Letter of no objection (LONO) for a particular substance
The legislation on narcotics and/or psychotropic substances differs between the different countries. Please find below some examples.
- Substances that are listed as narcotic or psychotropic substance in the import or export country, but not in Belgium.
In this case, no Belgian import or export authorisations are required. The foreign company must however observe its national legislation. For this reason export to Belgium may still require a prior import authorisation for a substance or preparation that in Belgium is not subject to legislation on narcotics and/or psychotropic substances. In such a case, a LONO can be issued by the FAMHP confirming that a particular substance/preparation is not subject to legislation on narcotics and/or psychotropic substances and that there is no objection to its import or export.
- Substances listed in Belgium as narcotic or psychotropic substance but not in the import or export country.
Make sure that you always work in accordance with Belgian legislation and have the necessary import or export authorisations.
When requesting an export authorisation, no foreign import authorisation will usually be available for this substance. In this case, a LONO must be included for this substance, issued by the foreign authorities and stating that nationally this substance is not certified as a narcotic or a psychotropic substance and that there is no objection to importing it into their country.
The summary of substances that are certified as narcotic or psychotropic substance in Belgium, is available on the website of the FAMHP.
LONO for IMPORTING reference standards
The Article 31, §5 of the royal decree of 06/09/2017 regulating narcotics and/or psychotropic substances provide national exemptions for import authorisations for substances used for analytical purposes.
1° Reference standards in solution with a concentration not exceeding 1 mg/ml and a maximum content of 1 ml, which contain substances listed in annexes I, II, III of this royal decree (internationally controlled substances), on condition that the concerned laboratory reports to the Belgian Early Warning System on Drugs.
2° Reference standards in general (both in solution and pure form) that exclusively contain substances listed in annex IV of this royal decree (nationally controlled substances).
If a foreign supplier of these reference standards still requires a prior Belgian import authorisation, the FAMHP will issue a LONO for the import of these substances.
As the exemptions only apply to import authorisations, such a LONO can only be issued to holders of an activity licence or end user authorisation, authorised for the import of these substances.
Authorisation holders who have obtained an authorisation for all substances controlled in Belgium, such as toxicology laboratories, can be issued a general LONO IMPORT for which the exemptions applicable for import are valid for all substances controlled in annexes I, II, III and IV.
Authorisation holders who are licensed for specific substances may of course only obtain a LONO IMPORT for the licensed substances.
A LONO for a particular substance is valid for a maximum of one year because the legislation on narcotics and/or psychotropic substances is often adjusted.
For the same reason, a LONO for the import of annex IV reference standards is also only valid for a maximum of one year.
A LONO IMPORT for reference standards in solution (mg/ml) is valid until the end date of the end user licence and so for maximum three years.
As opposed to an import or export authorisation, a LONO can be used for several imports or exports, until the date of expiry.
Both types of LONO can be requested by sending an e-mail to email@example.com mentioning:
- the type of LONO requested and if applicable:
• the substance and the quantity;
• the number of the activity licence or end user licence.
• the invoice address
Since 05/04/2018, any LONO issued is subject to a fee. It currently amounts to € 44.63 and will be indexed each year.
This amount will be invoiced afterwards. Therefore, it is also requested to confirm the invoice address in the request email.