{
  "schema": "upg.factor.v1",
  "id": "ptce/federal/dea-inventory",
  "exam": [
    "PTCE"
  ],
  "domain": "Federal Requirements",
  "title": "DEA controlled-substance inventory (initial + biennial)",
  "claim": "Under 21 CFR 1304.11, a DEA registrant must take an initial inventory of all controlled substances on hand when first engaging in manufacture/distribution/dispensing, then a new inventory at least every two years (biennial). For opened commercial containers, dispensers must make an exact count/measure for Schedule I or II, and may estimate Schedule III–V unless the container holds more than 1,000 tablets or capsules (then exact count).",
  "plain": "Initial inventory when you start, then at least every 2 years. Opened C-I/II = exact count; opened C-III–V = estimate unless >1,000 tabs/caps.",
  "confidence": 0.98,
  "citations": [
    {
      "authority": "21 CFR 1304.11",
      "url": "https://www.ecfr.gov/current/title-21/chapter-II/part-1304/section-1304.11",
      "pin": "1304.11(b)–(c)",
      "retrieved_at": "2026-09-08",
      "quote": "Every person required to keep records shall take an inventory of all stocks of controlled substances on hand on the date he/she first engages in the manufacture, distribution, or dispensing of controlled substances ... After the initial inventory is taken, the registrant shall take a new inventory of all stocks of controlled substances on hand at least every two years."
    },
    {
      "authority": "21 CFR 1304.11",
      "url": "https://www.ecfr.gov/current/title-21/chapter-II/part-1304/section-1304.11",
      "pin": "1304.11(e)(6)",
      "retrieved_at": "2026-09-08",
      "quote": "If the substance is listed in Schedules I or II, make an exact count or measure of the contents; or if the substance is listed in Schedule III, IV, or V, make an estimated count or measure of the contents, unless the container holds more than 1,000 tablets or capsules in which case he/she must make an exact count of the contents."
    }
  ],
  "updated_at": "2026-09-08",
  "token_cost_hint": 220,
  "integrity": "practice_only",
  "html": "/factors/ptce/federal/dea-inventory",
  "json": "/factors/ptce/federal/dea-inventory.json"
}