Controlled Substances: Sales Pursuant to an Order

A fact sheet is a plain-language explanation of the legislation that forms the foundation of certain pharmacy practices. It provides useful information and references to help pharmacy professionals understand a particular topic. A fact sheet is an informational resource and is not considered legal advice. Always refer to the legislation for full context. 

Legislative References 

• Controlled Drugs and Substances Act, 1996
  • Controlled Substances Regulations 

Additional References 

• College By-Law No. 7
• Fact Sheet – Controlled Substances: Purchase & Sales Record Fact Sheet
• Fact Sheet – Controlled Substances: Destruction of Unserviceable Stock and Post-Consumer Returns Fact Sheet 
• Controlled Substances: Prescription Regulation Summary Chart 

Definitions 

Controlled substance: A substance set out in Schedules I, II, III, IV, or Part 1 of V of the federal Controlled Drug and Substances Act, 1996 (CDSA).  This resource specifically applies to the controlled substances named in Schedule 1 (narcotics), Schedule 2 (controlled drugs) and Schedule 3 (targeted substances) under the Controlled Substances Regulations. 

Licensed Dealer: An individual or organization holding a dealer’s licence issued by the federal Minister of Health to conduct activities (i.e., produce, package, sell, provide, send, transport, deliver, import, export, or destroy) the controlled substances specified in their licence. (CSR s 12(1)) 

Order: A written or verbal request to sell or provide a controlled substance, other than pursuant to a prescription. (CSR s 1(1)) 

Practitioner: A physician, dentist, veterinarian, midwife, nurse practitioner, or podiatrist. (CDSA s 2(1), CSR s 1(3)) 

Prescription: An authorization given by a practitioner that a stated amount of a controlled substance be sold or provided for the individual named or the animal identified in it. (CSR s 1(1)) 

Provide: To give, transfer or otherwise make available directly or indirectly, whether or not the provision is made for consideration. (CDSA) 

Sell: To offer or have in possession for sale and distribute, whether or not the distribution is made for consideration. (CDSA) 

Background 

Controlled substances are regulated federally by Health Canada and the Office of Controlled Substances (OCS). The Controlled Drugs and Substances Act (CDSA) provides a legislative framework aimed at controlling access to substances that can alter mental processes and produce harm to the health of an individual and/or society when diverted or misused. 

The Controlled Substances Regulations (CSR) govern the sale and provision of controlled substances by pharmacists to other regulated parties (i.e., Licensed Dealers, hospitals, practitioners, and other pharmacists) pursuant to an order. This fact sheet is limited to these transactions and does not address the sale of controlled substances pursuant to a prescription (i.e., dispensing). 

Important notes: 

• Although the regulations use the terms “sell” and “provide” together, for simplicity, this fact sheet uses only “sell” to mean either of these, whether or not there is payment involved.
• Pharmacy professionals working in a hospital must follow the legislation pertaining to hospitals
• Where “hospital” is used, it meant a person permitted to place an order on the hospital’s behalf. 

Signing Authority 

• A pharmacist is authorized to sign orders for controlled substances.
• In a hospital, the person in charge designates a pharmacist who is permitted to sign orders for controlled substances.
• Controlled substances cannot be ordered by a pharmacist or practitioner who has terms, conditions or limitations (TCLs) imposed on their certificate of registration prohibiting them from ordering or possessing controlled substances.
• Access the appropriate College’s public register and check for TCLs 

Orders 

Orders are required before controlled substances can be sold and must specify: 

• The name of the pharmacist, hospital, or practitioner (and title, if applicable) placing the order
  • Their name and municipal address of their place of practise
• The name of the licensed dealer, pharmacist, or hospital (and title, if applicable) fulfilling the order
  • Their name and municipal address
• The name, form and quantity of the controlled substance 

The following information may be required in certain situations; refer to the legislative reference provided for the type of sale: 

• Brand name
• Strength
• Drug identification number (DIN)
• The number of containers and units per container ¹

Orders must be written (W), signed and dated by whomever is placing the order. 

• If the signature on the order if it is not known, it must be verified along with the person’s name (and title, if applicable).
• In an emergency, a verbal order (V) may be transcribed, signed and dated. 

Sales Permitted (Pursuant to an Order) 

Licensed Dealers may sell to: 

• Pharmacists (W), s 57
• Hospitals (W), s 59 

Pharmacists may sell to: 

• Licensed dealers specialized in destruction:
  • for destruction of post-consumer returns (W), s 92(1)(a)
• Licensed dealers that sold them the controlled substance: 
  • for return and/or destruction of unserviceable stock (W), s 92(1)(b) 
• Other pharmacists:
  • For emergency purposes² (W or V), s 93(1)
  • When providing central fill services³ (W), s 93(2)
  • When their pharmacy is permanently closing (W), s 93(2)
• Practitioners (W), s 94
  • For emergency purposes (W or V), s 94
  • For office use (W), s 94 
• Hospitals (W), s 95
  • For emergency purposes (W or V), s 95
  • For hospital use (W), s 95 

Hospitals may sell to: 

• Licensed dealers specialized in destruction:
  • For destruction of post-consumer returns (W), s 158(1)(a)
• Licensed dealers that sold them the controlled substance: 
  • For return and/or destruction of unserviceable stock (W), s 158(1)(b) 
• Pharmacists: 
  • For emergency purposes ² (W or V), s 160 
• Other hospitals:
  • For emergency purposes ² (W or V), s 161(1)
  • When their hospital is permanently closing (W), s 161(2) 

Published: October 2026
Version #: 3.1 

Revision History

Version #	Date	Action
1.0	August 2012	Published as “Narcotic Purchases”
2.0	October 2021	Changed title to Controlled Substances – Orders, Purchases & Sales (Federal)Inclusive of all controlled substances and hospitals. Added Health Canada notice of restriction
2.1	March 2022	Added emergency transfer note from Health Canada Guidance Document
2.2	March 2023	Minor content update from revised Health Canada Guidance Document
3.0	December 2024	Updated to reflect removal of controlled substance (“narcotic”) signers from OCP By law No.7. The College will no longer gather or post this information on the public register.
3.1	October 2026	Revised to reflect Controlled Substances Regulations coming into effect.

¹ Health Canada will accept “total quantity” when the number of containers (which is based on the units per container) are not known (CS-GD-022).

² Order must also include a declaration that the controlled substance is required for emergency purposes.

³ Orders for the purpose of fulfilling a prescription received at the other pharmacy, referred to a Central Fill agreement in Ontario, must also include the number assigned to the prescription, if applicable.