An uncontrolled MDMA precursor has turned up in 154 international incident reports since 2021, and the DEA proposes to control it along with six chemical relatives
104 metric tons.
That is the quantity of one uncontrolled chemical recorded in 154 reports to the Precursors Incident Communication System since 2021, and it appears in a notice of proposed rulemaking the Drug Enforcement Administration filed for public inspection on Friday morning. The chemical is the ethyl ester of PMK glycidic acid. Its close relative the methyl ester has been a list I chemical in the United States since May 2021, and in the thirteen years since 2013 that one has produced 79 reports and a little over 28 metric tons. The uncontrolled version passed it in five years, by volume and by count, and DEA now proposes to rewrite the listing so that it and six further esters come inside the Controlled Substances Act.
The mechanism is a single line of regulatory text. Entry 35 in the table of substances covered at 21 CFR 1310.02 currently reads for PMK glycidic acid, its optical and geometric isomers, its salts, and salts of those isomers. The proposal adds four words to it: and its esters, not listed elsewhere in the CSA. Seven are then named in full, ethyl, propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl, each with its systematic name written out.
The route through Vienna
This did not begin in Washington. The Commission on Narcotic Drugs voted at its 67th session on 19 March 2024 to put the seven esters into Table I of the 1988 United Nations convention on drug trafficking, and the Secretary-General notified the United States by letter dated 6 June 2024 under Article 12 of that convention. A second letter, dated 9 June 2025 and following the 68th session, moved PMK glycidate itself out of the body of Table I and into a footnote as the methyl ester, leaving its control status alone. Article 12 obliges a party to take measures it considers appropriate once it is notified. DEA states that amending the listing is how the United States meets that obligation.
The agency's own account of why is blunter. Clandestine laboratory operators, it writes, responded to controls on MDMA precursors by making their own precursors and diverting other chemicals to produce them, and the International Narcotics Control Board found the seven esters "highly suitable for the illicit manufacture of 3,4-MDP-2-P." They substitute for one another in the same synthetic route.
Where it comes from
The incident data carries a geography. Of the 86 ethyl-ester reports that named an origin country, China was named in 77. Of the 53 methyl-ester reports that named one, China was named in 37, and of the 20 salt reports, 17. In all three sets the majority of the incidents themselves were logged in the Netherlands. DEA queried the system on 24 March 2026.
Supply is not clandestine either. The agency states that the ethyl ester is now readily available from commercial chemical suppliers, and that it has identified potential suppliers in the United States, China, France, the United Kingdom and Hong Kong. It puts the number of domestic suppliers of one ester at 14, while adding that chemical distributors often carry an item in a catalogue without any material level of sales.
No threshold, no concentration floor
Two design choices give the proposal its reach. The rulemaking sets no threshold, so every transaction would be regulated regardless of size under 21 CFR 1310.04(g). And chemical mixtures containing any amount of the esters would not be exempt at any concentration, which DEA justifies by the absence of a legitimate industrial use and the risk of extraction. A manufacturer wanting relief has to apply for an exemption and wait for DEA to grant it.
Registration follows, with the fees stated: $3,699 a year for a manufacturer, $1,850 for a distributor, importer or exporter. DEA expects the few legitimate suppliers to stop selling rather than pay, and estimates the cost of those foregone sales as minimal. The Administrator certified that the rule would not have a significant economic impact on a substantial number of small entities. Handlers who file a complete registration application within 30 days of a final rule would get a temporary exemption from the registration requirement alone, at 21 CFR 1310.09, while recordkeeping, reporting, security and inspection obligations start on the effective date regardless.
DEA says it has found no known legitimate use for these esters beyond small research and laboratory quantities, and that it cannot rule out minimal amounts going into legitimate 3,4-MDP-2-P. It asks for comment on exactly that. The document was signed on 28 July by Administrator Terrance C. Cole. Comments close 30 days after publication.