If you sell controlled substances to another pharmacy, physician, or terminal distributor, what must you do?

• A. All distributors must report to the state board.
• B. No registration is required for wholesale distribution.
• C. DEA registration is required only for controlled substances.
• D. You must register as a wholesale distributor.

Answer: (D)

Selling controlled substances to other registrants places you in the role of a wholesaler, and that requires a DEA registration specifically as a wholesale distributor. This federal registration authorizes you to distribute controlled substances to pharmacies, physicians, or terminal distributors and ties you to strict recordkeeping, security, and reporting requirements designed to maintain oversight and prevent diversion. Without this registration, such wholesale distribution would be illegal. The idea that no registration is needed, or that registration only applies to some substances or to state boards, doesn’t match how the system regulates controlled substances; you must have the appropriate DEA registration to engage in any wholesale distribution of these drugs.