President Richard Nixon signed the Federal Comprehensive Drug Abuse Prevention and Control Act, better known as the Controlled Substances Act (CSA) in 1970.1 Although the law has three separate titles, the main section is of interest to Title II health care providers, which deals with issues relating to the registration and distribution of controlled substances.2 The overall purpose of the act is to improve production. import and export, distribution and distribution of controlled substances. To achieve this goal, manufacturers, distributors, prescribers, and donors of controlled substances must be registered with the Drug Enforcement Administration (DEA), the implementing authority at the federal level.3,4 DeA registration is essentially a „closed system“ for the distribution of controlled substances that allows products to be traced from first manufacture to final distribution. Such a waiver occurs when the Minister of Health and Human Services has declared a public emergency under 42 U.S.C 247d (Section 319 of the Public Health Services Act), as set out in section 21 U.S.C 802(54)(D). On January 31, 2020, Minister Azar declared such a health emergency regarding COVID-19 (www.hhs.gov/about/news/2020/01/31/secretary-azar-declares-public-health-emergency-us-2019-novel-coronavirus.html. . . .