered location.12eCFR. 21 CFR Part 1305 Subpart B – DEA Form 222 – Section 1305.17
Some states impose longer retention periods than the federal two-year floor, ranging from three to seven years depending on the jurisdiction. Check your state pharmacy board or controlled substances authority.
Returning Unused Forms When Registration Ends
If your registration terminates for any reason (death of the registrant, business ceasing to exist, discontinuing practice, or a name or address change), you must return all unused Form 222 books to the DEA Registration Section. Same rule if your registration is suspended or revoked for all Schedule I and II substances.13eCFR. 21 CFR 1305.18 – Return of Unused DEA Forms 222
The Electronic Alternative: CSOS
The Controlled Substance Ordering System is the electronic alternative to paper Form 222. It is not mandatory; the DEA has kept the paper process available and registrants are not required to switch. CSOS eliminates most of the recurring paper problems: transposed drug codes, unsigned forms, mail delays, and the line-item ceiling of a physical sheet.
To use CSOS you need a digital certificate issued through the DEA’s Certification Authority. Applicants must be a registrant, a coordinator, or a person with Power of Attorney authorization. Enrollment happens online at www.deaecom.gov: complete identity-proofing, list the DEA registrations you are authorized to sign for, and upload any applicable POA forms.14eCFR. 21 CFR 1311.25 – Requirements for Obtaining a CSOS Digital Certificate After identity and employment verification, the DEA sends a one-time reference number and access code through separate channels, which you use to request certification of your public digital signature key.
CSOS uses Public Key Infrastructure to make every order authenticated, tamper-evident, and non-repudiable. Access to your private signing key requires a password or biometric authentication, the system locks after 10 minutes of inactivity, backup copies of the private key are prohibited, and the key must sit on a FIPS-approved secure device. If your private key or password is lost, stolen, or compromised, submit a revocation request to the Certification Authority within 24 hours of confirming the problem. Both parties retain electronic order records for two years, the same period as paper.15eCFR. 21 CFR Part 1311 – Requirements for Electronic Orders and Prescriptions
Penalties for Non-Compliance
Federal law makes it unlawful to refuse or negligently fail to make, keep, or furnish any record or order form required under the Controlled Substances Act. For recordkeeping and order form violations specifically, the civil penalty caps at $10,000 per violation.16Office of the Law Revision Counsel. 21 USC 842 – Prohibited Acts B
If the government prosecutes a violation as knowing and intentional and proves that at trial, the exposure becomes criminal. A first knowing offense carries up to one year of imprisonment, a fine, or both. A repeat knowing offense after a prior conviction for a controlled-substance-related crime raises the maximum to two years. Non-knowing violations remain civil only and do not create a criminal record or any legal disability from a criminal conviction.16Office of the Law Revision Counsel. 21 USC 842 – Prohibited Acts B
Beyond fines and imprisonment, persistent recordkeeping failures put the DEA registration itself at risk. The agency weighs compliance history when deciding whether to renew, suspend, or revoke a registration, and a pattern of sloppy Form 222 handling is the kind of evidence that surfaces in revocation proceedings.