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Did you completely ignore the "face to face" relationship in the DEA guidance I posted above? It is in federal law. ...
We need a little lesson in what is law ...
The simple reply is No! The DEA posted that Policy Statement in the Federal Register. That was NOT a Rulemaking and it does not have the force of law as would be the case if they did a rulemaking under the provisions of the Administrative Procedures Act ... where they publish a Notice of Proposed Rulemaking which solicits comments, Final Rule, etc., which puts it in the CFR. The DEA Policy Statement that Billyl refers to is most definitely *not* law in any way, shape, or form.
The only venue in which it could be considered "pseudo-law" would be a DEA administrative hearing on a practitioner's license to dispense controlled substances. The Administrative Law Judge (or Hearing Officer) could base a licensing decision on whether that policy statement was followed. That would be a decision on revoking a *privilege* that can be rescinded by DEA with due process within their own system of hearings. The DEA Policy Statement in question cannot be used to prosecute anyone with a criminal charge in a federal (or state) court.
Under the Commerce Clause, DEA would probably have an indisputable *right* to make that policy into law. But they have done nothing in that direction and they would have to do a formal rulemaking, though the DEA Administrator could probably implement it into law for a 30-day period with an Emergency Order.
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Re: New OP in R&D phase consider CII's
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Re: New OP in R&D phase consider CII's