Controlled Substances Management for Vessels
Vessels engaged in international trade, or in trade between US ports, may carry controlled substances only if those drugs are acquired and dispensed under the general supervision of a DEA-registered medical officer. We provide that officer, the registration structure, the recordkeeping and the annual reports, so your fleet stays compliant without hiring a physician in-house.
Who this applies to
Under 21 CFR 1301.25(a), controlled substances may be held for stocking, maintained in, and dispensed from medicine chests, first aid packets, or dispensaries on board:
- Any vessel engaged in international trade, or in trade between ports of the United States
- Any merchant vessel belonging to the US Government
- Any other entity of fixed or transient location approved by the DEA Administrator, for example emergency kits at industrial field sites
If your vessels carry Schedule II-V medications, this regulation governs how you acquire, store, dispense, document and dispose of them. It is not optional, and it is not covered by your telemedicine provider unless they hold the registration.
The medical officer requirement
Under 21 CFR 1301.25(b), a medical officer must satisfy all three conditions:
Two reports, two different clocks
Two separate annual reports exist in this regulation. Most operators know about neither, and they run on different clocks.
Frequently asked questions
Controlled substances must be dispensed under the general supervision of a medical officer who is a state-licensed physician, employed by the vessel’s owner or operator, and DEA-registered under 21 CFR 1301.25(a)-(b). The medical officer need not be physically present, provided the person dispensing is responsible to that officer and can justify their actions.
No. The registration attaches to the medical officer, held at the principal office of the owner or operator, or at another location provided the DEA Form 223 details are kept at the principal office in a readily retrievable manner, per 21 CFR 1301.25(b)(3).
Yes, under a single registration, provided all vessels share one owner or operator. If the officer serves more than one owner or operator, they must maintain a separate registration at each owner’s principal office, or use the Form 223 documentation route, per 21 CFR 1301.25(c).
The master or first officer may purchase controlled substances directly, without being registered, by personally appearing at the vendor with photographic identification and a written requisition on the vessel’s official stationery containing the vessel’s official number, country of registry, owner or operator, and port, per 21 CFR 1301.25(d).
Copy 2 of the vendor’s record of sale must be furnished to the vessel’s officer and retained aboard the vessel. Copy 3 goes to the nearest DEA Division Office within 15 days after the end of the month of sale, per 21 CFR 1301.25(d)(3).
No. Owners and operators are not deemed to import or export controlled substances purchased and stored in accordance with 21 CFR 1301.25(g), read with Article 32 of the Single Convention on Narcotic Drugs (1961) and Article 14 of the Convention on Psychotropic Substances (1971).
Last reviewed: July 2026
2. 21 CFR Part 1317 — Disposal.
3. Single Convention on Narcotic Drugs, 1961, Article 32.
4. Convention on Psychotropic Substances, 1971, Article 14.
5. Amendment history: 62 FR 13951 (1997); 79 FR 53561 (2014); 84 FR 68342 (2019).
